Bright Horizons’ Transparency Report - Public Authority Requests

Last Updated: January 2024

In relation to international terrorism, counterespionage, surveillance, or foreign intelligence investigation, unless required by law, Bright Horizons will not allow access to any data it processes to public authorities.

Upon receipt of such a request, Bright Horizons will review its legality and consider whether it satisfies all the applicable requirements under law.  To the extent permitted under law, if the request includes access to client data, Bright Horizons will notify the relevant client(s).

If Bright Horizons determines that the request is not lawful, it will: (i) pursue a legal remedy to prevent access; (ii) formally object in writing, that the public authority comply with the law; (iii) where applicable, inform the public authority that the request is incompatible with Article 46 of the General Data Protection Regulation; or (iv) take any other action that is lawful and appropriate. 

If Bright Horizons determines that the request is lawful, it will construe the request narrowly, limiting the scope of data provided to what is strictly necessary in order to comply with the law.

For all requests from public authorities, Bright Horizons will at a minimum require the requests to:

• be in writing on official letterhead.
• identify the requesting party.
• be signed by an authorized official.
• contain the contact information of the contacting party.
• indicate the reason for, and nature of, the request.
• describe with appropriate specificity the data/information sought and its relationship to the investigation.
• be issued and served in compliance with applicable law.

Bright Horizons does not have backdoors within its systems or processes in place to enable public authorities access to its data or information systems (and Bright Horizons will not purposely build such backdoors or processes).

To date, Bright Horizons has not received any public authority access requests for the purposes of international terrorism, counterespionage, surveillance, or foreign intelligence investigation.

Please contact the Privacy Office at dataprivacy@brighthorizons.com with any questions.