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Data Policy

Data Access

 

C-Suite Coach maintains systems where PII data may reside; thus, user access to such systems is the responsibility of the department. The department has created internal controls for such systems to establish legitimate access for users of data, and access shall be limited to those approved. Any change in vendor status or the termination of an employee or independent contractor with access will immediately result in the termination of the user's access to all systems where the PII may reside.

 

Data Transmission and Transportation

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  • Company Premises Access to PII: Human Resources has defined responsibilities for on-site access of data that may include access to PII and has the operational responsibility for designating initial access and termination of access for individual users.

  • Vendors: C-Suite Coach may share data with vendors who have a business need to have PII data where such inter-Company  sharing of data is required. Approved vendor lists will be maintained, and will notify vendors of any changes to vendor status.

  • Portable Storage Devices: C-Suite Coach reserves the right to restrict PII data it maintains in the workplace. In the course of doing business, PII data may also be downloaded to laptops or other computing storage devices to facilitate Company  business. To protect such data, the Company  will also require that any such devices use encryption and security protection software while such devices are in use on or off Company premises. 

  • Off-Site Access to PII: C-Suite Coach understands that employees and independent contractors may need to access PII while off-site or on business travel, and access to such data shall not be prohibited, subject to the provision that the data to be accessed is minimized to the degree possible to meet business needs and that such data shall reside only on laptops used for business use.

 

Regulatory Requirements: It is the policy of the Company to comply with any international, federal, or state statute and reporting regulations. If any provision of this policy conflicts with a statutory requirement of international, federal, or state law governing PII, the policy provision(s) that conflict shall be superseded.

 

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