Updated April 23, 2015.

SI is a United States company with no foreign offices or “offshoring” operations. SI prepares its reports based on information available in the United States. Even if a foreign element is involved, SI will attempt to obtain the information through domestic means and sources. In instances that necessitate an in-country verification or research, SI obtains the information directly from the source or, if applicable, through research by a member of our established network of carefully-vetted subcontractors. Documentation or information such as passport numbers and dates of birth are not sent to anyone overseas other than the actual verification provider (e.g. school registrar) whenever possible. As indicated in this Policy, SI complies with the U.S.-E.U. Safe Harbor and the U.S.-Swiss Safe Harbor frameworks as set forth by the U.S. Department of Commerce regarding the collection, use and retention of personal information from European Union (“E.U.”) member countries and Switzerland, and requires its foreign subcontractors to sign contracts affirming that they will perform SI’s assignments in accordance with these privacy frameworks and applicable laws and regulations. For non-member countries, also pursuant to contractual agreements, we require that our subcontractors maintain adequate safeguards with respect to the protection of data privacy and the corresponding rights of individuals.