EU GDPR – Privacy Shield

Privacy Shield Certification

Future Care is listed as an Active member of the US Privacy Shield at www.privacyshield.gov/list.

Future Care’s Privacy Shield Policy

Overview

Future Care respects the confidentiality and privacy of our clients, their crewmembers, our people and others with whom we do business.

Future Care and its affiliated subsidiaries comply with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States.  Future Care has certified to the Department of Commerce that it adheres to the Privacy Shield Principles.  If there is any conflict between the terms 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, please visit https://www.privacyshield.gov/

 

This Privacy Shield Policy applies to personal information within the scope of Future Care’s Privacy Shield certification, which covers the following categories of information:

Personal information regarding current, former and prospective clients and their personnel or others for the purposes of delivering Future Care services, maintaining ongoing relationships and performing business development activities.

Personal information regarding our third parties (e.g., vendors, service providers, etc.) and their personnel for the purposes of managing and administering Future Care’s business relationships with such third parties.

Additionally, Future Care may, from time to time, collect personal information from the general public in order to answer inquiries or provide information requested.

For the purposes of this Privacy Shield Policy, “personal information” means information that is about, or pertains to a specific individual and can be linked either directly or indirectly to that individual.  In addition, certain personal information covered by Future Care’s Privacy Shield certification may be subject to more specific privacy policies of Future Care, which are also consistent with the requirements of the Principles, and in the case of any conflict between these policies and the Principles, the Principles will control.

For example:

Personal information obtained from or relating to clients or former clients is further subject to the terms of any specific privacy notice provided to the client, any contractual arrangements with the client and applicable laws and professional standards.

Individual Notice and Choice

We collect and process personal information from certain individuals and for the purposes described in this Privacy Shield Policy.  Personal information covered by this Privacy Shield Policy is collected and processed only as permitted by the Principles.

Notice to individuals regarding the personal information collected from them and how that information is used may be provided through this Privacy Shield Policy, other Future Care website notices, or other direct forms of communication with appropriate parties, such as contracts or agreements.  Where necessary and appropriate, consent for personal information to be collected, used, and/or transferred may also be obtained through these same means of communication (including opt-in consent for sensitive personal information).

Disclosures & Accountability for Onward Transfers

Consistent with the Principles, Future Care may transfer personal information to third parties, including transfers from one country to another.  We will only disclose an individual’s non-public personal information to third parties under one or more of the following conditions:

The disclosure is to a third party providing services to Future Care, or to the individual, in connection with the operation of our business, and as consistent with the purpose for which the personal information was collected. We maintain written contracts with these third parties and require that these third parties provide at least the same level of privacy protection and security as required by the Privacy Shield Principles. To the extent provided by the Principles, Future Care remains responsible and liable under the Privacy Shield Principles if a third-party that it engages to process personal information on its behalf does so in a manner inconsistent with the Privacy Shield Principles, unless Future Care proves that it is not responsible for the matter giving rise to the damage.

With the individual’s permission to make the disclosure;

Where required to the extent necessary to meet a legal obligation to which Future Care is subject, including a lawful request by public authorities and national security or law enforcement obligations and applicable law, rule, order, or regulation.

Where reasonably necessary for compliance or regulatory purposes, or for the establishment of legal claims.

Access

Individuals whose personal information is covered by this Privacy Shield Policy have the right to access the personal information that Future Care maintains about them as specified in the Principles. Individuals may contact us to correct, amend or delete such personal information if it is inaccurate or has been processed in violation of the Principles (except when the burden or expense of providing access, correction, amendment, or deletion would be disproportionate to the risks to the individual’s privacy, or where the rights of persons other than the individual would be violated).  Requests for access, correction, amendment or deletion should be sent to: privacy.office@future.careinc.com

Security

Future Care takes appropriate measures to protect personal information in its possession to ensure a level of security appropriate to the risk of loss, misuse, unauthorized access, disclosure, alteration, and destruction.  These measures take into account the nature of the personal information and the risks involved in its processing, as well as best practices in the industry for security and data protection.

Data Integrity and Purpose Limitation

Future Care collects and processes personal information only to the extent that it is compatible with the purposes for which it was collected or subsequently authorized by the data subject.  Future Care may retain personal information beyond immediate use through authorization by: consent; employer’s instruction; other authorization intended to facilitate additional services to the affected individual or Future Care’s client; legal requirements; contractual arrangement; and/or for archiving purposes in the public interest or for reasons of scientific or historical research.     Future Care takes reasonable steps to ensure that personal information is accurate, complete, current, and reliable for its intended use. Requests for access, correction, amendment or deletion should be sent to: privacy.office@futurecareinc.com.

Enforcement

Future Care is subject to the investigatory and enforcement powers of the United States Federal Trade Commission (FTC)

In compliance with the Principles, Future Care commits to resolve complaints about our collection or use of your personal information. European Union individuals with inquiries or complaints regarding our Privacy Shield Policy should first contact Future Care at: privacy.office@futurecareinc.com.

If a European Union individual decides that his or her inquiry or complaint has not been addressed satisfactorily that individual has the right to invoke binding arbitration. Future Care has further committed to refer unresolved Privacy Shield complaints to the International Centre for Dispute Resolution/American Arbitration Association (“ICDR/AAA”) an alternative dispute resolution provider located in the United States. Future Care has a policy of responding to individuals within fort y-five (45) days of an inquiry or complaint.  If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, European Union individuals should please contact or visit ICDR/AAA at https://www.icdr.org/privacyshield for more information or to file a complaint.  The services of ((“ICDR/AAA are provided at no cost to you.

Modifications

Future Care may update this Policy at any time by publishing an updated version here.  We will not update this Privacy Shield Policy in contravention to the Principles so long as we remain certified to the Privacy Shield.

Privacy policy effective: May 31, 2018