Our policy is designed to ensure the safety and accuracy of our clients and their customers’ personal information. Any information revealed to us will never be sold, rented, traded, or leased. CLI adheres to all HIPAA Administrative Simplification Regulations found at 45 CFR 160, 162, and 164. All CLI employees and independent contractors are required to complete the requisite training courses upon hire and annually thereafter.
CLI holds certification that it is in full compliance with the EU–U.S. Privacy Shield Framework and the Swiss–U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce, regarding the collection, use, and retention of personal information from European Union member countries and Switzerland to the United States, respectively. CLI adheres to the Privacy Shield privacy principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about the Privacy Shield program, please visit the Privacy Shield website https://www.privacyshield.gov/list), which includes the Privacy Shield privacy principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. CLI’s EU–U.S. Privacy Shield and Swiss–U.S. Privacy Shield certifications can be found here.
For complaints and disputes that cannot be resolved between CLI and the complainant, CLI has agreed to participate in the dispute resolution procedures of the panel established by the EU data protection authorities (DPAs), and the Swiss Federal Data Protection and Information (Swiss FDPIC) to resolve disputes pursuant to the Privacy Shield privacy principles. Individual DPAs may be contacted directly via the information provided on the Privacy Shield website. If your complaint is not resolved, you may have the ability to invoke binding arbitration. Please see the Privacy Shield website if you have questions on this topic.
Each and every person who works with CLI, either as a direct employee in the central offices or as a contract interpreter, receives training in the compliance with confidentiality and nondisclosure laws. This training takes place prior to the employee or contractor ever working with the customer in any form. Further, questions pertaining to their understanding of this information are incorporated into our testing program. Periodic review of this information takes place via quarterly training updates. As part of our employee initiation program, every employee is required to read, understand, and sign our proprietary employee manual, which includes all documentation that supports confidentiality, HIPAA, and Privacy Shield requirements.
CLI is constantly aware of the necessity to keep all documentation and recordings regarding our customers and their clients in strict confidentiality. We have implemented the following procedures to ensure that our practice of protecting private information is followed. These practices are consistently reviewed and updated and include:
- Strict guidelines require that Customer confidential information never leave our secure office.
- We have contacts within the Centers for Medicare and Medicaid Services (CMS) and the U.S. Office for Civil Rights (OCR), both of which specialize in HIPAA compliance. These contacts evaluate our practices and advise us, ensuring our practices are HIPAA compliant.
- No confidential information is available on the web. All data is stored securely in-house.
- Our premises are not open to the public; the doors are locked and solely accessible via regulated key cards.
- Every employee has a strict confidentiality agreement with emphasis on HIPAA and Privacy Shield compliance.
- Interpreters are bound by signed confidentiality and HIPAA compliance agreements.
In order to provide our services, we may collect the following types of information:
- Information you provide – When you sign up for services with CLI, we ask you for personal information (such as your name, email address, phone number, other account information, and an account password). For certain accounts, we accept credit card or other payment account information that we maintain in encrypted form on secure servers.
- User communications – When you send email or other communications to CLI, we may retain those communications in order to process your inquiries, respond to your requests, and improve our services.
When you sign up for our interpreter services, the only confidential information that is necessarily exchanged is the information that the interpreter is relaying between the two parties.
CLI does record some telephone interpreting calls with permission from our customers. These recordings are made strictly for internal quality assurance purposes and are securely retained for 90 days, at which point they are destroyed.
- Call recordings are encrypted with an encryption level of at least 256AES.
- Access to call recordings are limited to authorized staff.
- Recordings are kept securely on the premise only.
Upon request, CLI will provide you with information on whether we hold, or process on behalf of a third party, your personal information. To request this information, please contact us via email (email@example.com). When notified by email or mail, CLI will make reasonable effort to correct, amend, or delete such Personal Data if such data is demonstrated to be inaccurate or incomplete.
CLI only shares personal information with other companies or individuals outside of CLI in the following limited circumstances:
- We have your consent. We require opt-in consent for the sharing of any sensitive personal information.
- We have a good faith belief that access, use, preservation, or disclosure of such information is reasonably necessary to (a) satisfy any applicable law, regulation, legal process, or enforceable governmental request; (b) enforce applicable Terms of Service, including investigation of potential violations thereof; © detect, prevent, or otherwise address fraud, security, or technical issues; or (d) protect against imminent harm to the rights, property, or safety of CLI, its users, or the public as required or permitted by law.
We take appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. These include internal reviews of our data collection, storage, and processing practices and security measures, as well as physical security measures to guard against unauthorized access to systems where we store personal data.
We restrict access to personal information to CLI employees, contractors, and agents who need to know that information in order to operate, develop, or improve our services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination and criminal prosecution, if they fail to meet these obligations. Additionally, CLI maintains current certification for compliance with PCI data security standards.
CLI is responsible for the processing of personal data it receives, under the Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. CLI complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions. With respect to personal data received or transferred pursuant to the Privacy Shield Framework, CLI is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, CLI may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.
c/o Certified Languages International
4800 SW Macadam Avenue, Suite 400
Portland, OR 97239 USA
CLI PII POLICY
We are committed to protecting your personal information and rights to privacy. If you have any questions about our policy or how we handle your personal information, please contact firstname.lastname@example.org.
TABLE OF CONTENTS
INFORMATION COLLECTED THAT YOU DISCLOSE TO US
INFORMATION AUTOMATICALLY COLLECTED
HOW DO WE PROTECT YOUR INFORMATION?
DO WE SHARE YOUR INFORMATION WITH THIRD PARTIES?
WHAT ARE MY PRIVACY RIGHTS?
DO WE COLLECT INFORMATION FROM MINORS?
CALIFORNIA ONLINE PRIVACY PROTECTION ACT
DO WE MAKE UPDATES TO THIS POLICY?
1. INFORMATION COLLECTED THAT YOU DISCLOSE TO US
WHAT PERSONAL INFORMATION DO WE COLLECT FROM THE USERS THAT VISIT OUR WEBSITE?
While on our website, as appropriate, you may be asked to enter your name, email address, mailing address, phone number, or other details to help you with your experience.
WHEN DO WE COLLECT INFORMATION?
We collect information from you when you subscribe to a newsletter, fill out a contact form, or any other instance where you manually enter information on our site.
HOW DO WE USE YOUR INFORMATION?
In addition to the stated purpose of information gathering, such as newsletter email sign-up, contact request, etc, we may use the information we collect from you to:
- Personalize your experience and to allow us to deliver the type of content and product offerings in which you are most interested.
- Improve our website in order to better serve you.
- Ask for ratings and reviews of services or products.
2. INFORMATION AUTOMATICALLY COLLECTED
When you visit, use, or navigate through our website, we automatically collect information such as:
- IP Addresses
- Browser and device characteristics
- Operating systems
- Language preferences
- Referring URLs
- Device names
- Location information
- How and when you use our site
- Other technical information
This information is generally used to maintain and operate the security of the website, and for our internal analytics and reporting.
DO WE USE ‘COOKIES’?
Yes. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your web browser (if you allow) that enables our website’s or service provider’s systems to recognize your browser and capture and remember certain information.
- Keep track of, show, and send targeted advertisements.
- Compile aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the future. We may also use trusted third-party services that track this information on our behalf.
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser settings. Since each browser is different, look at your browser’s Help Menu to learn the correct way to modify your cookies.
If you turn cookies off, it may affect the user experience.
3. HOW DO WE PROTECT YOUR INFORMATION?
Our website is scanned on a regular basis for security holes and known vulnerabilities in order to make your visit to our site as safe as possible.
Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential. In addition, all sensitive you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user enters and submits their information to maintain the safety of your personal information.
4. DO WE SHARE YOUR INFORMATION WITH THIRD PARTIES?
We will only share and disclose your personal information in these situations:
- Legal Compliance: Your information may be disclosed if we are legally obliged to do so to comply with applicable law, government requests, judicial proceedings, court orders, or legal process.
- Vital Interests and Legal Rights: If we believe it is necessary to investigate or take action due to a violation of our policies, suspected fraud, threats of illegal activity, or as evidence in litigation in which we are involved.
- Business Transfers: We may share or transfer information in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- With Your Consent: We may disclose your personal information for any reason with your consent.
We do not sell, trade, or otherwise transfer to outside parties your Personally Identifiable Information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential.
Occasionally, at our discretion, we may link to third-party products, services, or content on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
5. WHAT ARE MY PRIVACY RIGHTS?
You have the right to request changes, review, or terminate your data from our records at any time.
Fair Information Practices
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur: We will notify you via email within 7 business days.
We also agree to the Individual Redress Principle which requires that individuals have the right to legally pursue enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or government agencies to investigate and/or prosecute non-compliance by data processors.
6. DO WE COLLECT INFORMATION FROM MINORS?
When it comes to the collection of personal information from children under the age of 13 years old, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, United States’ consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under the age of 18 years old.
7. CALIFORNIA ONLINE PRIVACY PROTECTION ACT
See more at:
According to CalOPPA, we agree to the following:
Users can visit our site anonymously.
You can change your personal information at any time by emailing us at email@example.com.
8. CAN-SPAM ACT
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
- Send information, respond to inquiries, and/or other requests or questions.
- Send you additional information related to your product and/or service.
- Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.
To be in accordance with CAN-SPAM, we agree to the following:
- Not use false or misleading subjects or email addresses.
- Identify the message as an advertisement in some reasonable way.
- Include the physical address of our business or site headquarters.
- Monitor third-party email marketing services for compliance, if one is used.
- Honor opt-out/unsubscribe requests quickly.
- Allow users to unsubscribe by using the link at the bottom of each email.
If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email or email us at firstname.lastname@example.org and we will promptly remove you from ALL correspondence.
9. DO WE MAKE UPDATES TO THIS POLICY?
10. CONTACTING US
4800 SW Macadam Ave #400
Portland, OR 97239
Last Edited on 2/1/2019