In order to carry out compliance screening assignments, John Sterling Associates LLC receives and processes sensitive personal information such as dates of birth and some Social Security Numbers (SSN). Data may be sent us securely in one of several modalities which is determined mutually before the assignment. Our SSN requests are limited to a small number of client personnel for whom there is no other good way of resolving tentative matches to OIG exclusions. These requests are usually for less than one-half percent of all personnel screened. However, if your policy prohibits release of any SSN, we will work with you for alternative means of resolving these tentative matches. We maintain sensitive information on a perpetual basis. Data is processed on a computer system in our office protected by a hardware firewall, software firewall, anti-virus software, anti-spyware software and other technical means from outside intrusion. Access to this data is limited to our personnel only, and then only when they have been authorized by management to work on the data. This authorization is given on a strict "need to know" basis only. All data is stored and processed in a building we own. We are the only tenant of this building and therefore ingress and egress are strictly monitored. All doors are deadbolt locked at all times, and keys are limited to authorized company personnel. Any printed material containing sensitive data is shredded before disposal. We will not allow the use of this data for any purpose other than your compliance screening assignment. We will not sell, give or divulge this data to any person or entity. You will be notified immediately of any request or demand by anyone to disclose, examine, inspect or copy any information communications or documents or any attempt to serve, or the actual service of any court order, subpoena, demand or request upon us that requires the disclosure or inspection of any information, communication or document. If any person requests or demands disclosure of any information, communication or document described above, we will advise the person or entity seeking disclosure that such materials are privileged and may not be disclosed. We will further take all steps necessary to permit the assertion of all applicable rights and privileges with respect to such information, communications or documents and will cooperate fully with your Counsel in any judicial proceeding relating to a requested disclosure of the information, communications or documents. Back
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