International Transfer Statement

Bloomberg · Official agreement

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Sharing & Disclosure · Company practice

Transfers to Bloomberg group members overseas use intra-group agreements

When Bloomberg transfers personal information to Bloomberg group members overseas, the relevant group members enter into Intra-Group Personal Data Protection Agreements (IGAs). Each IGA identifies which group member is the data exporter and which is the data importer. Bloomberg says the IGAs ensure the transferred information is subject to appropriate safeguards, as applicable data protection laws require.

Supporting quotations

where Bloomberg transfers personal information to Bloomberg group members overseas, the relevant Bloomberg group members enter into appropriate Intra-Group Personal Data Protection Agreements (“IGAs”)
which identify the Bloomberg group members acting as data exporter and data importer
ensure that personal information transferred overseas is subject to appropriate safeguards, as required by applicable data protection laws

Qualifications & exceptions

  • Applies where Bloomberg transfers personal information to Bloomberg group members overseas.
  • The safeguards are described as those "required by applicable data protection laws"; the Statement does not say what those laws require.

Not stated here

  • The text of the IGAs is not supplied in this source.
  • This passage covers transfers to Bloomberg group members only; transfers to other recipients are not addressed in it.

Sharing & Disclosure · Company practice

Company-wide approach to government and law enforcement requests

Bloomberg says it takes a company-wide approach to disclosure to law enforcement, government and regulatory agencies. The approach goes beyond personal information and applies to all client data. For more detail the Statement points readers to Bloomberg's Law Enforcement Data Request Statement, which is not part of this source.

Supporting quotations

We take a company-wide approach to law
enforcement, government, and regulatory agency disclosure, which extends beyond personal
and applies to all client data
Please see our Law Enforcement Data Request

Qualifications & exceptions

  • The approach is described as covering all client data, not only personal information.

Not stated here

  • The Statement does not say when Bloomberg discloses information to authorities, whether it notifies the people affected, or whether it challenges requests; those details are left to the separate Law Enforcement Data Request Statement, which is not supplied here.