Companies come to TRUSTe when they’re concerned about the protection of HR/employee data in their global operations. US human resources teams especially want to mitigate their HR data risks when expanding or acquiring operations in Europe that require workforce data transfers from the EU to the US.

To achieve this objective, a successful certification of HR Data under the US-EU and US-Swiss Safe Harbor Framework (the “Safe Harbor Framework”) becomes critical. TRUSTe Privacy Consultants deliver HR Data US-EU Safe Harbor Assessments to analyze and verify compliance under the Safe Harbor Framework, thereby enabling your organization’s continued expansion within the European Community.

Key Benefits


  • Independent compliance verification to prepare for self-certification of HR data under the Safe Harbor Framework and enable international business expansion
  • Detailed and actionable reports to implement immediate steps for privacy compliance
  • Full-service team of privacy experts by your side throughout the assessment process
  • Legal knowledge with practical business process implementation experience
  • Powered by TRUSTe’s Data Privacy Management (DPM) Platform’s state-of-the-art privacy technology for assessment management, compliance control, and website monitoring
  • Key regulatory relationships as a leading service provider for several of the world’s regulatory and self-regulatory compliance agencies
  • Rapid response, in as little as 4 to 6 weeks, dependent on scope and complexity
  • Streamlined process minimizes disruption to your daily business operations


Our People

All of our Privacy Consultants are recognized data privacy experts with significant experience leading global privacy assessments for large enterprises. As the leading privacy brand, we’ve become one of the most experienced and innovative Data Privacy Management companies in the world, with offices in the US, EU, and Asia. Our privacy experts assist clients with all of their privacy compliance needs.

Established Assessment Methodology

TRUSTe has an established assessment methodology based on almost two decades of experience delivering privacy services to thousands of clients around the world. Privacy Consultants deliver the HR Data US-EU Safe Harbor Assessment in a streamlined 5-step process.

1: Data Discovery

TRUSTe works with you to identify relevant employee data flows. We conduct initial interviews with relevant subject matter experts within your organization to understand the HR data life cycle.

TRUSTe then conducts in-depth interviews on site or remotely to fully map HR data flows from the point of data collection, storage and processing, resources involved in processing data (internal systems, third party service providers, cloud providers), and retention and deletion practices. In addition, we work with your team to gather supporting documents, including employee privacy policies, handbooks, and training materials.

2: Risk Classification

Armed with information from the Data Discovery, we help you organize the data by type, purposes, uses, and associated risk levels. We perform an HR data lifecycle analysis and review supporting documents, including employee privacy policies, handbooks, training materials, data collection from the point of job application through on-boarding, post-separation data storage, access and deletion practices. We analyze any issues concerning vendors and service providers such as payroll and benefits services that are reliant on your organization’s core HR system of record data.

3: Policy & Practices Compliance Review

Our consultants analyze your stated privacy policies and data management practices alongside the US-EU and US-Swiss Safe Harbor Framework and against industry best practices to identify your organization’s privacy risk and prioritize your remediation activities. Our methodology includes a broad look at risk factors, including those introduced by service providers, vendors and other third parties.

4: Findings Report & Gap Analysis

From this discovery, our consultants provide you with a Findings Report & Gap Analysis outlining the full HR data lifecycle analysis and risk classification, and describing any gaps found versus the US-EU and US-Swiss Safe Harbor Framework and against industry best practices. For each gap, TRUSTe provides a recommended remediation measure, with required and best practice changes.

5: Policy & Practices Change Guidance

Armed with our gap analysis and remediation recommendations, TRUSTe can assist in the development of policies and training programs, provide sample language and templates, validate remediation steps, and help you prepare for the self-certification process under the U.S. Department of Commerce.

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