February 2, 2006
A. DATA PROTECTION AT Eureka Inc., dba The Relocation Center
Please note that additional information concerning the EU Safe Harbor principles may be found on the U.S. Department of Commerce’s website at: www.export.gov/safeharbor
B. SCOPE OF POLICY
This Policy applies to all personal information received by The Relocation Center in the U.S. and to and from a member state of the EU in any format including but not limited to, electronic, written or verbal communications. This policy sets certain minimum standards within The Relocation Center which may be subjected to more stringent privacy safeguards as a result of the requirements of other national or international regulatory agencies.
For purposes of this Policy, the following definitions shall apply
1. “Agent” means any third party that uses personal information provided by The Relocation Center to perform tasks on behalf of and at the direction of The Relocation Center.
2. “The Relocation Center” means Eureka, Inc., dba The Relocation Center, its subsidiaries, affiliates and offices within the United States.
3. “Personal information” means any information or set of information that identifies or could be used by or on behalf of The Relocation Center to identify an individual. Personal information does not include information that is encoded or stripped of all personal identifiable information, or which is publicly available.
4. “Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, or that concerns the health of an individual. In addition, The Relocation Center will treat as sensitive personal information any information received from a third party where that third party treats and identifies the information as sensitive.
D. PRIVACY PRINCIPLES
The privacy principles in this Policy are based on the Safe Harbor Privacy Principles.
1. NOTICE: Where The Relocation Center collects personal information directly from individuals in the U.S. and the EU, it will inform them about the purposes for which it collects and uses the information, the types of third parties to which The Relocation Center discloses that information, and the choices and means, if any, The Relocation Center 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 The Relocation Center, or as soon as practicable thereafter, and in any event before The Relocation Center uses the information for a purpose other than that for which it was originally collected.
Where The Relocation Center receives personal information from its subsidiaries, affiliates or other entities in the U.S. and the EU, it will use such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
2. CHOICE: The Relocation Center will offer individuals the opportunity to choose whether their personal information is (a) to be disclosed to a third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized to be used by the individual (“opt-out”).
With regards to sensitive personal information, The Relocation Center will give individuals the opportunity to affirmatively and explicitly consent to the disclosure of the information to a third party or to the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual (“opt-in”).
The Relocation Center will provide individuals with reasonable processes to exercise their choices.
3. DATA INTEGRITY: The Relocation Center will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. The Relocation Center will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete and up-to-date.
4. TRANSFERS TO AGENTS: The Relocation Center may share an individual's information with consultants, independent contractors and/or partners of The Relocation Center in connection with services that these individuals or entities perform for, or with, The Relocation Center. For example, The Relocation Center may provide an individual's personal information to service providers for real estate, mortgage and other relocation related services.
1. The Relocation Center will obtain assurances from its consultants and independent contractors that they will safeguard personal information received from us in a manner consistent with this Policy. Appropriate assurance of compliance may be provided through a contract between The Relocation Center and the third party which includes provisions obligating the third party to provide at least the same level of protection to sensitive personal information as is required by the relevant Safe Harbor Principles.
2. The third party may be subject to the U.S. Information Privacy and Data Protection Laws and EU Data Protection Directive itself, and if so, may provide The Relocation Center a copy of its policy and self-certification.
3. The third party may have Binding Corporate Rules approved by the European Commission, or may be subject to another European Commission adequacy finding.
Where The Relocation Center has knowledge that a consultant, independent contractor or partner is using or disclosing personal information in a manner inconsistent with this Policy, The Relocation Center will take reasonable steps to prevent or stop such improper use and/or disclosure.
5. ACCESS AND CORRECTION: Upon request, individuals will be granted reasonable access to personal information that The Relocation Center maintains about them. In addition, upon request, The Relocation Center will take reasonable steps to permit individuals to correct, amend or delete information that is found to be inaccurate, incomplete or out-of-date.
6. SECURITY: The Relocation Center will employ reasonable safeguards to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration or destruction. For personal information subject to electronic storage or transmission, The Relocation Center maintains an internal private, secure network that is protected from computer virus infection and monitored for unauthorized access. Both electronic and paper based records holding personal information are maintained in access controlled facilities for which business continuity plans are required.
7. ENFORCEMENT: The Relocation Center will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy.
All reported breaches or potential breaches will be investigated by the Ethics and Compliance Committee and any internal auditors assigned by such committee, who will take such actions as they deem appropriate in the investigation and if necessary, correction of the situation. Any employee that The Relocation Center determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment. In the event of criminal or other serious violations of the law, these actions could also be subject to notification of the appropriate legal body.
8. DISPUTE RESOLUTION: Any questions or concerns regarding the use or disclosure of personal information should be directed to the Ethics and Compliance Committee at the address given below. The Relocation Center will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information in accordance with the principles contained in this Policy.
9. CONTACT INFORMATION: Questions or comments regarding this Policy should be submitted to The Relocation Center Ethics and Compliance Committee at the following address:
The Relocation Center
C/o Ethics and Compliance Committee
631 Main Street
Baton Rouge, LA 70801
If you feel that The Relocation Center may not have abided by its policy as described herein, or the U.S. – EU Safe Harbor privacy principles, you may contact The Relocation Center at the address above, or the U.S. Federal Trade Commission.
10. RESERVATION OF RIGHTS: The Relocation Center reserves the right to share an individual's information if required to so by a court of law or in order to respond to duly authorized information requests made by government authorities or agencies.
Our business model is tailored to fit everyone from the individual to employer relocations for workers and their families. We also specialize in clergy relocation services, catering to the needs of ministers, clergy and church lay professionals.