Effective on: September 26, 2024
Introduction and Scope
Kaiser Leadership Solutions, LLC (“KLS,”) takes the protection of personal data very seriously. This Privacy Notice (the “Notice”) is directed at data subjects whose personal data is collected or submitted on the assessment survey sites for the Leadership Versatility Index®, and Progress Report® applications and related services (collectively, the “Services”). This Notice does not apply to personal data we collect by other means, such as personal data that we receive directly through KLS’s own publicly accessible websites
EU-U.S. Data Privacy Framework and its UK Extension, and the Swiss-U.S. Data Privacy Frameworks
Kaiser Leadership Solutions, LLC complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”) and the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. Kaiser Leadership Solutions, LLC has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of personal data received from the European Union and the United Kingdom in reliance on the EU-U.S. DPF and the UK Extension to the EU-U.S. DPF respectively. Kaiser Leadership Solutions, LLC has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF. If there is any conflict between the terms in this Notice and the EU-U.S. DPF Principles and/or the Swiss-U.S. DPF Principles, the Principles shall govern.
To learn more about the Data Privacy Framework Program, and to view KLS’s certification, please visit https://www.dataprivacyframework.gov/s/ and https://www.dataprivacyframework.gov/s/participant-search, respectively.
Dispute Resolution
In compliance with the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF, KLS commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. DPF to VeraSafe, an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgement of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit www.verasafe.com/public-resources/dispute-resolution/submit-dispute/ for more information or to file a complaint. The services of VeraSafe are provided at no cost to you.
Categories of PII
KLS collects only the information necessary to perform the assessment sought by its clients, who are generally employers seeking assessments of its leadership personnel. For any of the categories of data subjects, KLS might collect, store, and process the following categories of personal data:
- name
- username
- password
- records regarding to consents and preferences (such as consent to use the platform)
- gender
- position
- leadership experience
- time of employment in current position
- identity of employer
- assessments and characterizations of self (for individuals to be rated) or of others (for raters or any other data subjects)
- reports including the previously mentioned personal data
Controllership
In the context of this Notice, KLS acts as a data processor for the PII we process.
Purpose of Processing
We use the information you provide about yourself for assessment and research purposes to provide the Services, as instructed by our clients who are generally employers seeking to perform assessments of their personnel. KLS keeps PII for as long as required to fulfill the purposes for which it was collected, or as permitted by law.
Sharing PII with Third Parties
KLS discloses PII to the following entities for the purposes noted immediately above:
- Performance Programs Inc.
- Amazon Web Services
- Box
- Qualtrics (Survey Platform)
- SendGrid
- Network Solutions
- Microsoft Corporation
- Intuit
- Salesforce
- Avankia
- Mailchimp
- Hogan
- KLS Customers
- Distributors of our services and products
Some of these third parties may be located outside of the United States. However, before transferring your personal data to these third parties, we will either ask for your explicit consent or require the third party to maintain at least the same level of privacy and security for your personal data that we do. We remain liable for the protection of your personal data that we transfer to third parties, except to the extent that we are not responsible for the event that leads to any unauthorized or improper processing.
When the purposes of processing are satisfied, we will retain such PII (which is anonymized) for ten years unless requested by the customer to be deleted sooner.
Other Disclosure of Your PII
We may disclose your PII (i) to the extent required by law or if we have a good-faith belief that such disclosure is necessary in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, or private parties, including but not limited to: in response to subpoenas, search warrants, or court orders, or (ii) if we sell or transfer all or a portion of our company’s business interests, assets, or both, or in connection with a corporate merger, consolidation, restructuring, or other company change, or (iii) to our subsidiaries or affiliates only if necessary for business and operational purposes as described in the section above.
We reserve the right to use and share aggregated, anonymous data, which does not include any PII, related to our Services and customers as a group, for any legal business purpose, such as analyzing usage trends and research
If we must disclose your PII in order to comply with official investigations or legal proceedings initiated by governmental and/or law enforcement officials, we may not be able to ensure that such recipients of your PII will maintain the privacy or security of your PII.
Information Security
We are very much aware of Internet users’ concerns about security. KLS takes technical, contractual, administrative, and physical steps to protect against unauthorized access to and disclosure of individually identifiable information. These steps can include firewalls, secure socket layers, password verification, etc. You can determine when you are in a secure environment by locating the key (Netscape browsers) or lock (Microsoft browsers) symbol at the bottom of the browser page. When the key or lock is complete, the information provided by you is encrypted, restricting access by anyone else. If your browser does not support secure transactions, there is a chance that others may view any information that you send. You can check your browser’s help button to learn more about secure transaction support.
Children’s Privacy
Our Services are not intended for persons under the age of 18; therefore, we do not knowingly collect personal information directly from such persons. We encourage parents to talk to their children about their use of the Internet and the information that they disclose.
External Links
KLS is not responsible for the privacy policies of web sites to which the KLS web site may link or for those of any downstream linkages.
Use of Cookies
Cookies are alphanumeric identifiers that we transfer to your computer’s hard drive through your Web browser to enable our systems to recognize your browser and to provide necessary assessment features such as language selection.
Data Subject Rights
Kaiser Leadership Solutions, LLC acknowledges the right of EU, UK and Swiss individuals to access their personal data pursuant to the Data Privacy Framework and will grant individuals reasonable access to personal information it received pursuant to the Data Privacy Framework Principles. In addition, KLS will take reasonable steps to permit individuals to correct, amend, or delete such information that is demonstrated to be inaccurate or processed in violation of the Principles. An individual may request to access their information, or otherwise correct, amend, or delete their information in line with the EU-U.S. (and its UK Extension) and Swiss-U.S. Data Privacy Framework Principles by calling us at +1-336-217-2740 or sending us an email at info@kaiserleadership.com.
Choice
You have the choice to opt out of having your PII shared with third parties by us, and you may revoke your consent that you have previously provided for us to share your PII with third parties, except as required by law. You may also have the right to opt out if your PII is used for any purpose that is materially different from the purpose(s) for which it was originally collected or which you originally authorized. To do this, you may send your request to us using the information in the “Contact Us” section below.
Changes to this Privacy Notice
If we make any material change to this Notice, we will post the revised Notice to this web page and update the “Effective” date above to reflect the date on which the new Notice became effective.
If a privacy complaint or dispute relating to personal data received by KLS in reliance on the Data Privacy Framework (or any of its predecessors) cannot be resolved through our internal processes, we have agreed to participate in the VeraSafe Data Privacy Framework Dispute Resolution Procedure. Subject to the terms of the VeraSafe Data Privacy Framework Dispute Resolution Procedure, VeraSafe will provide appropriate recourse free of charge to you. To file a complaint with VeraSafe and participate in the VeraSafe Data Privacy Framework Dispute Resolution Procedure, please submit the required information here: www.verasafe.com/privacy-services/dispute-resolution/submit-dispute/.
Binding Arbitration
If your dispute or complaint cannot be resolved by us, nor through the dispute resolution program established by VeraSafe, you may invoke binding arbitration pursuant to the Data Privacy Framework’s Recourse, Enforcement and Liability Principle and Annex I of the Data Privacy Framework.
Regulatory Oversight
KLS is subject to the investigatory and enforcement powers of the United States Federal Trade Commission.
Contact Us
If you have any questions about this Notice or our processing of your PII, please call us at 1-336-217-2740 or send us an email at info@kaiserleadership.com.
Please allow up to four weeks for us to reply.