The purpose of this policy is to describe the treatment of client or prospect information provided to or accessed by Cushnoc Resiliency Advisors’ (“Cushnoc”) employees and/or those working on behalf of Cushnoc such as contractors, consultants, and vendors.
Cushnoc is granted access to private, sensitive and/or non-public client information through the normal course of business. Access to this information is important to the ability of Cushnoc to deliver effective, customized and valued services to clients. Cushnoc will not use the information obtained or accessed through the normal course of delivering services for purposes other than those agreed to with the client in the statement of work or at the time of collection. Cushnoc does not disclose client information to third parties unless necessary for the delivery of services listed in a statement of work or contract as required by law or regulatory requirements, in which case Cushnoc would require the explicit consent of the client to do so. No client information shall be collected that is not needed for the delivery of services. Any inquiries or complaints in regards to this policy should be directed to info@Cushnoc.com.
In addition to client information collected as part of delivery of services and solutions, Cushnoc may also collect marketing data from both clients and prospects for use in delivery of sales and marketing. This information is limited to the individual’s name, title, company name, address, e-mail, and phone number. This information will be used solely for marketing purposes and will not be directly shared with third-parties. It is possible that this information may be stored in third-party systems that are used to enable marketing communications; access to this information, however, will be restricted to Cushnoc employees.
This information will be collected in accordance with local statutory regulations and will be transparent about the nature, purpose, and extent of processing operations associated with the data. Persons who voluntarily supply their contact information to Cushnoc may receive future communications. Persons who wish to amend or update their details or who do not wish to receive further correspondence may contact Cushnoc and ask that their details to be changed or to be removed.
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Cushnoc retains the information collected from clients and web site users for as long as the information is relevant to the executive of business contracts or for other business purposes, or until the user requests that we remove the data.
The security, integrity and confidentiality of non-public information are extremely important to Cushnoc. Cushnoc has implemented technical, administrative and physical security measures that are designed to protect such information from unauthorized access, disclosure, use and modification. Access to information is limited to those employees, contractors, consultants, and vendors that need to access the information to perform their duties. All employees are required to sign a non-disclosure agreement to work at Cushnoc. Consultants, contractors and vendors that perform work on behalf of Cushnoc are required to enter into a non-disclosure agreement and are expected to adhere to this policy and any others governing the actions of Cushnoc’s employees.
Cushnoc’ need to collect, maintain, use, or disseminate personal information about individuals is limited to use in delivering services to clients or marketing/sales services to prospects. Personal information will not be collected that is not needed and agreed to for these purposes. Cushnoc personnel and third parties that perform work on behalf of Cushnoc have a responsibility to protect an individual’s privacy when collecting, maintaining, using or disseminating personal information about an individual.
Program Sponsor – Provides sponsorship and oversight to the Privacy Program. The sponsor is a C-Level executive and responsible for reviewing and validating all program activities, strategy options and organizational changes that may affect the privacy program.
Program Coordinator – Provides day-to-day management for the Privacy Program. The coordinator is responsible for approving program activities and strategy options. The coordinator also requests resources to enable successful implementation and maintenance of program activities.
Cushnoc Employees – Responsible for understanding their role in the Privacy Program and familiarity with this policy and program details.
Any party acting as an agent of Cushnoc Consulting will be required to adhere to the same principles and policies set forth in this document.
Analysis of Information Needs
Privacy Risk Identification and Assessment
Cushnoc will implement and maintain procedures to identify and assess risks to information security and integrity. Cushnoc will identify and monitor the locations where sensitive information is stored. The risk identification and assessment will include the identification of sources of risk, impact of the risk and potential mitigation strategies. The risk identification and assessment will be conducted on all new projects with the potential to impact privacy risks.
There are several reasonable and foreseeable internal and external risks to the security and integrity of personal information that could result in the unauthorized disclosure, misuse, alteration, destruction, or other compromise of the security and confidentiality of personal and confidential information. These risks may include, but are not limited to:
The management and control of privacy risks shall be accomplished by 1) the development of policies, procedures, and standards which address identified privacy risks; 2) the development of training opportunities and informational materials to assist in the implementation of these policies, procedures and standards; and 3) monitoring, auditing and otherwise evaluating business areas for compliance with privacy policies, procedures, and standards.
Cushnoc implements and maintains digital and physical security procedures and safeguards to restrict access to sensitive information to only those people that need access to perform their duties. Please be aware that despite Cushnoc Resiliency Advisor’s best efforts, no security measures are perfect or impenetrable. Any employee, consultant, contractor, or vendor that becomes aware of any breach of information security and integrity will immediately notify the Cushnoc Managing Consultant or Director for the project. The Cushnoc Managing Consultant or Director will then take action to mitigate the potential for further breaches and take the necessary steps to notify the client and resolve the situation.