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Workplace Answers Safe Harbor Information

Originally Posted: April 13, 2011 | Last Reviewed: March 07, 2012


Workplace Answers, LLC provides eLearning training and other solutions to meet your compliance and educational needs. Protecting consumer privacy is important to Workplace Answers. Workplace Answers and its affiliated United States subsidiaries (hereinafter collectively referred to as the "Workplace Answers," "we," "us" or "our") adhere to the Safe Harbor Agreement concerning the transfer of personal data from the European Union ("EU") to the United States of America. Accordingly, we follow the Safe Harbor Principles published by the U.S. Department of Commerce (the "Principles") with respect to all such data. If there is any conflict between our privacy policy and the Principles, the Principles shall govern.

 

This Safe Harbor Information page sets forth the privacy principles that Workplace Answers follows with respect to transfers of personal information, whether it is in electronic, paper or verbal format, between the United States and member states of the European Union, Switzerland, Iceland, Liechtenstein and Norway (the European Economic Area, herein referred to as "EEA").

 

Safe Harbor

The United States Department of Commerce and the European Commission have agreed on a set of data protection principles and frequently asked questions (the "Safe Harbor Principles") to enable U.S. companies to satisfy European Union law requirements for adequate protection of personal information transferred from the EU to the United States. The EEA also has recognized the U.S. Safe Harbor as providing adequate data protection. Consistent with its commitment to protect personal privacy, Workplace Answers adheres to the Safe Harbor Principles.

 

Definitions:

"Personal Information" or "Information" in this context means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

"Sensitive Personal Information" in this context means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual's health.

 

Privacy Principles
The following privacy principles are based on the Safe Harbor Principles.


1. NOTICE: Workplace Answers collects customer information when it is provided to Workplace Answers by the training administrator (typically by registering an employee for training using the Learning Management System (LMS) interface). Information collected may include, but is not limited to, personal information about an individual such as name, email address, company name, company address and company phone number. This information is used to track completed course work and will be provided to the user's employer upon request. Workplace Answers is not responsible for how the employee's company will treat personal information provided.

 

If and when Workplace Answers collects personal information directly from individuals, it will inform them about the purposes for which it collects and uses personal information about them and the choices and means, if any, Workplace Answers offers individuals for limiting the use and disclosure of their personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to Workplace Answers, or as soon as practicable thereafter, and in any event before Workplace Answers uses the information in any way other than as described in the privacy policy and terms of service of the company.

 

2. CHOICE: Where Workplace Answers collects personal information directly from individuals in the EEA, Workplace Answers will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For sensitive personal information, Workplace Answers will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Workplace Answers will provide individuals with reasonable mechanisms to exercise their choices.

 

3. ONWARD TRANSFERS TO AGENTS: Workplace Answers will obtain assurances from its agents that they will safeguard personal information consistent with our policies. Examples of appropriate assurances that may be provided by agents include: a contract obligating the agent to provide at least the same level of protection as is required by the relevant Safe Harbor Principles, being subject to EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the agent, or being subject to another European Commission adequacy finding. Where Workplace Answers has knowledge that an agent is using or disclosing personal information in a manner contrary to our policy, Workplace Answers will take reasonable steps to prevent or stop the use or disclosure.

 

4. SECURITY: Workplace Answers will take reasonable precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

 

5. DATA INTEGRITY: Workplace Answers will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Workplace Answers will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete and current.

 

6. ACCESS: Upon request, Workplace Answers will grant individuals reasonable access to personal information that it holds about them. In addition, Workplace Answers will take reasonable steps to permit individuals to correct, amend or delete information that is demonstrated to be inaccurate or incomplete.

 

7. ENFORCEMENT: Workplace Answers will conduct compliance audits of its relevant privacy practices to verify adherence to the policies. Any employee that Workplace Answers determines is in violation of its policies will be subject to disciplinary action up to and including termination of employment.

 

Contact Information:
Questions or comments regarding this policy should be submitted to Workplace Answers, LLC:

 

Workplace Answers, LLC
Karunakar Pulsani, Compliance Officer
3701 Executive Center Drive, Suite 201
Austin, TX 78731-1624
pulsani@workplaceanswers.com

 

 

Privacy Complaints by European Union Citizens:

In compliance with the Safe Harbor Principles, Workplace Answers commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union citizens with inquiries or complaints regarding this privacy policy should first contact Workplace Answers at:

Workplace Answers, LLC
Karunakar Pulsani, Compliance Officer
3701 Executive Center Drive, Suite 201
Austin, TX 78731-1624
pulsani@workplaceanswers.com

Workplace Answers has further committed to refer unresolved privacy complaints under the US-EU [and EU-Swiss] Safe Harbor Principles to an independent dispute resolution mechanism, the BBB EU SAFE HARBOR, operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed by Workplace Answers, please visit the BBB EU SAFE HARBOR web site at www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

 

 

Workplace Answers Safe Harbor Information

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