ICCDP International Council of Certified Dementia Practitioners, LLC (“International Council of Certified Dementia Practitioners,”, the “Company” “we”, “us”, or “our”) will endeavor to protect and develop or use technology that provides a safer online experience for the customers (“you” or “your”) and has created this privacy statement (the “Privacy Policy”) to demonstrate its firm commitment to secure and trustworthy internet commerce and the individual's policy.
By using this web site and any related web pages and content therein (collectively, the “site”), you consent to the terms or International Council of Certified Dementia Practitioners, privacy policy and International Council of Certified Dementia Practitioners, processing of personal information for the purposes set forth below.
Registration
You may be required to register in order to be granted access to certain information, services and or products at this site. At the time of registration, you may be prompted by one of our online forms to provide certain personal information to us, including name, Company name and email address.
Use of Your Personal Information
The personal information that you provide to International Council of Certified Dementia Practitioners, may be stored, processed, and used by International Council of Certified Dementia Practitioners, and its affiliates for the following purposes: (a) to provide information about our Company, products and / or services, including updates, notifications, and details of any offers or promotions; (b) to assist us in improving our products, services or the content of this site; (c) to create better products; (d) for our own internal marketing and research purposes; (e) to promote user groups; (f) to make this Site or service easier to use by eliminating the need for you to repeatedly enter the same information by or by customizing this Site or service to your particular interests or preferences; (g) to analyze information for trends and statistics. We may also provide this information to an agent acting on International Council of Certified Dementia Practitioners, behalf in connection with the activities described above.
International Council of Certified Dementia Practitioners, will occasionally hire other companies, which use cookies, to provide limited service on our behalf, such as packaging, sending and delivering purchase and other mailings, answering customer questions about products or services; processing event registrations; or performing statistical analysis of our services, International Council of Certified Dementia Practitioners, will only provide those companies the personal information they need to deliver the service and any such personal information shall be subject to the third party companies' privacy policies.
You also hereby grant to International Council of Certified Dementia Practitioners, a perpetual, non - cancelable, worldwide, non exclusive right to utilize data that arises from the use of this Site or any International Council of Certified Dementia Practitioners, or its affiliate's products by you for any legitimate business purpose, including the right to sublicense such data to third parties subject to all legal restrictions regarding the use and disclosure of such information.
Except as described above, International Council of Certified Dementia Practitioners, will not sell, rent, or in any way intentionally disclose personal information that you provide to use on this Site to any third party (other than an agent acting on our behalf as described above), unless: (a) International Council of Certified Dementia Practitioners, is required to do so by law, regulation, warrant, subpoena or court order (b) International Council of Certified Dementia Practitioners, is required in urgent circumstances to protect the personal safety of International Council of Certified Dementia Practitioners, employees, users of International Council of Certified Dementia Practitioners, products or services, or members of the public, or to enforce provisions of the Terms of Use; or (c) such disclosure is part of a sale or transfer of all (or substantially all) of the assets or stock of International Council of Certified Dementia Practitioners, or one or more divisions or affiliates of International Council of Certified Dementia Practitioners.
Use of Cookies
International Council of Certified Dementia Practitioners uses cookies to help us provide better customer service, to enhance the user experience, and to deliver personalized content and advertisements. Many improvements and updates to this Site are based on the data collected through the cookies, such as total number of visitors and pages viewed. A “cookie” is a small text file stored locally in the computer used to access your account, and contains information relating to your past use of this Site. International Council of Certified Dementia Practitioners may disclose the non-personally identifiable information collected, in aggregate form only, to third parties including advertisers or potential advertisers. You have the ability to accept or decline cookies. However, if you choose to decline cookies, you may not be able to fully experience the interactive feature of this Site or services you visit.
Bulletin Boards, Chat Rooms, Testimonials and Live Chat
From time to time, portions of this Site may allow you to post information which other visitors to this site will be able to access (such as on a “bulletin board” or during interactive “chat” with other visitors.) or that you have provided permission to post your testimonial. In the event that you choose to post information in this context, it becomes generally available to the public, and we have no ability to control or limit it use by visitors to our site. By posting this information on this Site you are providing International Council of Certified Dementia Practitioners and its affiliate the right to use the information in connection with the operation of International Council of Certified Dementia Practitioners, business. Therefore, we encourage you not to post any information you consider private or sensitive on this Site. Additionally, you may participate in live chat sessions with members of our sales organization, information included in a live chat may be used to provide additional marketing communications to you, and you agree to receive those communications by participating in the live chat sessions.
Children's Privacy
International Council of Certified Dementia Practitioners, Site, software and services do not target, and are not structured to attract, children under the age of 18. International Council of Certified Dementia Practitioners does not collect any registration information from users who indicate they are under the age of 13. If the International Council of Certified Dementia Practitioners, discovers personal data from a child, International Council of Certified Dementia Practitioners, will eliminate that data.
Security of Information
To protect the privacy of personal information provided by you, International Council of Certified Dementia Practitioners employs industry standard controls including physical access controls, internet firewalls, intrusion detection and network monitoring. Additionally, only authorized administrators and staff have access to systems containing such information. We urge you to take every precaution to protect your personal data when you are on the Internet. Change your passwords often, use a combination of letters and numbers, and make sure you use a secure browser.
Revisions
International Council of Certified Dementia Practitioners, reserves the right to change this Privacy Policy at any time without notice to you, and International Council of Certified Dementia Practitioners, will post any changes to this Privacy Policy on this Site as soon as they go into effect. We encourage you to review the Privacy Policy regularly for any changes.
SAFE HARBOR PRIVACY POLICY STATEMENT
International Council of Certified Dementia Practitioners, LLC (“the Company”) is committed to preserving personal privacy. As part of that commitment, the Company adheres to the Safe Harbor Privacy Principles developed by the United States Department of Commerce in consultation with the European Commission and the Federal Data Protection and Information Commissioner of Switzerland (the “Safe Harbor program”) with respect to personal information within the scope of this statement, pursuant to the European Commission's personal data directive (the “EU Personal Data Directive” and the Swiss Federal Act on Data Protection.
The Company complies with the U.S.-EU Safe Harbor Framework and the U.S. - Swiss Safe Harbor 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. The Company has certified that it adheres to the Safe Harbor Privacy Principles of notice, choice, onward transfer, security, data integrity, access, and enforcement. To learn more about Safe Harbor program, and to view the Company's certification, please visit: https://www.export.gov/safeharbor/ (https://www.export.gov/safeharbor)
Scope
This statement applies to all personal information received by the Company (or its subsidiaries) in the United States from the European Economic Area (“EEA”) or Switzerland.
Definitions
“Agent” means any third party that processes personal information pursuant to the instructions of, and solely for the benefit of, the Company discloses personal information for processing on the Company's behalf.
“Data subject” means, as to personal information, the natural person as to which such personal information relates. Under this Statement, a data subject may be an employee of the Company or may be an employee customer or other associate of the Company's client (provided that such customer or associate is a natural person), or may be any other natural person about which personal information is received by the Company (or its subsidiaries) in the United States from the European Economic Area or Switzerland.
“Personal Information” means any information relating to an identified or identifiable natural person that is within the scope of the EU Personal Data Directive, received by the Company from the European Economic Area or Switzerland, and recorded in any form. An identifiable person is one who can be identified, directly or indirectly, in particular by reference to an identification number or to one or more factors specific to his physical, physiological, mental, economic, cultural or social identity. Personal information does not include anonymized information, aggregate information (to the extent an individual's identity cannot reasonably be derived from such information), or information as to which the data subject (who is not a Company employee) has freely given specific, informed and unambiguous consent to transfer to the United States.
“Processing” of personal information means any operation or set of operations which is performed upon personal data, whether or not by automatic means, such as collection, recording, organization, storage, adaption or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, blocking, erasure or destruction.
“Sensitive personal information” means personal information that reveals a natural person's race ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, or that concerns a natural person's sex life or health.
Safe Harbor Principles
The following principles are based on the Safe Harbor Privacy Principles. Additional Information about Safe Harbor program is available at the U.S. Department of Commerce's web site at http:www.export.gov/safeharbor/ (https://www.export.gov/safeharbor/).
Notice
Where Company collects personal information directly from individuals in the EEA, 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 Company discloses that information, the choices and means, if any, Company offers individuals for limiting the use and disclosure of personal information, and how to contact Company. Notice will be provided in clear and conspicuous language when individuals are first asked to provide information to Company, or as soon as practicable thereafter, and in any event before Company uses or discloses the information for purpose other than that for which it was originally collected.
With respect to employees of the Company, on occasion, the Company transfers employee personal data to the United States in connection with the Efficient management and operation of Company, enabling all Company personnel to communicate with one another and work together, human resources and benefits administration and safety and security processes. The Company may also transfer employee personal data to an agent of the Company in connection with the above purposes, such as a payroll provider or benefits provider. Data may also be processed and transferred to the United States in connection with collection and discovery requests in the context of litigation or government investigation, and in such context it may be made available to adverse parties in litigation or governmental entities. Except as permitted by the Safe Harbor Privacy Principles, the Company does not use sensitive employee personal information for a purpose other than that for which it was originally collected, or disclose sensitive employee personal information to a third party that is not an agent of the Company, without the employee's opt-in to such use or disclosure, respectfully.
Where Company receives personal information from its subsidiaries, affiliates or other entities in the EEA, it will use and disclose such information in accordance with the notices provided by such entities and the choices made by the individuals to whom such personal information relates.
Choice
Company 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.
Employees of the Company who reside in the EEA or Switzerland have the choice to opt-out of having their personal information disclosed to a third party that is not an agent or used for a purpose other than that for which it was originally collected as described in the “Notice” section above. Employees so desiring to opt-out should contact their Human Resources representative or alternatively may contact the Office of the General Counsel using the contact information provided at the end of this Policy. Except as permitted by the Safe Harbor Privacy Principles, the Company does not sue sensitive employee personal information for a purpose other than that for which it was originally collected, or disclose sensitive employee personal information to a third party that is not an agent of the Company, without the employees opt-in to such use or disclosure, respectively.
The provision does not apply to public record information or publicly available information except in certain situations as defined by the Safe Harbor program.
For sensitive personal information, the Company 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.
The Company will provide individuals with reasonable mechanisms to exercise choices.
Onward Transfer
The Company will obtain reasonable assurances from its agents that they will safeguard personal information collected by the Company consistently with this Statement and the Safe Harbor Privacy Principles. Example of appropriate assurances may include: a contract obliging the agent to afford a level of protection to the personal information that is at least equivalent to the Safe Harbor Privacy Principles; Safe Harbor certification by the agent; or the agent being subject to EU Directive 95/46/EC or other law providing an adequate level of privacy protection.
This provision does not apply to public record information or publicly available information except in certain situations as defined by the Safe Harbor Program.
Access
Upon an individual's request, the Company (or its client or its designees) will offer such individual reasonable access to his or her personal information and will afford such individual a reasonable opportunity to correct, amend, or delete inaccurate information. If a Company employee would like to access personal information maintained by the Company, the employee should make a written request to his or her local human resources representative. If a non-Company data subject would like to access personal information maintained by the Company, the individual should contact the Company using the contact information set forth in the “Contact information” section below. For security purposes, the individual may need to provide the Company with various pieces of personal information in process the request. The Company may limit or deny access to personal information, or charge a fee, where providing such access would be unreasonable burdensome or expensive under the circumstances or as otherwise permitted by the Safe Harbor Privacy Principles.
Security
The Company will take reasonable measures including technical, physical, and administrative measures and training to protect personal information from loss, misuse, and unauthorized disclosure, access, alteration, and destruction. The Company safeguards information according to established security standards and periodically assesses new technology for methods of protecting information. However, the Company cannot guarantee the security of personal information.
Data Integrity
The Company will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. The Company will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete, and current.
Enforcement and Dispute Resolution
The Company will conduct periodic assessments to confirm the accuracy of, and verify its adherence to, this Statement. The Company will investigate suspected infractions. Any employee that the Company determines to be in violation of this Statement will be subject to disciplinary action, which may include termination of employment.
Any questions, concerns, or complaints concerning the collection and use of personal information by the Company should be directed to the Legal Department at the address given below. The Company will conduct a reasonable investigation of and will attempt to resolve any complaints in accordance with the principles contained in this Statement. For complaints that cannot be resolved between the Company and the complainant, the Company agrees to participate in the dispute resolution procedure of the panel established by the European Union data protection authorities (DPAs) to resolve disputes pursuant to the Safe Harbor Privacy Principles, and to cooperate and comply with the Federal Data Protection and information Commissioner (FDPIC) of Switzerland. The EU DPA panel may be contacted at ec-dppanel-secr@ec.europa.eu and the EU DPAs may be contacted directly via the information provided at c. The contact information for the Swiss FDPIC can be found at: https://www.edoeb.admin.ch/kontakt/index.html?lang=en.
Dispute Resolutions has a independent third party to serve as an independent recource mechanism to deal with dispute resollutions. The web address is https://www.bbb.org/council/
We cooperate and comply with the EU Data Protection Authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) to investigate unresolved complaints - See more under our tab Privacy.
Complaints
IDDCP cooperates and complies with the EU Data Protection Authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) to investigate unresolved complaints.
The independent resource mechanism for Safe Harbor-related dispute resolution is the EU Data Protection Authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC). ICCDP agrees to cooperate and comply with the EU Data Protection Authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) to investigate unresolved complaints.
Limitations
The Company's adherence to the Safe Harbor Privacy Principles may be limited by any applicable legal, regulatory, ethical or public interest consideration, and as expressly permitted or required by any applicable law, rule, or regulation. Examples of such limitations include but are not limited to exceptions to the opt-in requirements for sensitive personal information permitted by the Commission Decision 2000/520/EC of 26 July 2000, exceptions on access as permitted by Safe Harbor Privacy Principles, or under applicable European Economic Area member state or Swiss directives. The Company also may disclose personal information reasonably related to the sale or disposition of all or part of its business.
Modification of this Safe Harbor Privacy Statement
This statement may be amended from time to time with or without notice in accordance with the Safe Harbor Privacy Principles. Any modified statement will be posted on the Company's website.
Contact Information
Questions, concerns, or complaints concerning the collection and use of personal information by the Company pursuant to this Safe Harbor Privacy Policy Statement should be directed by mail or electronic mail to the following address:
Legal Department, International Council of Certified Dementia Practitioners, LLC
One Main Street,Suite 6
Sparta, NJ 07871 USA
Telephone 1.973.729.6601
email: ICCDPOffice@iccdp.net
Customer Portal www.iccdp.net
Industries we serve: Senior Care, Health and Human Services Training, Health and Human Services Certifications, Hospice Training and Certification, First Responder Training and Certification.
Seven Safe Harbor Privacy Principles
- Notice - Companies collecting personal data must notify data subjects that they are collecting their personal data, and state the purpose for collecting such data. The company must identify to whom the data will be disclosed and provide notice about how data subjects can contact the company with complaints or questions and how disclosure of their personal information can be limited.
- Choice - The data subjects must be given a clear and conspicuous choice to opt-out of allowing their information to be disclosed to third parties or used for a purpose which is incompatible with the purpose for which it was originally collected or subsequently authorized by the individual. For sensitive information, data subjects must be given the affirmative or explicit choice whether their information is given to a third party or purpose other than its original purpose or the purpose authorized subsequently by the individual.
- Onward Transfer of Data to Third Parties - Where a company or organization wishes to transfer information to a third party, it must apply the "notice" and "choice" principles. Where a company or organization wishes to transfer to a third party acting as agent, it may do so if it first either ascertains that the third party subscribes to the Safe Harbor, is subject to the EUD or some other qualifying rule, or enters into a written agreement with the third party requiring the third party to provide at least the same level of privacy protection as is required by the Safe Harbor. If a company meets this requirement, it will not be held responsible if the third party handles data in a way contrary to any restrictions or representations, unless the company knew or should have known that the third party would process the data in such a contrary way and took no reasonable steps to prevent or stop such activity.
As an alternative, the organization can enter into a written agreement with the third party requiring that the third party provide at least the same level of privacy protection as is required by these principles.
- Access - Companies must allow data subjects to access their personal data and to correct erroneous information, unless the burden of providing access is greater than the risks associated with the erroneous information or giving access to the information would violate another person's rights. This requirement is subject to the reasonableness standard. In the event a data subject corrects their personal data, Company will ensure such changes are updated in the corresponding records storage at CSC.
- Security - Companies must take reasonable measures to protect personal information from tampering, destruction, loss, misuse, alteration, disclosure, unauthorized access, and any other potential abuses.
- Data Integrity - Companies collecting personal data must have reasonable procedures designed to keep the information reliable, accurate, complete, current, and relevant for the lawful purposes for which it was collected.
- Enforcement - Three elements are required to satisfy this principle: (a) readily affordable and independent recourse mechanisms so that each individual's complaints and disputes can be investigated and resolved and damages awarded where the applicable law or private sector initiatives so provide; (b) procedures for verifying that the commitments companies make to adhere to the safe harbor principles have been implemented; and (c) obligations to remedy problems arising out of failure to comply with the principles. Sanctions must be sufficiently rigorous to ensure compliance by the organization. CSC will cooperate and comply with the EU Data Protection Authorities (DPAs) and the Swiss Federal Data Protection and Information Commissioner (FDPIC) as the independent recourse mechanisms through which CSC will work to investigate any unresolved complaints.
Sanctioned Countries
In order to comply with legal requirements, it is ICCDP general policy that CDP certification is not provided to the following countries and regions:
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