In the course of conducting business worldwide, Professional Consulting Services,
Inc. (PCS) collects and processes personally identifiable information of our clients,
shareholders, employees, suppliers, business partners, Web site visitors and other
persons (Personal Data). Maintaining the integrity and confidentiality
of Personal Data and handling it correctly is central to the way we conduct our
business activities. This policy describes how we handle Personal Data.
Personal Data is information that can be used directly or indirectly to identify
a living individual. Personal Data may include sensitive categories of information,
such as information that reveals racial or ethnic origin, political opinions, religious
beliefs, trade union membership, health, or sexual orientation (Sensitive Personal
This policy applies to PCS and its subsidiaries, and is effective as of April 1,
1990. All employees will be required to abide by this policy.
This policy is designed to protect Personal Data under applicable law as it currently
exists. However, PCS realizes that this policy cannot address every potential issue
and circumstance. Therefore, we acknowledge that this policy is subject in all respects
to applicable local legal and regulatory requirements and existing agreements and
confirm that we will comply with such requirements and existing agreements.
We will observe the privacy principles described below of Notice, Choice/Fair Processing,
Access, Security/Integrity, Onward Transfer, and Enforcement/Compliance in processing
When we collect and process Personal Data about individuals, we will make certain
information available to those individuals on a reasonable and timely basis.
This information will include what Personal Data is being collected, who is collecting
it, how and for what purposes it is being collected, how it is being used and to
whom it will be disclosed.
We will process Personal Data only with consent or when such processing is permitted
by applicable law. If we need to process Sensitive
Personal Data, we will obtain explicit consent for such processing, unless
such processing is permitted by applicable law.
We will not process Personal Data in a manner incompatible with the purposes for
which it was originally collected unless later authorized by the affected individuals
or allowed by law; we will take reasonable steps to ensure that such data is accurate,
adequate, relevant and not excessive in relation to such purposes; and we will not
keep such data longer than is necessary for such purposes.
We will enable individuals to choose whether their Personal Data can be disclosed
to a third party for direct marketing purposes.
We will allow individuals reasonable access to their Personal Data to verify, correct
or delete their data, where inaccurate. We will also provide a means for individuals
to exercise all other legal rights that they may have in relation to their Personal
Personal Data will be accessible and processed only by (i) PCS employees, suppliers,
business partners and others who require access for the performance of their obligations
to PCS; (ii) any person granted access by the individual to whom Personal Data pertains;
and (iii) those otherwise authorized by law or court order.
We will take reasonable security procedures through appropriate technical and organizational
measures to protect against unauthorized or unlawful access or processing, disclosure,
alteration, destruction or accidental loss of Personal Data.
We will utilize reasonable means to keep Personal Data accurate, complete and current
in order to protect the quality and integrity of Personal Data, however, we rely
on individuals to provide all relevant information and to advise us of any changes
to their Personal Data to ensure that it remains accurate, complete and current.
When we transfer Personal Data within PCS or to third parties (including our suppliers
and business partners), we will observe the privacy principles of Notice and Choice
(described above), and we will require all the recipients of such data to provide
at least the same level of protection for such data as specified by the standards
stated in this policy.
We will follow internal processes for handling complaints regarding our management
of Personal Data.
We will demonstrate our compliance with this policy by:
- -publishing this policy conspicuously so that it is accessible to all interested
- -appointing and maintaining a Privacy Officer with responsibility for developing
and implementing a privacy program
- -implementing procedures to execute this policy in the conduct of our business,
including training our employees in the use of such procedures and disciplining
employees for failure to comply with this policy and its procedures
- -at least annually, reviewing this policy to ensure that it continues to comply
with prevailing privacy standards, current applicable law and regulations and existing