International Transfer Statement

Bloomberg · Official agreement

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7 of 13 cards in Legal Rights & Agreement Rules

Legal Rights & Agreement Rules · Context

What this Statement covers

This Statement is Bloomberg's description of the measures it puts in place to protect personal information it transfers. It is issued by Bloomberg Finance L.P., its operating agent Bloomberg L.P., and affiliates, who are together called "Bloomberg", and it states that they are committed to complying with their data protection obligations worldwide.

Supporting quotations

Bloomberg Finance L.P., its operating agent Bloomberg L.P., and affiliates (“Bloomberg”)
sets out information about the measures we put in place to protect personal information we transfer

Qualifications & exceptions

  • Describes measures Bloomberg says it has in place; it is a statement of practice and does not itself grant rights to any individual.
  • "Bloomberg" is defined to include Bloomberg Finance L.P., Bloomberg L.P. and affiliates.

Not stated here

  • The Statement does not say which personal information is transferred, whose it is, which countries it goes to, or which Bloomberg products or services it relates to.
  • The Statement does not name the specific data protection laws it refers to.

Legal Rights & Agreement Rules · Company practice

IGAs incorporate Standard Contractual Clauses for EU, Swiss and UK information

As an example, for personal information that originates in the European Union, Switzerland or the United Kingdom, the IGAs incorporate EU Commission-approved Standard Contractual Clauses (SCCs), which include specific obligations and rights around transfers. The IGAs also contain amendments that applicable data protection law requires so that their application extends to transfers from non-EU jurisdictions, where relevant.

Supporting quotations

for personal information originating in the European Union, Switzerland or the United Kingdom, the IGAs incorporate EU Commission-approved Standard Contractual Clauses (“SCCs”), which include specific obligations and rights around transfers of personal information
The IGAs will also contain amendments required by applicable data protection law to extend their application to transfers of personal information from non-EU jurisdictions, where relevant

Qualifications & exceptions

  • Introduced as an example ("For example"), so the Statement does not present it as a complete list of the regimes it handles.
  • The non-EU amendments apply only "where relevant" and only to the extent applicable data protection law requires them.

Not stated here

  • The Statement does not list the non-EU jurisdictions or say how the IGAs are amended for them.
  • The SCC text and the contents of the amendments are not supplied.

Legal Rights & Agreement Rules · Company practice

Governance program and compliance working group

Bloomberg says it maintains a personal information governance program, regularly reviews and updates its governance framework (including personnel roles and responsibilities), and maintains a working group that oversees compliance with data protection regulation and documents results and decisions about personal information management.

Supporting quotations

We maintain a robust personal information governance program
maintain a working group to oversee data protection regulation
document results and decisions as they relate to personal information management

Qualifications & exceptions

  • This is Bloomberg's description of its own internal practice, given as one of the safeguards in the IGAs.

Not stated here

  • The Statement does not say how often "regularly" is, who sits on the working group, or whether results are reported outside Bloomberg.

Legal Rights & Agreement Rules · Company practice

Policy reviews and privacy training

Bloomberg says it regularly reviews and updates its policies, procedures and controls to address its data protection obligations. It also says it conducts company-wide privacy training, data protection executive education and tailored training programs for data protection compliance.

Supporting quotations

We regularly review and update our policies, procedures, and
controls to address our data protection obligations
We conduct company-wide privacy
data protection executive education and tailored training programs for data

Qualifications & exceptions

  • Internal administrative practice described in general terms.

Not stated here

  • The Statement does not give review or training frequency, or who is covered by the tailored programs.

Legal Rights & Agreement Rules · Company commitment

Data Privacy Framework certification for certain group members

Bloomberg says it has certified to the U.S. Department of Commerce that certain Bloomberg group members adhere to the EU-U.S. Data Privacy Framework, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework. It points to a separate Data Privacy Framework Notice for more information.

Supporting quotations

Bloomberg has also certified to the U.S. Department of Commerce that certain Bloomberg group members adhere to the EU-U.S. Data Privacy Framework
the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework

Qualifications & exceptions

  • The certification is for "certain" Bloomberg group members, not stated to be all of them.

Not stated here

  • The Statement does not name the certified group members.
  • The Data Privacy Framework Notice it links to is not supplied in this source.

Legal Rights & Agreement Rules · Procedure

Where to send questions or comments

Questions or comments about this Statement should be submitted to privacy@bloomberg.com.

Supporting quotations

Contact information
Questions or comments regarding this Statement should be submitted to
privacy@bloomberg.com

Qualifications & exceptions

  • Covers questions or comments about the Statement itself.

Not stated here

  • The Statement does not describe a response time or process, or any rights request procedure.

Legal Rights & Agreement Rules · Permission or license

Bloomberg may change the Statement at any time

Bloomberg reserves the right to change this Statement at any time. Revisions are indicated through the date at the top of the Statement, and changes take effect when posted. The version supplied here carries the date "As of October 29. 2024".

Supporting quotations

Bloomberg reserves the right to change this Statement at any time by indicating revisions through the date at the top of the Statement
Such changes will be effective upon posting
As of October 29. 2024

Qualifications & exceptions

  • Notice of changes is described only as a revised date at the top of the Statement.
  • Changes are "effective upon posting", with no advance period stated.

Not stated here

  • The Statement does not say Bloomberg will notify people directly of changes.
  • The date line reads "October 29. 2024" with a period after the day; the Statement does not say whether that is the effective date or the last revision date, and it names no successor version.