The purpose of this policy is to describe the treatment of client information provided to or accessed by Avalution Consulting (“Avalution”) employees and/or those working on behalf of Avalution such as contractors, consultants, and vendors.
The Use of Client Information by Avalution
Avalution 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 Avalution to deliver effective, customized and valued business continuity services to clients. Avalution 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. Avalution does not disclose client information to third parties unless necessary for the delivery of business continuity services listed in the statement of work or as required by law or regulatory requirements, in which case Avalution 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 business continuity services. Any inquiries or complaints in regards to this policy should be directed to firstname.lastname@example.org.
Client Information Security and Integrity
The security, integrity and confidentiality of client information are extremely important to Avalution. Avalution has implemented technical, administrative and physical security measures that are designed to protect client information from unauthorized access, disclosure, use and modification. Access to client information is limited to those employees, contractors, consultants, and vendors that need to access the information to perform their duties for the client on behalf of Avalution. All employees are required to sign a non-disclosure agreement to work at Avalution. Consultants, contractors and vendors that perform work on behalf of Avalution are required to enter into a non-disclosure agreement and are expected to adhere to this policy and any others governing the actions of Avalution’s employees.
Avalution’s need to collect, maintain, use, or disseminate personal information about individuals is limited to use in delivering business continuity services to clients. Personal information will not be collected that is not needed for delivering business continuity services. Avalution personnel and third parties that perform work on behalf of Avalution have a responsibility to protect an individual’s privacy when collecting, maintaining, using or disseminating personal information about an individual.
Avalution's Privacy Program
Roles and Responsibilities
Program Sponsor – Provides sponsorship and oversight to the Privacy Program. The sponsor is a senior-level manager 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.
Avalution Employees – Responsible for understanding their role in the Privacy Program and familiarity with this policy and program details.
Safe Harbor Compliance (Pending)
Avalution complies with the US-EU Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Avalution has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Safe Harbor program, and to view our certification page, please visit http://www.export.gov/safeharbor/
Avalution has further committed to refer unresolved privacy complaints under the US-EU 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 Avalution, 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.
Agents of Avalution Consulting
Any party acting as an agent of Avalution Consulting will be required to adhere to the same principles and policies set forth in this document.
Privacy Program Activities
Analysis of Information Needs
Privacy Risk Identification and Assessment
Avalution will implement and maintain procedures to identify and assess risks to client information security and integrity. Avalution will identify and monitor the locations where client 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 client information. These risks may include, but are not limited to:
- Unauthorized access of personal information by individuals not approved for access
- Compromised system security
- Interception of data during transmission
- Loss of data integrity
- Physical loss of data
- Poor audit trails
- Unauthorized access of personal information by employees
- Unauthorized transfer of personal information to third parties or employees not approved for access
- Unauthorized transfer of personal information by third parties
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.
Implementation of Client Information Security and Integrity Procedures and Controls
Avalution will implement and maintain digital and physical security procedures and safeguards to restrict access to client information to only those people that need access to perform their duties. Please be aware that despite Avalution’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 Avalution Managing Consultant or Director for the project. The Avalution 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.
Review of Client Information Security and Integrity Procedures and Controls
Training and Awareness