Change History for HP Binding Corporate Rules
August 2024
- The EU Public Version is now available in all languages in the EU.
- Section 1: More details about HP's commitment to the BCR have been included.
- Section 2: List of the rights conferred under the BCR has been included.
- Section 3.5: Wording adjustment for the role of HP as data processor has been made.
- Section 3.6: Details about the use of automated decision making have been updated.
- Section 3.7: Details about onward transfers for the role of data controller have been updated.
- New section 3.8 for the principle of Accountability.
- Section 4.1: Details for Governance including contact details for DPO have been included.
- Section 4.3: Details about making audits available to DPAs have been included.
- Section 4.5: Right to lodge a complaint before competent court has been included in the rights list.
- New section 5.1.1: Consequences of submitting a complaint have been included.
- Section 5.2: Details about complaint escalation have been updated.
- Section 5.3: Details about third-party enforcement rights have been updated.
- New Appendix 2: A table describing the data flows for international transfer has been included.
- Appendix 3: Glossary has been updated.
February 2024
- HP Inc. EU BCR Public Version has been updated with the following changes:
- Introduction: The introduction section has been updated to include the references to the CNIL as the lead authority, the recognition of the HP EU BCR by the Swiss authority, and the site where the list of HP EU BCR entities is located.
- Summary of the HP EU BCR: The section has been updated to clarify the distinction between HP's role as a data controller and a data processor, and to provide more details on the principles and obligations of the HP EU BCR. Details about contingent workers have been included, and a note for HP employees has been included.
- Scope of the HP EU BCR: The section has been updated to include a reference to data relating to criminal convictions and offences, and small wording changes have been made to provide more clarity, especially for HP’s role as Processor. Some references to non-applicable transfer mechanisms have been removed from the text.
- HP's commitments: The section has been updated to include additional details for rights of data subjects, and to present them in a high-level format. Small wording changes have been made to provide more clarity.
- Submitting a complaint and enforcing the HP EU BCR: The complaint section has been updated to provide more information on HP's complaint handling process (such as details for HP Employees, specific timeframes for responding to submissions, and more details for the process for HP as a Processor).
- HP EU BCR Entities: A new section has been created to specify that Appendix 1 contains a list of all HP Entities bound by the HP EU BCR.
- Updates to this HP EU BCR Public Version: A new section has been created to provide details about updates to the document.
- Contact Information: A new section has been created to provide clarity about the channel for communication with HP. Appendix 1: This new appendix has been created to provide contact details for all HP entities bound by the HP EU BCR.
January 2024
- The list of HP BCR Members has been updated to reflect changes to the legal or business name of some Members.
If you have any questions regarding HP BCRs, please contact our Trust and Privacy Organization on the “HP Chief Privacy and Data Protection Officer ” form, and select the option “Privacy/data protection question”, and then select “International Data Transfers”.
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