Protecting Organizations & Their People

Privacy Statement

The trust reflected in our client relationships means a great deal to Red Flag Reporting. As a hotline provider, we recognize that protecting your privacy is critical to our effectiveness and continued success.

Bound by standards of confidentiality that are even more stringent than the law requires, Red Flag Reporting assures you that your confidence in our professional ethics and reliance on our capabilities will always be honored.

Collecting information

As a hotline service, we collect only nonpublic personal information that is provided to us by reporters, you or obtained by us with your authorization.

Disclosing information

For current and former clients, we do not disclose any nonpublic personal information obtained in the course of our hotline services, except as required or permitted by law. Permitted disclosures include, for instance, providing information to our employees. In such situations, we stress the confidential nature of the information being shared.

Protecting your confidentiality and security

We retain records relating to the hotline services we provide so that we are better able to assist you with your professional needs and in some cases, to comply with professional guidelines. In order to guard your nonpublic personal information, as a hotline provider we maintain physical, electronic, and procedural safeguards that comply with our professional standards.

E. U. Privacy Shield Policy

The trust reflected in our client relationships means a great deal to RFR Resources, LLC (dba Red Flag Reporting and dba Culminate CMS), collectively “the Company.”  As a hotline and software as a service provider, we recognize that protecting your privacy is critical to our effectiveness and continued success.

This Privacy Shield Policy (the “Policy”) sets forth the privacy principles that the Company adheres to in regards to personal information transferred from the European Union (EU) to the United States of America.  The Company follows the Privacy Shield principles (“the Principles”) as agreed to by the European Commission and the U.S. Department of Commerce (https://www.privacyshield.gov) regarding the collection, use, and retention of personal information from European Union member countries.  We certify that we comply with the Privacy Shield Principles of notice, choice, accountability for onward transfer, security, data integrity and purpose limitation, access, and recourse, enforcement and liability.

Red Flag Reporting complies 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.  Red Flag Reporting 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 (the “Policy”) applies to all personal information received by the Company in the United States of America from the European Union, in all formats including electronic, paper or verbal.

PRIVACY PRINCIPLES

The privacy principles in this Policy are based on the Privacy Shield Framework.  The Company is committed to being subject to the principles of the Privacy Shield Framework as it relates to all personal data received from the EU in reliance on the Privacy Shield.

NOTICE:

NOTICE: The purpose of the Company is to empower people to speak-up, anonymously or not, about unethical or unsafe behavior in the workplace and to empower employers to address such concerns.   In order to reduce the risk of harm to individuals and organizations, organizations engage us for those services and make us available to their employees, customers, vendors, students and/or others.  Information provided to us may include names and locations of employment, or any other information deemed relevant by concerned reporter or member of management.  This information is collected so that our clients’ management can investigate concerns specific to their organization only.  At no point do we request individual specific government assigned identification numbers or personal bank account or credit card numbers.  As a result of the process, and while we do not process personal data, reporters may or may not disclose confidential information about themselves or other individuals.  For example, an employee reporting suspected fraudulent activity by another employee may disclose “the card holder’s name is John Doe and the credit card number is 1234 5678.” We do not disclose personal data to third parties.  Anyone identified in a report provided to us was identified by the reporter and/or management and is assumed to be innocent of any accusations unless proven otherwise.  Reports received relative to an organization engaging us are provided only to that organization, unless a) otherwise required by law, b) except where permitted, required and or directed by contract with the engaging organization, or c) required by lawful requests by public authorities, including to meet national security or law enforcement requirements, so that the engaging organization can ensure an ethical and safe work environment.  We do not disclose private information to third-parties for reasons incompatible with the above.

Inquiries or complaints may be directed to:

Privacy Officer

RFR Resources, LLC

PO Box 4230

Akron, Ohio 44321

In accordance with the Principles, we will reply to complaints within 45 days of receipt.

CHOICE: While we do not disclose personal information to third parties or for purposes incompatible with the purpose for which it was originally collected or subsequently authorized, individuals may still specifically opt-out of any such use by contacting us via any of the means noted below.  Furthermore, for sensitive information, and in accordance with the Privacy Shield Framework, individuals may give us affirmative or explicit permission to disclose such information to third parties and/or to use it for reasons other than its original purpose.  Such opting in or out may be done by contacting our customer service team at  redflag@redflagreporting.com or our Privacy Officer at the address listed above.

ACCOUNTABILITY FOR ONWARD TRANSFER: Our agents do not obtain personal data from us.  Our agents do not retain personal information but rather may enter personal information obtained from reporters into our database.  We obtain assurances from our agents that they take appropriate steps to ensure that personal information is transferred in a manner consistent with the obligations under the principles and to safeguard personal information consistently with this policy.  We do not transfer any information to third parties acting as a controller.  We will take reasonable and appropriate action to stop and remediate unauthorized processing, if any.  We are liable in cases of onward transfers to third parties.

SECURITY: We maintain physical, electronic, and procedural safeguards to protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction.

DATA INTEGRITY AND PURPOSE LIMITATION: We use personal information only when it is relevant for the purposes for which it will be used or as subsequently authorized by the individual.  For as long as we have access to such personal information, we take reasonable steps to ensure that such personal data is reliable for its intended use, accurate, complete, and current.

ACCESS: Individuals may have access to personal information we have about them and may correct, amend or delete that information where it is inaccurate, or has been processed in violation of the Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question or where the rights of other persons would be violated.

RECOURSE, ENFORCEMENT AND LIABILITY: The Company is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC).

In compliance with the Privacy Shield Principles, Red Flag Reporting commits to resolve complaints about our collection or use of your personal information.  Individuals in the European Union with inquiries or complaints regarding our Private Shield policy should first contact Red Flag Reporting at:

Privacy Officer

RFR Resources, LLC

PO Box 4230

Akron, Ohio 44321

 

P: 1-877-676-6551

F: 1-330-572-8146

redflag@redflagreporting.com

 

Red Flag Reporting has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not addressed your complaint to your satisfaction, please contact or visit https://www.jamsadr.com/file-an-eu-us-privacy-shield-or-safe-harbor-claim for more information or to file a complaint. The services of JAMS are provided at no cost to you.

As a last resort, privacy complaints that remain unresolved after pursuing these and other channels may be subject to binding arbitration before the Privacy Shield Panel to be created jointly by the US Department of Commerce and the European Commission.

The Company provides its employees with education on the Privacy Shield Principles and has self-assessment procedures in place to ensure its compliance.  The Company uses a self-assessment approach to ensure compliance with this Privacy Policy and periodically verifies that the Privacy Policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible and in conformity with the Privacy Shield Principles.  Any employee that the Company determined to be in violation of this policy will be subject to disciplinary action up to and including termination of employment.

CONTACT INFORMATION: Questions or comments regarding this Policy should be submitted to the following person by mail as follows:

Privacy Officer

RFR Resources, LLC

PO Box 4230

Akron, Ohio 44321

 

P: 1-877-676-6551

F: 1-330-572-8146

 

redflag@redflagreporting.com

PRIVACY SHIELD POLICY CHANGES: This Policy may be amended from time to time.  This policy was last modified July 26, 2016.   This policy is publicized at:  http://www.redflagreporting.com/sample-page/privacy-policy/ .