Service Providers Privacy Notice

MACMILLAN PRIVACY NOTICE FOR SERVICE PROVIDERS/CONTRACTORS and CONTRACTED STAFF

Effective June 2023

All of the companies in US Macmillan trade publishing and Macmillan Learning[1], (collectively, “Macmillan”), are committed to protecting the privacy of all individuals who interact with Macmillan. This Privacy Notice is designed to provide you with an overview of our practices regarding the personal information we collect, use, store and, when necessary, transfer, in connection with your business relationship with us.

For additional information and to learn about how we handle personal information subject to the California Consumer Privacy Act and other laws, please visit: https://us.macmillan.com/privacy-notice.

  1. Macmillan has a global privacy program that protects your personal information no matter how or where it is processed or stored.
  2. We collect, use, store and, when necessary, transfer, personal information through automated and paper-based data processing systems. We may also process your personal information on an occasional or ad hoc basis.
  3. We have implemented an information security program that is reasonably designed to protect the confidentiality and security of your personal information.
  4. In many cases, we collect personal information directly from you. We may also obtain information about you from third parties, such as the company that employs you (if you work for a Macmillan supplier) or your references. We may collect information about you automatically when you use our computer systems, participate in our social media programs or, if you have access to our offices, when you swipe your access badge.

    Examples of the types of personal information that we may collect, use, store and, when necessary, transfer, include:
  • Contact and identification information (such as your name, address, and government-issued identification numbers),
  • Payment and tax information,
  • Job-related information (such as assignment details, and if applicable, travel and expense data and performance-related records),
  • Voice recordings from narrators,
  • Demographic information, including (if you voluntarily provide it) information about your race, ethnicity and disabilities for supplier diversity purposes or to promote authenticity in projects that you may be working on,
  • Information needed for security, legal compliance and risk management and
  • Your image, which you may submit to us, or which may be collected by our security monitoring cameras or when you participate in public group discussions or video conferences

Additionally, if you have access to our computer systems or facilities, we will collect information related to your use of company technology. We reserve the right, subject to applicable law, to access, inspect, disclose, and dispose of any electronic files, data, and messages created, stored, sent, or received through our systems as needed to protect our interests and satisfy our legal obligations.

  1. We collect, use, store and, when necessary, transfer your personal information for customary business purposes, as permitted by law. In particular, we will process your personal information as needed to develop and maintain our business relationship with you, including:
  • Supplier due diligence, such as verifying your qualifications for projects and ability to meet contractual requirements,
  • Negotiating contracts and related documents (such as statements of work), including quality control activities,
  • Overseeing the performance and delivery of good and services,
  • Processing invoices and other accounts payable functions,
  • Closely-related activities, such as providing customer service, recordkeeping and reporting (including reporting related to supplier diversity programs),
  • Conducting background checks as applicable,
  • Administration of diversity programs,
  • Workplace administration tasks (such as managing Macmillan computers and other assets) and facilitating relationships within Macmillan and with our clients,
  • For occupational health and safety programs (including required reporting, disaster and pandemic planning, and incident management),
  • For training,
  • For risk management, including premises monitoring as set forth in other policies

We may also process your personal information for everyday business purposes, such as:

  • Identity and credential management, including identity verification and authentication, issuing ID card and badges (if applicable), system administration and processing data for information security and cybersecurity purposes by our security program technologies,
  • Legal and regulatory compliance: all uses and disclosures of personal information that are required by law or for compliance with Macmillan policies and procedures, such as our fraud prevention programs, security and incident response programs, intellectual property protection programs, and corporate ethics and compliance hotlines,
  • Corporate audit, analysis and consolidated reporting,
  • Making back-up copies for business continuity and disaster recovery purposes, and
  • To facilitate corporate governance, including mergers, acquisitions and divestitures.

We may disclose your personal information in the following circumstances:

  • To other Macmillan affiliates which will handle your personal information in accordance with this Privacy Notice,
  • To our third-party vendors, which use the data only as permitted by our contracts with them, and to those companies that provide benefits and services to you,
  • When required by law, including to law enforcement agencies and courts in all of the countries where we operate,
  • When permitted by law, such as to our auditors and advisors, in connection with internal investigation or audit,
  • With your consent or as reasonably needed to protect your vital interests, such as in the event of an emergency or natural disaster, and
  • To an acquiring organization if we are involved in a sale or a transfer of some or all of our business.

We may also disclose your information to other third parties as needed for the purposes of our contracts. For example, if you are employed by a Macmillan supplier, we may disclose your information to your employer to facilitate our business contract with that company. We may also disclose your information to our clients and authors, to the extent that your project involves them.  We will never sell your information for monetary consideration to third parties.

  1. Your personal information may be transferred to, stored at or processed in a location outside the country of your contracted work which may not have equivalent privacy or data protection laws. However, regardless of where your personal information is transferred, we will protect it in accordance with this Privacy Notice.
  2. We will retain your personal information as needed for business and compliance purposes in accordance with our retention policies and applicable law.
  3. You have shared responsibility with regard to the accuracy of your personal information. For Macmillan Learning, please click here and for Macmillan Trade please click here to access and update your personal information and other personal information that you have provided and that you have on file with us. All Macmillan service providers/contractors and contracted staff whose responsibilities include collecting, processing or storing personal information for us are expected to assist in the protection of that information, by adhering to this Privacy Notice as well as the Macmillan Publishers Privacy and Cookies Notices, the Macmillan Learning Privacy Notices, the Electronic Devices and Systems Policy, the Personal Device Policy, all to the extent applicable. If you process any personal information for or on behalf of us, we have the right to monitor your compliance with our policies during normal business hours and without prior notice, or our authorized representatives may inspect your facilities and equipment and information or materials in your possession, custody or control, relating in any way to your obligations under our policies. An inspection performed pursuant to this policy shall not unreasonably interfere with the normal conduct of your business and you shall cooperate fully with any such inspection initiated by us.
  4. If you have any questions about privacy or the security of your personal information, please contact [email protected]. As part of our commitment to you, we will try to resolve any questions or concerns that you may have.

[1] Holtzbrinck Publishing Holdings Limited Partnership; Holtzbrinck Publishers, LLC; Macmillan Publishing Group, LLC Bedford, Freeman and Worth Publishing Group, LLC; Hayden McNeil, LLC; and EBI Map-Works, LLC