This analysis describes what ADP's agreement states, permits, or reserves. It does not constitute a legal determination about enforceability. Regulatory applicability and practical outcomes may vary by jurisdiction, enforcement context, and individual circumstances. Read our methodology
Individual notification is conditional on a high-risk-of-harm determination, meaning individuals assessed as lower risk may not receive direct breach notification.
Interpretive note: The excerpt ends with condition (a), implying there may be additional conditions (b), (c), etc. that govern individual notification obligations but are not present in the quoted text. Only condition (a) is stated in the canonical claim.
If you are determined to be at a high risk of harm following a Data Security Breach, ADP must notify you within a reasonable period of time after making that determination.
How other platforms handle this
When legally permitted to do so, and under appropriate circumstances, Patreon will attempt to notify you by contacting you at the e-mail address and/or phone number you provided when creating your Patreon account when we intend to release your data pursuant to a valid government request...
California's Generative Artificial Intelligence (GenAI) Training Data Transparency Act requires developers of GenAI systems available to California residents to post details on the data used for training their systems on their websites.
If required by applicable laws, we will use reasonable efforts to notify you of any transfer of personal information to an unaffiliated third-party.
"ADP shall notify Individuals of a Data Security Breach within a reasonable period of time following determination of such Data Security Breach if (a) the Individual is at a high risk of harm...Excerpt from ADP's Privacy Statement
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Individual notification is conditional on a high-risk-of-harm determination, meaning individuals assessed as lower risk may not receive direct breach notification.
If you are determined to be at a high risk of harm following a Data Security Breach, ADP must notify you within a reasonable period of time after making that determination.
ConductAtlas has identified this type of provision across 266 platforms. See the full comparison.
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