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Privacy Policy

Siena Consulting, LLC (Siena) respects and is committed to protecting your privacy. Siena has established safeguards to protect the privacy of personally-identifiable information that is collected on its client's behalf or received from its clients. This privacy policy applies to all personally-identifiable information that Siena processes including manually or electronically processed data in electronic, written, or verbal formats. Personally-identifiable information is any information that can be directly or indirectly linked to or used to identify a living individual including name, email, address, phone number, race, ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or other identifying characteristics. Personally-identifiable information does not include publicly available information that is not combined with non-public personal information or information which has been encoded or anonymized.

All Siena employees and contractors are required to read and comply with these policies when using personally-identifiable information.

Notice

Siena performs management and human resources consulting services for clients including employee assessments and surveys. As part of its consulting work, Siena may collect or be given access to personally-identifiable information to process, analyze, or report. Personally-identifiable data that is collected for the purpose of employee assessment will be shared with the client. Personally-identifiable data that is collected for the purpose of surveying employees on their attitudes and opinions will be kept confidential. Siena may share data collected for either purpose with third party sub-contractors or vendors working for Siena provided that they comply with Siena's privacy policy. Siena may also use data collected for either purpose as part of scientific research provided it has received permission from the client.

Choice

Siena does not disclose any personal information that it has collected for or received from a client to any other third parties except as required by law or instructed by the client. Third party sub-contractors or vendors working for Siena that have access to personal data are required to comply with Siena's privacy policy. Siena may transfer data to third parties or additional vendors when instructed to do so by the client.

Accountability for Onward Transfer

Siena will not transfer personal information to any third party except (1) as required by law, (2) in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, (3) as direct by the client, or (4) to a third party working for Siena that has agreed to comply with Siena's privacy policy. All third-party sub-contractors or vendors working for Siena are required to execute a written confidentiality and non-disclosure agreement. This agreement stipulates the confidential nature of data collected by and transferred to the third party working on Siena's behalf. It also prohibits the third party working for Siena from releasing or disclosing information or data to any other parties without Siena's express written permission

Security

Siena maintains reasonable precautions to protect personal data from loss, misuse and unauthorized disclosure, alteration or destruction. Data are stored and maintained such that access is limited only to authorized users. All authorized users are bound by Siena's confidentiality and non-disclosure agreements.

Data Integrity and Purpose Limitation

Siena is committed to only collecting data authorized by the client and analyzing any client data in a manner consistent with the purposes for which it has been collected or subsequently authorized by the individual. To the extent possible, Siena will take reasonable steps to ensure that any data it collects or analyzes are reliable for its intended use, accurate, complete, and current. However, the responsibility for ensuring the reliability of the data that are provided by the client rests with the client.

Access

If directed to do so by its client, Siena will correct, revise, or remove any inaccurate data in a manner consistent with the principles of proportionality and reasonableness. Any requests by a client's employees for corrections, revisions, or removal of any inaccurate data must be made through the client. Any requests by a client's employees to limit the use and disclosure of personal information must be made through the client.

Enforcement, Recourse, and Liability

Siena will thoroughly investigate any and all complaints, and take prompt and appropriate remedial action where necessary if violations of Siena's privacy policy and principles are found.

Contacting Siena Consulting, LLC

In order to inquire about Siena's privacy policies or anything related to the privacy of personal information handled by Siena, please contact the following:

Siena Consulting, LLC

208 Bullock Drive

Princeton, NJ 08540

http://www.sienaconsulting.com

Policy Updated on May 14, 2019

 

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