Homeopathic Academy of Naturopathic Physicians

 

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General

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Privacy Policy


IV. PRIVACY PRINCIPLES

(1) NOTICE: Where HANP.NET collects Personal information directly from individuals, 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 HANP.NET discloses that information, and the choices and means, if any, HANP.NET offers individuals for limiting the use and disclosure of their Personal information. Notice will be provided in clear and conspicuous language when individuals are first asked to provide Personal information to HANP.NET, or as soon as practicable thereafter, and in any event before HANP.NET uses the information for a purpose other than that for which it was originally collected. HANP.NET may disclose Personal information if required to do so by law or to protect and defend the rights or property of HANP.NET.

(2) CHOICE: HANP.NET 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 authorized by the individual.

For sensitive Personal information, HANP.NET 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 authorized by the individual.

HANP.NET will provide individuals with reasonable mechanisms to exercise their choices should requisite circumstances arise.

(3) DATA INTEGRITY: HANP.NET will use Personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. HANP.NET will take reasonable steps to ensure that Personal information is relevant to its intended use, accurate, complete and current.

(4) TRANSFERS TO AGENTS: HANP.NET 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 EU Directive 95/46/EC (the EU Data Protection Directive), Safe Harbor certification by the Agent, or being subject to another European Commission adequacy finding (e.g., companies located in Switzerland). Where HANP.NET has knowledge that an Agent is using or disclosing Personal information in a manner contrary to this Policy, HANP.NET will take reasonable steps to prevent or stop the use or disclosure. HANP.NET holds it Agents accountable for maintaining the trust our employees and customers place in the company.

(5) ACCESS AND CORRECTION: Upon request, HANP.NET will grant individuals reasonable access to Personal information that it holds about them. In addition, HANP.NET will take reasonable steps to permit individuals to correct, amend or delete information that is demonstrated to be inaccurate or incomplete. Any employees that desire to review or update their Personal information can do so by contacting their local Human Resources Representative.

(6) SECURITY: HANP.NET will take reasonable precautions to protect Personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction. HANP.NET protects data in many ways. Physical security is designed to prevent unauthorized access to database equipment and hard copies of sensitive Personal information. Electronic security measures continuously monitor access to our servers and provide protection from hacking or other unauthorized access from remote locations. This protection includes the use of firewalls, restricted access and encryption technology. HANP.NET limits access to Personal information and data to those persons in HANP.NET's organization, or as agents of HANP.NET, that have a specific business purpose for maintaining and processing such Personal information and data. Individuals who have been granted access to Personal information are aware of their responsibilities to protect the security, confidentiality and integrity of that information and have been provided training and instruction on how to do so.

(7) ENFORCEMENT: HANP.NET will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that HANP.NET determines is in violation of this Policy will be subject to disciplinary action up to and including termination of employment.


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