CS Logistics, Inc. (CSL) has created a privacy policy in order to document and communicate its commitment to doing business with the highest ethical standards using appropriate internal controls.

Company Intentions and Responsibilities

In the course of its business, it is necessary for CSL to record, store, process, transmit, and otherwise handle private information about individuals, customers, clients, employees. CSL takes these activities seriously and provides fair, secure, and fully-legal systems for the appropriate handling of this private information. All such activities at CSL are intended to be consistent with both generally accepted privacy ethics and standard business practices.

Revealing Information

As a general rule, information, policies and procedures should be revealed only to CSL employees and selected outsiders, such as auditors, who have a legitimate business need for this information. A notable exception involves the policies and information that deal with private information about individuals. All involved individuals have a right to receive an officially-approved statement of CSL policies and procedures regarding the handling of information about them. In addition, CSL will disclose the existence of systems containing private information and the ways that this information is used. With the exception of criminal and policy-violation investigations, there will be no system of personnel records within CSL whose very existence is kept secret from the people described therein.

Collect Only Necessary Information

In general, CSL may collect, process, store, transmit, and disseminate only that private information that is necessary for the proper functioning of its business. For example, CSL management will not collect information about employee’s activities during non-work hours unless these activities are highly likely to influence the involved employee’s performance, or unless they could adversely affect the reputation of CSL.

Handling Private Information Requests

All requests for private information coming from a person or organization outside CSL will be forwarded to the CSL senior management team. All requests for private information that fall outside normal business procedures and that come from a CSL insider will be forwarded to the director of the Human Resources department. These managers will decide whether the requests will be granted.

Destruction of Private Information

When private information is no longer needed, it will be destroyed by shredding, or by other destruction methods approved by the Information Security Team.

Removal of Private Information

Private/confidential information will not be removed from CSL offices. Permission to take such information offsite may be granted by the CSL President. Signed third-party non-disclosure agreements may additionally be required when private information is removed from CSL offices.

Preventing Inadvertent Disclosure of Private Information

Whenever an employee is handling private information, if a person who is not authorized to view that information enters the immediate area, steps to conceal the information will promptly be taken. If the information is in physical form, the information can be covered with other material. If the information is displayed on a computer screen, the employee can change screens, invoke a screen saver, log off, etc.

Expectation of Privacy

All messages sent over CSL internal computer and communications systems are the property of CSL. Management reserves the right to examine all information transmitted through these systems. Examination of such information may take place without prior warning to the parties sending or receiving such information. Because the CSL systems are to be used for business purposes only, employees have no expectation of privacy associated with the information they store in or send through these systems.

Handling Personnel Information

Access to Own Personnel File

  • Upon written request, every employee may be given access to his or her own personnel file.
  • Employees may be permitted to both examine and make one copy of the information appearing in their personnel file. If employees object to the accuracy, relevance, or completeness of information appearing in their personnel file, the employee may add a supplementary statement explaining their dispute, which will then be attached to the disputed information. Whenever the disputed information is revealed to a third party, the employee’s supplementary statement shall be revealed therewith.
  • The Human Resources Manager will contact the employee to schedule a mutually convenient time to review the records. The meeting will be held within seven (7) working days of the request. (Note: If the employee is in a location other than the Main Office, a copy of all of the records can be sent to the employee within seven (7) working days of the request).
  • The inspection will be scheduled such that the employee does not miss work.
  • All inspections will be conducted in the presence of the Human Resources Manager.
  • A reasonable charge, not to exceed the actual cost to CS Logistics, Inc., may be made for any copies of records made by/for the employee.
  • The employee will be required to sign the original inspection request stating they did inspect the file and the date the file was inspected. This written inspection notice will be placed in the employee’s personnel file.
  • An employee may request to inspect his/her records two times per calendar year.
  • Employees may inspect certain portions of their own personnel records and may copy, but not remove, documents in the file. Employees may be prohibited from viewing certain records. Records exempted from employee inspection include, but may not be limited to, the following:
    • Letters of reference for that employee.
    • Records relating to the investigation of possible criminal offenses committed by that employee.
    • Pre-employment/Employment test documentation (except that the employee may see the cumulative total test score for a section of or the entire test document).
    • Interview notes.
    • Strategic staffing planning documents.
    • Information of a personal nature about someone other than the employee.
    • Records relevant to any other pending claim of the employee against the employer which may be discoverable in a judicial proceeding.

Disclosure to Third Parties

Disclosure of private information about CSL employees to third parties will not take place unless required by law or permitted by explicit consent of the employee. CSL will not disclose the names, titles, phone numbers, locations, or other contact particulars of its employees unless required for business purposes. Exceptions will be made when such a disclosure is required by law or when the involved persons have previously consented to the disclosure.

Summary of Disclosures

If requested, employees will be provided with a summary of all disclosures of their private information to third parties. In addition, employees will be given sufficient information to permit them to contact such third parties to rectify errors or supply additional explanatory information.

Change of Status Information

Detailed employee change of status information is strictly confidential and will not be disclosed to anyone except those people who have a genuine need to know. Detailed change of status information includes the reasons for terminations, retirements, resignations, leaves of absence, leaves of absence pending the results of an investigation, inter-departmental transfers, relocations, and changes to consultant or contractor status.

Gathering Unnecessary Information

Private information about a prospective employee may not be gathered unless it is both necessary to make an employment decision and relevant to the job.

Credit and Background Checks

Whenever a credit report will be examined or a background check will be performed, prospective workers will sign a written release indicating their approval of the process.

Private Information About Customers

Consent for Collection Required

The collection of private information on prospects, customers, and others with whom CSL does business, is customary and expected.

Uses of Information

When you disclose personal information to us, which is where it stays. The only exception involves disclosure to the government according to normal business practice, for instance for the collection of taxes, and according to the orders of a court, for example responding to a subpoena or search warrant. We do not sell, rent, trade, lend, or otherwise transfer such personal information to affiliates, subsidiaries, sister companies, holding companies, parent companies, strategic partners, or any other organization. Before a customer discloses private information, all CSL representatives will inform the customer about the ways that this private information will be used, and the third parties, if any, to whom the information will be disclosed.

Opting Out from Unsolicited Contact

CSL customers will be given an opportunity to inform CSL that they do not wish to be contacted through unsolicited direct mail, telemarketing, and related promotions. CSL staff will faithfully observe and act on these customer requests. CSL workers will diligently observe the unconditional right of individuals to block data about them from being included in mailing lists or calling lists, block the sale of data about them to third parties, and to have data about them erased from direct marketing lists.

Sharing of Customer Information

CSL does not disclose specific information about customer accounts, transactions, or relationships to unaffiliated third parties for their independent use, except under certain circumstances. These circumstances are limited to the disclosure of information to a reputable information reporting agency such as a credit bureau, when performing its own due diligence related to a customer’s request to perform a certain action such as extend the amount of an existing line of credit, those circumstances when the customer requests the disclosure, the disclosure is required by or permitted by law, or the customer has been informed about the possibility of such a disclosure for marketing or similar purposes, and has been given an opportunity to decline.

Change of Business Structure

Should CSL go out of business, merge, be acquired, or otherwise change the legal form of its organizational structure, CSL may need to share some or all of its customer information with another entity in order to continue to provide products and services. If such a change and associated information transfer takes place, customers will be notified.

Use of Outsourcing Organizations

CSL may outsource some or all of its information handling activities, and it may be necessary to transfer prospect and customer information to third parties to perform work under an outsourcing agreement. In all such cases, the third parties involved will sign a confidentiality agreement prohibiting them from further dissemination of this information and prohibiting them from using this information for unauthorized purposes.