UPDATED GDPR PRIVACY Progress Statement from The Partners
October 24, 2018
Dear AMS Clients,
For the last several months we have been working with a Privacy Consulting firm to assist us with GDPR requirements. Here is an update:
- We have completed our gap analysis and we have appointed our Chief Privacy Officer (“CPO”), Karen Moreland. We will be updating the Privacy Notice posted on our website with this and other new information by December 31, 2018.
- We are adding new procedures for GDPR data processor and data controller compliance. In most cases, AMS is the data processor of its clients’ data, and clients are data controllers under the GDPR.
- We are creating a process for implementing Privacy Impact Assessments (“PIAs”) and GDPR Data Protection Impact Assessments (“DPIAs”), as needed, on privacy impacting processes, systems and products.
- We are drafting contract addenda to address GDPR requirements between AMS and its clients.
- We have started, and will continue, to train our staff on our new privacy policies and procedures.
- We expect to have some general recommendations for our clients as well and we will share those when they become available. We expect more work to be of our compliance complete by January 31, 2019, and we will provide another update at that time.
Should you have any questions in the meantime, please contact AMS partner: Kirsten Machi at help@AMSL.com.
Kirsten, Karen and Lisa
May 01, 2018
A Message From The Partners
Dear AMS Clients,
We want to inform you that AMS has retained a firm to assist with GDPR (https://www.eugdpr.org/) requirements. We are currently conducting a gap analysis and will be actively working toward GDPR compliance. Once we are further along in this process, we will give you an update of our status.
Should you have any questions regarding this, please contact AMS partner, Kirsten Machi at help@AMSL.com.
Kirsten, Karen and Lisa,
January 22, 2016
Who We Are
What Information We Collect, How We Get It and How We Use It
Client and Member Information. Most of the Personally Identifiable Information we collect or have access to is provided to us by our clients and may include information about the respective client’s employees, contractors or members. Examples may include name, e-mail address, mailing address, phone number, organizational affiliation, employment title, authorization credentials or similar information. A client may provide this information to us directly and/or may request its members (or direct us to solicit its members) to provide us with this information such as through registration forms. We use this information to provide our requested services to the respective client and its members, to communicate with the respective client about our services or respond to such client’s inquiries or actions, to communicate with the respective client’s membership at the direction of such client, and to improve our services. All membership information is segregated and utilized only with respect to the client for whom it was provided. If an individual happens to be a member of two of our clients, such individual’s information may appear in both clients’ records as held by AMS, but will not be linked together within AMS’s records.
Website Visitors. If you visit our Sites as one of our clients, one of their members, or simply to learn more about AMS, we may log or collect some technical information such as IP addresses, browser type and page viewing history via cookies and other automated mechanisms. This information usually does not personally identify you, but it is possible that it could at some point be linked with other Personally Identifiable Information. We also collect information that you voluntarily input through our Site such as by completing a form, sending us an email or otherwise contacting us. We use this information to respond to your inquiry, provide services to our respective client with whom you are associated, or to enhance the online user experience such as efficient webpage navigation and loading.
Children’s Information. AMS’s services and Sites are a business-to-business platform and are not directed towards children under 13 years of age. If you learn that your minor child has provided us with Personally Identifiable Information, please contact us at help@AMSL.com.
Sharing Information with Others
Third-Party Collection of Personally Identifiable Information
AMS does not knowingly permit or facilitate any third-party to collect Personally Identifiable Information about your online activities over time via the Sites, except to the limited extent described in this policy such as by our vendors and clients.
How We Protect Your Personally Identifiable Information
We take reasonable steps consistent with industry practice to protect your Personally Identifiable Information from loss, misuse, unauthorized access, disclosure, alteration or destruction. No measure of security is foolproof, so please keep this in mind when deciding the information you choose to provide to us or to your members through our services or Sites.
How to Update, Correct and Manage your Personally Identifiable Information
Should you wish to update, correct or otherwise manage any Personally Identifiable Information you or the client organization with whom you are associated has provided to us, please notify us at help@AMSL.com. We reserve the right to retain information to the extent and for the duration it is reasonably necessary or helpful in making our services or Sites available to the respective client or for archival business purposes, or as we reasonably believe we are required to do by law or regulation. Our respective client may have its own data retention policy.
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Do Not Track Signals
The Sites currently do not support the ability to respond to “Do Not Track” signals or other similar mechanisms that may be emitted from a user’s device.
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