JRock Consulting Privacy Policy

JRock Consulting specializes in building organizational capacity through talent management, assessment, applied research and sustainable change initiatives.  JRock Consulting values the privacy of our clients and online users. JRock Consulting has an affirmative commitment to adhere the following:

“EU- U.S. Privacy Shield”

JRock Consulting complies with the EU-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.  JRock Consulting has certified that it adheres to the Privacy Shield Principles of Notice; Choice; Accountability for Onward Transfer; Security; Data Integrity and Purpose Limitation; Access; and Recourse, Enforcement and Liability.  If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/.

What follows is JRock Consulting’s privacy statement addressing each principle as it relates to your rights and our industry specific data and personal information privacy concerns.

NOTICE: Personal and identifying information collected by JRock Consulting is done so with the expressed permission of our clients in order to meet their organizational needs. JRock Consulting informs individuals as to why personal information is being collected and the way in which it will be used.  We collect name and responses to assessment tools such as personality assessments and 360 surveys for assessment purposes.  The purpose of data collection is always clearly stated.

CHOICE: In the case that personal information may be transferred to a third party not affiliated with JRock Consulting for purposes other than which the data were initially intended, individuals have the choice to opt out of their information being disclosed to a third party, and to opt out of the information being used either by JRock Consulting or a third party for purposes incompatible with its originally intended use. This commitment includes but is not limited to the use and disclosure of sensitive demographic data. We promise to offer the choice to opt out in a clearly presented, efficient and easy to use Opt Out form that can be accessed by request, completed and returned via email to Shannon@jrockconsult.com.  Third parties who have data are vendors who provide test platforms.  Data collection often occurs on their platforms to which we have access.

ACCOUNTABILITY FOR ONWARD TRANSFER:  JRock Consulting is not required to give notice or provide choice when personal information is transferred to third party that is affiliated with, contracted by, or acting as an agent on our behalf. However, we do have potential liability and take reasonable measures to ensure your privacy through one or more of the following ways. JRock Consulting contracts with the third party that they provide adequate procedures for collecting, using, and maintaining private information. JRock Consulting requires the agent to notify the organization if it can no longer meet its obligation to provide the protection as is required by the Principles; JRock Consulting will take appropriate actions to stop and remediate unauthorized processing; and if asked will provide a copy of the relevant privacy provisions with that agent.  In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, JRock Consulting is potentially liable.

JRock Consulting may also be required to disclose personal information in response to a lawful request by public authorities, including meeting national security or law enforcement requirement.

SECURITY:  JRock Consulting takes reasonable precautions to protect personal information it collects and uses from loss, misuse, unauthorized access, disclosure, alteration and destruction.

DATA INTEGRITY AND PURPOSE LIMITATION:  Data that is accurate, complete, and current is essential to our work. Therefore, we take adequate measure to ensure the reliability of all data. In addition, any data we collect is relevant to the stated and explicit purpose. Personal information will not be processed for reasons other than its intended use without applying the Privacy Shield principles of notice and choice.

ACCESS:  JRock Consulting acknowledges that EU individuals have the right to access the personal information that we maintain about them.  An individual who seeks access, or who seeks to correct, amend, or delete inaccurate data, should direct his query to Shannon@jrockconsult.com.  If requested to remove data, we will respond within a reasonable timeframe. In some cases, the cost or burden of providing access to an individual is greater than the risk to that individual’s privacy; or, making the information accessible violates a third party’s privacy. In these cases, access is not guaranteed.

RECOURSE, ENFORCEMENT AND LIABILITY: As a EU-U.S. Privacy Shield self-certifying organization, we will regularly verify our compliance with these privacy principles by prominently displaying our published statement and ensuring its accuracy, comprehensiveness, and full implementation.  JRock Consulting has procedures in place for educating its employees on the correct handling of personal information. Should you have any questions, concerns, and/or complaints regarding JRock Consulting’s use of personal information, we encourage you to contact us and we will work with you to resolve any disputes as best we can in accordance with the EU- U.S. Privacy Shield principles.  The enforcement authority that has jurisdiction over JRock Consulting compliance with the Privacy Shield is the Federal Trade Commission.

In compliance with the EU-U.S. Privacy Shield Principles, JRock Consulting commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union individuals with inquiries or complaints regarding this privacy policy should first contact JRock Consulting at:
JRock Consulting

Attn: Shannon Doughney

Chrysler Building

405 Lexington Avenue

New York, NY 10174

Shannon@jrockconsult.com

646-783-2627

 

JRock Consulting has further committed to refer unresolved privacy complaints, free of charge to the individual, under the EU-U.S. Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.  There is a possibility, under certain limited conditions, as set forth in terms of Annex I, for individuals to invoke “last resort” binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.