Owner: Privacy Department
Approver: Global Privacy Officer
Version: January 2024
Last Review: January 2024

Introduction

We are disclosing information about our data processing practices as required by the United Kingdom’s Data Protection Act 2018 (DPA) and the General Data Protection Regulation (GDPR). This DPA/GDPR Addendum supplements the information contained in the Bright Horizons Global Consumer Privacy Notice. This Addendum applies exclusively to Consumers using Services in the United Kingdom, Ireland, the Netherlands and any other country within the European Economic Area.

What legal basis do we rely on to process your personal information?

Bright Horizons relies on the following legal basis for processing your personal information. 

• Performance under a Contract: For Consumers, most of the personal information we process is necessary for us to perform our obligations under a contract we have with you, and, if applicable, your employer when you receive the Service as an employee benefit.
• Legal Obligations: For Consumers, there are many laws that require us to process your personal information. Examples include law and regulations for child/adult care, safeguarding, health and safety, tax and government funding.
• Legitimate Interest: For Consumers, we have a legitimate interest in processing some of your personal information in some circumstances. We will only process your personal information if our legitimate interests do not override your fundamental rights, freedoms and interests. For any questions regarding this legal basis, please contact our Global Privacy Officer at dataprivacy@brighthorizons.com. Some examples of our legitimate interests include:
  • Use of your email address to send you newsletters, invitations to webinars, or information about your services or new/enhanced Service updates.
  • Analysing your digital information and monitoring your digital experience (such as IP, browser, swips and error message information to improve the website experience for you and provide support. ‘Session’ cookies help you navigate through BH websites efficiently and are temporary and ‘persistent’ cookies are small files left on your device that store your user preferences for current and successive visits to Bright Horizons websites. Learn more about how we use cookies and similar technologies by clicking here.
  • In some locations, we use Closed Circuit (CCTV) for security/safety of our consumers, staff and premises; to help prevent and detect crime; to support learning and training; and/or to defend legal claims.
  • Recording your contact center calls to assist us with monitoring our policies and procedures; identifying opportunities for training and development; and improving Services to you.
  • For consumers receiving our services as an employee benefit, we will use the information provided to us from your employer and you to create reporting and analytics information that inform us and your employer of registration for and use of the services, as well as for quality improvement of services (including as necessary anonymization of your personal information for these purposes).
• Special Categories of Personal Information: Depending upon our relationship with you, (consumer, staff or supplier), we may need to process special categories of personal information in order to employee you or evaluate whether Services are suitable for the care requested and/or to provide the Services safely and/or effectively. In some locations, government regulations/laws require us to process special categories of personal information. Special categories of personal information that we may process include information relating to:
• Health data:
  • when receiving adult/child care services, in order for us to provide the Services safely and/or in compliance with applicable law, you may need to provide us with health data of the dependent we care for (for example to inform us of allergies, medicines, special physical or educational requirements, health conditions).In addition, this type of information may be provided to us by a government body;
  • when receiving personal or family coaching or special educational needs services, you may voluntarily provide us with health data about you / your dependents to enable us to provide the advice services; and your employment.
• Race/ethnic origin: you may provide this information to us voluntarily when receiving College Coach services (for example to assist with identifying schools, scholarships, etc.).
• Trade union membership: your employer may provide this information to us to assist with determining levels of employee’s eligibility for our EdAssist services;

International Transfers and Adherence to the EU-U.S. Data Privacy Framework (and UK Extension)

We may process some of your personal information outside the UK / EEA as applicable. Whenever we transfer personal information out of the UK / EEA, we ensure a similar degree of protection is afforded to it by putting in place appropriate safeguards and protections.

For transfers to the United States, Bright Horizons Family Solutions LLC is certified to the EU-U.S. Data Privacy Framework and its UK Extension (“DPF”) and complies with its requirements as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information we transfer from the United Kingdom and European Union to the United States in reliance on the DPF. Bright Horizons Family Solutions LLC has certified to the Department of Commerce that it adheres to the DPF Principles. The Federal Trade Commission has jurisdiction over our compliance with the DPF.

If there is any conflict between the terms in our Global Privacy Notice and the DPF Principles, the DPF Principles shall apply. To learn more about the DPF and view our certification, please visit https://www.dataprivacyframework.gov/.

There is an independent dispute resolution body designated to address complaints and provide appropriate recourse, free of charge to you, as follows: for EU / EEA personal data: the panel established by the EU data protection authorities (DPAs); for UK personal data, the UK Information Commissioner’s Office (ICO).

In addition, under certain circumstances, you have the right to invoke binding arbitration for complaints regarding our DPF compliance that you have been unable to resolve through any of the other DPF mechanisms. To learn more about the binding arbitration mechanism, please visit https://www.dataprivacyframework.gov/Program-Overview.

In compliance with the DPF Principles, Bright Horizons Family Solutions LLC commits to the following:

• Resolve complaints about our collection or use of your personal information. If you have questions or complaints regarding our adherence to the DPF, please contact our Global Privacy Officer at dataprivacy@brighthorizons.com or Pioneer House, 7 Rushmills, Northampton, NN4 7YB United Kingdom.
• Cooperate with the panel established by the EU data protection authorities (DPAs) / the UK ICO and comply with the advice given by the panel / the ICO with regard to personal information transferred from the European Union. / the UK (as applicable).
• Remain responsible and liable for the processing of personal information we receive under the DPF and subsequently transfer to a third party acting as an agent on our behalf.

Read about who we share your information with here.

What rights do you have over your personal information?

You have the right to request:

• Access to the personal information we hold about you, free of charge in most cases.
• The rectification of your personal information to ensure that it’s up-to-date, accurate and complete.
• The erasure of your personal information (subject to certain exemptions).
• We stop processing your personal information for direct marketing purposes (either through specific channels or all channels).
• We and other third parties cease processing your personal information when this was previously undertaken based on your consent and you’ve now withdrawn that consent.

How do you make a request about your personal information?

To read about how to amend your information or update your email list preferences, click here.

You can complete our Webform to make a request to access/receive a copy of your personal information or for us to correct or delete your personal information (or exercise any of your other rights).

You can also contact the Global Privacy Officer at dataprivacy@brighthorizons.com.

Please note:

• Only you (or your authorized legal representative) may make a request related to your personal information.
• In order to authenticate and process your request, you will need to:
  • provide sufficient information that allows us to reasonably verify you are the person about whom we processed personal information or a legally authorized representative; and
  • describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• We will not be able to respond to your request if we cannot verify your identity or legal authority to make the request and confirm the personal information relates to you or the subject of the request.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal information (or to exercise any of your other rights). This is a security measure to ensure that personal information is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

In circumstances where we are processing your personal information based on our legitimate interest, you can ask us to stop for reasons connected to your individual situation. We must then do so unless we believe we have a legitimate overriding reason to continue processing your personal information that doesn’t infringe your rights and freedoms. You have the right to challenge our decision to the Supervisory Authority or seek legal redress through the courts.

If you feel that your personal information hasn’t been handled correctly, or you are unhappy with our response to any requests you have made regarding the use of your personal information, you have the right to lodge a complaint with the relevant Supervisory Authority.

• UK Supervisory Authority: Information Commissioner’s Office at www.ico.org.uk/concerns (opens in a new window; please note we can't be responsible for the content of external websites.)
• Ireland Supervisory Authority: Data Protection Commissioner/An Coimisinéir Cosanta Sonraí at dataprotection.ie/docs/Home/4.htm (opens in a new window; please note we can't be responsible for the content of external websites.)
• The Netherlands Supervisory Authority: Autoriteit Persoonsgegevens (Dutch Data Protection Authority – Dutch DPA) at https://autoriteitpersoonsgegevens.nl/en/contact-dutch-dpa/contact-us (opens in a new window; please note we can't be responsible for the content of external websites.)