The Halverstone Group operates platforms and corporate systems that handle personal, commercial, and operational data on behalf of Group employees, shareholders, contracting authorities, and platform operators. This policy describes the Group's data stewardship practices under GCI Charter Article VII and applicable national data protection frameworks.
This privacy policy covers personal data collected through halverstonegroup.com, Group corporate operations, Group employee systems, and Group investor relations channels. It does not cover personal data collected through platforms operated by Group clients on Halverstone Systems infrastructure (such as the Continuity Assessment Platform operated by Humanitas Trust), which are governed by the operating client's own policies under Group platform-provider agreements.
The Group processes data in the following categories: corporate contact and procurement data; employee personnel and operational data; shareholder and investor relations data; press and media contact data; press, government affairs, and investor relations submissions; and continuity-screened recruitment data under Article XII consent.
For mission-critical recruitment pathways in Defense, Compliance, ISR, and Operations divisions, the Group receives continuity profile data from the Humanitas Trust Continuity Assessment network under formal partnership agreement and individual participant consent. Article XII of the GCI Charter governs the consent, data minimization, processing, and retention requirements for continuity-screened recruitment data.
Data is retained only as required for operating purposes, regulatory compliance, contractual obligation, and Charter reporting requirements. Continuity-screened recruitment data is retained for the duration of an active employment relationship and is purged within thirty days of separation or withdrawal of consent.
The Halverstone Group is subject to GCI Charter Article VII data stewardship requirements. Compliance is reported quarterly to the GCI Compliance Council and audited annually by the GCI-approved external audit panel.
For privacy inquiries, data access requests, or consent withdrawal, contact privacy@halverstonegroup.com or write to the Office of the Data Protection Officer, Halverstone Tower, Route de Florissant 1, 1206 Geneva, Switzerland.