Data Privacy Policy 1

Immigration Support Services (ISS) take the privacy of your personal data very seriously.  In an effort to provide you with specifics concerning this commitment we provide the following Privacy Policy, which may be updated and modified from time to time.  If you have any questions or concerns regarding the privacy or confidentiality of your personal data or information please contact the Data Privacy Manager whose contact information is listed at the end of this document.

Immigration Support Services, a dba of Brookwood Technologies, Inc. a Pennsylvania corporation, (ISS) provides a full range of immigration services for companies and individuals seeking one or more immigration benefits related to working and living in the United States.  In addition we provide other services needed to prepare and file for and receive approvals for immigrant and nonimmigrant visas or other immigration related benefits.

Purpose of this policy

This policy explains how we collect, store, process, and disclose your personal data, and also sets out your rights related to our collection, storage, processing, and disclosure of such personal information.

Data collected

For the purposes of providing  you and your employer with comprehensive immigration services U.S. immigration law requires ISS to collect a broad range of personal and family related information called ‘personal data’ or ‘personal information’.  Some of these data include sensitive information such as personal identifiers such as name, address, social security or individual tax ID numbers, alien numbers; biographic information revealing racial and ethnic origin, sexual orientation; legal information including criminal background; financial and tax information; employment history; and other information related to global immigration and employment. 

ISS limits data collection to only those data specifically required by statute and regulation for the particular petition prepared or service rendered on your behalf.  You may inadvertently provide additional information and data when you send ISS forms and documents you are required to submit.  This policy covers all the personal data you or your employer provides to ISS in whatever form it is received.

These data are collected by entries you or your employer make at ISS’ secure website; from documents, forms and information you provide; from documents, forms and information provided by your employer; and other means needed to fulfill our obligations to provide the contracted services.

Legal basis for collecting your data

ISS collects, stores, processes, and discloses your personal data because there are lawful reasons to do so.  These lawful reasons include:

1. The processing of your personal data is necessary for compliance with legal obligations defined by the Immigration and Naturalization Act (INA), 8 CFR, 20 CFR, and 22 CFR of the U.S. Code of Federal Regulations and any other relevant regulations of the U.S. Citizenship and Immigration Service (USCIS), the U.S. Department of Labor (DOL), U.S. Department of State (DOS) and other pertinent government agencies, to which ISS and you are subject in fulfillment of the contracted immigration services.   
2. The processing of your personal data is necessary for the performance of a contract between ISS and you or between ISS and your employer regarding the services we provide.
3. You have given affirmative permission and consent to ISS for the processing of your personal data for the purposes of obtaining certain immigration related benefits.

Sharing your personal data

ISS will not share your personal information and data with any third party for any purpose whatsoever unless it is required to provide the services for which you have hired ISS and only then limited by the terms of this policy.

ISS will not share your personal data with any third party not an integral part of the services provided unless subject to a lawful court order to do so.  ISS will not use your personal data for the purposes of marketing products or services not related to the immigration services for which we have been retained.

Your personal data may be shared with employees and contractors of ISS, as well as, your employer but only to the extent needed to accomplish the services ISS is under contract to provide. 

ISS may share your personal data with the USCIS, the DOL, the DOS and any other government agencies essential to the completion of the contracted services.

As mentioned above, ISS may appoint sub-contractor data processors as required to deliver the services, such as, without limitation, document processing and translation services, IT systems or software providers, IT Support service providers, and document and information storage providers, who may process personal information on behalf of and at the direction of ISS.

Further, ISS may appoint external data controllers where necessary to deliver the services (for example, but without limitation, accountants, attorneys, consultants and other third party experts including, but without limitation, other ISS employees, as well as other law firms). When doing so, ISS will comply with the terms outlined in this policy in relation to the processing of personal information including, but without limitation, putting appropriate safeguards in place.

Specifically ISS utilizes software and services provided by INSZoom.com, Inc. to manage and store your data and to assist in providing the contracted services.  INSZoom.com, Inc. is a Privacy-by-Design company and possesses ISO 27001 certification.  All data is formatted and stored in an Encrypted SQL Database.

Retention of Personal data

ISS generally retains files and information regarding client engagements and matters for which we have been retained for at least seven years from the date of our last interaction, or for longer where required by our regulatory obligations, professional indemnity obligations, or where ISS believes necessary to establish, defend, or protect our legal rights and interests or those of others. We may then destroy such files without further notice or liability.

Confidentiality and security of your personal data

ISS is committed to keeping personal information and data secure and have implemented appropriate information security policies, rules and technical measures to protect the personal information that we have under our control from unauthorized access, improper use or disclosure, unauthorized modification and unlawful destruction or accidental loss.  Please note that no transmission over the Internet is completely secure or error-free, and that the information security policies, rules and technical measures utilized and maintained may be subject to compromise.

All of ISS partners, employees, consultants, workers and data processors (i.e., those who process your personal information on our behalf, for the purposes listed above), who have access to, and are associated with the processing of personal information, are aware of the need to respect the confidentiality of such personal information.

How to access your information and your other rights

You have the following rights in relation to the personal information ISS holds about you:

Your right of access
If you ask, ISS will confirm whether we are processing your personal information and, if necessary, provide you with a copy of that personal information for which we reserve the right to charge a reasonable fee.

Your right to correction or rectification
If the personal information ISS holds about you is inaccurate or incomplete, you are obligated to correct it.  Indeed it is essential that all of the information ISS holds on your behalf is as accurate and complete as possible.   If you ask, we will also tell you, where possible and lawful to do so, with whom we have shared your personal information so that you can contact them directly if you desire.

Your right to erasure
You may ask ISS to delete or remove your personal information in some circumstances, such as where ISS no longer needs it or if you withdraw your consent (where applicable). If you ask, ISS will tell you, where it is possible and lawful to do so, with whom we have shared your personal information so that you can contact them directly.  You understand that if you exercise your right to have your data erased ISS may not be able to perform the contracted services and may no longer be able to represent you or your interests regarding the contracted services.  You also understand that under certain circumstances you and/or your employer may be responsible for paying fees and costs associated with the services even if the services cannot be completed due to your exercise of your right of erasure.

Your right to restrict (block) processing
You may ask ISS to restrict the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information. If you ask, ISS will tell you, where it is possible and lawful to do so, with whom we have shared your personal information so that you can contact them directly.  You understand that if you exercise your right to restrict or block processing then we may not be able to perform the contracted services and may no longer be able to represent you or your interests regarding the contracted services.  You also understand that under certain circumstances you and/or your employer may be responsible for paying fees and costs associated with the services even if the services cannot be completed due to your exercise of your right to restrict.

Your right to data portability
You have the right, in certain circumstances, to receive a copy of personal information we have obtained from you in a structured, commonly used and machine readable format (e.g. PDF), and to reuse it elsewhere for which we reserve the right to charge a reasonable fee.

Your rights in relation to automated decision-making and profiling
ISS does not engage in automated decision-making as all decisions regarding the services we provide to you are executed, controlled, monitored or supervised by one of our attorneys,  employees or contractors.  However you should know that you have the right not to be subject to a decision when it is based on automatic processing, including profiling, if it produces a legal effect or similarly significantly affects you, unless such profiling is necessary for entering into, or the performance of a contract between you and ISS. 

Your right to withdraw consent
If ISS relies on your affirmative consent (or explicit consent) as the legal basis for processing your personal information; you have the right to withdraw that consent at any time.

Your right to lodge a complaint with the supervisory authority
If you have a concern about any aspect of our privacy practices, including the way ISS has handled your personal information, you may report it to the relevant supervisory authority.

Please note that some of these rights may be limited where ISS has an overriding legitimate interest or legal obligation to continue to process the personal information, or where the personal information may be exempt from disclosure due to applicable law, the applicable rules of professional conduct, attorney-client privilege, legal professional privilege, other applicable privileges or protections, or professional confidentiality obligations.

Changes to this privacy policy

ISS may make changes to this Privacy Policy from time to time, to reflect changes in our practices. ISS may also make changes as required to comply with changes in applicable policy or regulatory requirements. Where ISS materially changes this Policy, we will take steps to notify you (such as by posting a notice on our website or via email), and where required to obtain your updated consent.

Who to contact with questions or concerns

Immigration Support Services

2215 Millennium Way

Enola, PA 17025

Data Privacy Manager

800-437-7173

DataPrivacyManager@immigrationsupport.com