Privacy & Safe Harbor

FORENSICS CONSULTING SOLUTIONS, LLC Safe Harbor Privacy Policy

Date: 8/24/2009 - Safe Harbor Privacy Statement

FORENSICS CONSULTING SOLUTIONS, LLC (FCS) ) participates in the Safe Harbor program and adheres to the Safe Harbor Principles developed by the U.S. Department of Commerce and the European Union. The following privacy principles apply to our collection, use, and disclosure of personal data from the European Economic Area. Notice: FCS enters into e-discovery agreements with its clients in the EU, which may include the processing of information relating to their clients' customers and employees. In these agreements, the EU client agrees and recognizes that it is the 'data controller' for the purposes of data protection legislation. This means that our clients in possession of data originating from the EU are responsible for complying with the data protection legislation in the relevant Member State national law before it sends its customer data to, or requests data collection by, FCS for processing in the United States. Data collected by FCS in any EU member state will only be transferred to the United States upon requests by the client and written consent given by the data subject. Any data processed by FCS is only disclosed to third parties, other than those referenced in the “Onward Transfer” section, at the request and direction of its European client as the data controller, or when required by law. FCS has a Compliance Manager who is responsible for the internal supervision of FCS privacy policies. FCS also has technicians to handle data security. FCS educates its employees about compliance with the Safe Harbor Principles and has self-assessment procedures in place to ensure its compliance.FCS adheres to the U.S.-EU Safe Harbor Framework as set forth by the U.S. Department of Commerce. FCS does not use customer data for any purpose incompatible with those purposes authorized in its client agreements. Sensitive information is not stored except as directed by FCS clients who own the data and does not transfer to third parties except as authorized by client. Choice: Where FCS collects personal information directly from individuals within the European Economic Area, FCS will offer the opportunity to choose (opt out) whether their personal information is:
    a) To be disclosed to a non-agent third-party or b) Can be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual or corporation. c) For sensitive personal information, FCS will give individuals the opportunity to affirmatively and explicitly (opt in) consent if the information is to be disclosed to a third party or used for a purpose other than for which it was originally collected or subsequently authorized by the individual. d) FCS will provide individuals with reasonable mechanisms to exercise their choice should circumstances arise.
Onward Transfer: FCS will obtain assurances from their agents that they will safeguard personal information consistently with this Policy. 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. Where FCS becomes aware that an agent is using or disclosing personal information in a manner contrary to this Policy, FCS will take reasonable steps to prevent or stop the use or disclosure. Security: FCS will take reasonable and responsible steps to protect the personal information in its possession from loss, misuse, unauthorized access, or disclosure. Data Integrity: FCS will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. FCS will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current. Access: upon request, FCS will grant individuals reasonable access to personal information that it holds about them. In addition, FCS will take reasonable steps to individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. Enforcement: FCS utilizes the self-assessment approach to assure its compliance with its privacy statement, and will annually self certify with the US Department of Commerce as being in full compliance. FCS will conduct compliance audits to verify adherence to this policy. Any employee that FCS determines is in violation of this policy will be subject to disciplinary action. FCS will investigate and attempt to resolve any complaints and/or disputes regarding violation of this privacy policy directly with the individual. The compliance officer is: Ray Moralez. The primary safe harbor contact is: Robin Thompson. All complaints/disputes should be addressed to: Forensics Consulting Solutions Attention: Safe Harbor Compliance 2600 N. Central, Suite 700 Phoenix, AZ 85004 or email to safeharbor@forensicsconsulting.com. For questions call 602-354-2799. If for any reason a complaint or dispute cannot be resolved through these mechanisms, a complaint can be submitted for arbitration to JAMS (http://www.jamsadr.com/).