This Policy is addressed to participants in and users of the services provided by MDA Leadership Consulting. MDA Leadership Consulting (sometimes referred to as “we” or “us” in this policy) is committed to protecting your privacy. Except as explained below, any information we may gather, that is identifiable to you, is used only by us, so that we can carry on our business of leadership consulting and evaluation without unnecessary disclosure of your personal information. In implementing this Policy, MDA Leadership Consulting complies with its own standards of personal confidentiality as well as those of the applicable data security regulations of the European Union under the “Safe Harbor” privacy principles of the United States Department of Commerce. For further information on the Safe Harbor principles, see http://www.export.gov/safeharbor/sh_overview.html. The principles are listed below by numbered headings.
Preliminary Note: Personal Data. MDA Leadership Consulting collects information on individuals through the process of personal assessment for purposes of employee selection and development. Some of the information that we collect or generate in working with you is personal to you, meaning that another person looking at the information would be able to understand or find out whose it is. It would be identifiable, for example, because it includes information such as your address, telephone number, driver’s license number, or other data. This personal information is considered confidential, and we treat it accordingly. In this policy, that information is called your “Personal Data.” If it is not identifiable to you (one example being a test score without a name attached), the information is not Personal Data and is not covered by this policy.
1. Notice of Collection and Use of Your Information
At the beginning of the process of your assessment, you will be given a disclosure agreement, either in person or online. Your acceptance of that disclosure agreement and your participation in the assessment process mean that you permit MDA Leadership Consulting to provide the results of the assessments to the parties that have initiated the process (such as your employer or potential employer) and to any other parties to which you have permitted us to send the assessments. However, other than the assessments, we do not provide your Personal Data to these parties, and we do not use your Personal Data for marketing purposes or for purposes other than the assessments. Without your consent, we will not pass your Personal Data to additional parties, beyond those that we have described above.
2. Your Choice for Further Disclosure
By informing us, you have the right to opt out of whether your basic Personal Data will be disclosed to any third parties or used for a purpose other than the purposes described above or in a disclosure statement provided to you when you give us the information. Some information, however, is treated under a special rule. In the process of gathering information, we may collect or notice some particularly sensitive information, such as some health information, or some information revealing race or national origin, political opinions, religious beliefs, and the like. This type of information is called “Sensitive Information.” MDA Leadership Consulting will not pass your Sensitive Information on to other parties, or use it in any way other than its original purpose, unless you give us your specific consent.
3. Onward Transfer
It may become necessary for MDA Leadership Consulting to pass your Personal Data on to other parties, for example to permit aggregation or processing in order to carry out the assessment that you have approved, or for other uses consistent with your approval. In such circumstances, we will transfer it only to parties that have subscribed to the same Safe Harbor principles that we have subscribed to or that will agree to apply at least the same level of privacy as the principles listed here.
4. Security
By keeping your Personal Data in locked areas and on restricted-access servers, MDA Leadership Consulting will take reasonable precautions to keep it safe from loss, misuse, unauthorized disclosure, unauthorized access, alteration, and destruction.
5. Data Integrity
MDA Leadership Consulting will follow reasonable procedures and steps to see that your Personal Data is reliable for the use for which it was collected or generated, and that for those uses it is accurate, complete, and current. This does not mean that we will be constantly updating it; rather, we state that that we will take reasonable steps to see that it is current at the time it is used.
6. Access
If you have given Personal Data to MDA Leadership Consulting, you will generally have reasonable access to the information, so that you are able to correct, amend, or delete the information if it is inaccurate. However, this right of access will apply only as long as: (a) our expense or burden of providing you that access is not disproportionate to the risk to your privacy if we cannot reasonably give you access or allow the changes; and (b) giving you access does not violate the rights of others.
7. Enforcement
MDA Leadership Consulting is committed to applying this Policy and will consider and investigate any complaints and resolve any disputes concerning its application. If you have provided or will provide any personally identifiable information to MDA Leadership Consulting and have any questions about this Policy, or any concerns about how it applies to your information, please contact:
MDA Leadership Consulting
150 S. 5th Street #3300
Minneapolis MN 55402,
Attention: Paul Batz, President.
Concerning Personal Data, MDA Consulting has also subscribed to a dispute resolution system with the Better Business Bureau (BBBOnline) for disputes that cannot be resolved by investigation and discussion. Please check here for information on the dispute resolution mechanism: www.bbbonline.org
MDA Consulting has certified to the United States Department of Commerce that it has achieved compliance with the Safe Harbor principles.