Safe Harbor Privacy Policy

we self certify compliance with

       

Life Line Screening (LLS) respects individual privacy and values the confidence of its customers, business partners and others.  LLS is committed to collecting, using and disclosing personal information only in a manner consistent with the laws of the countries in which it does business.  In addition LLS will uphold the highest ethical standards in its business practices.  The Save Harbor Privacy Policy (the “Policy”) sets forth the privacy principles LLS follows with respect to transfers of personal information from the European Economic Area (EEA) to the United States.

SAFE HARBOR

The European Commission and The United States Department of Commerce have agreed on a set of data protection principles and frequently asked questions to enable U.S. companies to satisfy the requirement under the European Union law that adequate protection be given to personal information transferred from the EEA to the United States (the “US-EU Safe Harbor”).  The EEA also has recognised the U.S.-EU Safe Harbor as providing adequate data protection (OJ L 45 15.2 2001 p.47).  Consistent with its commitment to protect personal privacy, LLS adheres to the principles set forth in the U.S.-EU Safe Harbor.

SCOPE

The Safe Harbor Privacy Policy (the “Policy”) applies to all personal information received by LLS in the United States from the EEA in any format, including electronic, paper or verbal.

DEFINITIONS

For the purpose of this Policy, the following definitions shall apply:
“Agent” means any third party that collects or uses personal information under the instructions of, and solely for, LLS or to which LLS discloses personal information for use on LLS’ behalf.
“LLS” means Life Line Screening Holdings, LLC, including all of their subsidiaries.
“Personal Information” means any information or set of information that identifies or could be used by or on behalf of LLS to identify an individual.  Personal information does not include information that is encoded or anonymised or publicly available information that has not been combined with non-public personal information.
“Sensitive personal information” means personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, views or activities that concerns health or sex life, information about social security benefits or information in criminal or administrative proceedings and sanctions other than in the context of pending proceedings.  In addition, LLS will treat as sensitive information any information received from a third party where that third party treats and identifies the information as sensitive.

PRIVACY PRINCIPLES

The privacy principles in this Policy have been developed based on the Safe Harbor Principles.

NOTICE:  Where LLS collects personal information directly from individuals in the EEA, it will inform them about the purposes for which it collects and uses personal information about them, the types of non-agent third parties to which LLS discloses that information, the choices and means, if any, that LLS offers individuals for limiting the use and disclosure of personal information about them, and how to contact LLS.  Notice will be provided in clear and conspicuous language when individuals are first asked to provide personal information to LLS or as soon as practical thereafter, and in any event before LLS uses or discloses the information for a purpose other than that for which it was originally collected.

When LLS receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made be the individuals to who such personal information relates.

CHOICE:  LLS will offer individuals the opportunity to choose (opt-out) whether their personal information is (a) to be disclosed to a non-agent third party, or (b) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorised by the individual.
For sensitive personal information, LLS will give individuals the opportunity to affirmatively and explicitly (opt-in) consent to the disclosure of the information to a non-agent third party or the use of the information for a purpose other than the purpose for which it was originally collected or subsequently authorised by the individual.
LLS will provide individuals with reasonable mechanisms to exercise their choices.

DATA INTEGRITY:  LLS will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorised by the individual.  LLS will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.

TRANSFERS TO AGENTS:  LLS will obtain assurances from its agents that they will safeguard personal information consistently with this Policy.  Examples of appropriate 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, being subject to same level of protection as is required by the relevant Safe Harbor Principles, being subjected to the EU Directive 95/46/EC (the EU Data Protection Directive).  Where LLS has knowledge that an agent is using or disclosing personal information in a manner contrary to this Policy, LLS will take reasonable steps to prevent or stop the use or disclosure.

ACCESS AND CORRECTION:  Upon request, LLS will grant individuals reasonable access to personal information that it holds about them.  In addition, LLS will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete.

SECURITY:  LLS will take reasonable precautions to protect personal information its possession from loss, misuse and unauthorised access, disclosure, alteration and destruction.

ENFORCEMENT:  LLS will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy.  Any employees that LLS determines is in violation of this policy will be subject to disciplinary action up to and including termination of employment.

DISPUTE RESOLUTION:  Any questions or concerns regarding the use or disclosure of personal information should be directed to LLS’ Privacy Officer at the address given below.  LLS 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.  For complaints that cannot be resolved between LLS and the complainant, LLS has agreed to participate in the DMA Safe Harbor Program.

DMA Safe Harbor Program
1615 L St. NW, STE 1100
Washington, DC  20036-5624
safeharbor@the-dma.org
http://www.dmaresponsibility.org/safeharbor/consumers.shtml

LIMITATIONS ON APPLICATION OF PRINCIPLES

Adherence by LLS to these Safe Harbor Principles may be limited (a) to the extent required to respond to a legal or ethical obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

CONTACT INFORMATION

Questions or comments regarding this policy should be submitted to LLS as follows:

Privacy Officer
Life Line Screening
6150 Oak Tree Blvd Suite 200
P.O. Box 318049
Independence, OH  44131