Information Privacy Policy

All individually attributable, personal information must be protected from disclosure to anyone without an authorized and immediate need-to-know and only be used for the stated purposes for which it was gathered. It must also be available for review by the individual to whom it pertains and correctable if in error. Information that is not classified or where the classification is questionable or unknown is to be considered confidential.

Kirkwood Direct systems may hold personally identifying data (i.e., any data that is unique to any individual including but not limited to financial, medical and benefits information) to carry out its mission. The protection of the privacy of personal information is of utmost importance. Active steps are taken by all associates to ensure its privacy. All information described above is confidential and Kirkwood Direct will not sell, share, rent, or provide this information to anyone for purposes other than for the purpose it was collected. All Kirkwood Direct associates with access to personal information and Kirkwood Direct associates generating applications that process personal data are required to respect the confidentiality of such information. All Kirkwood Direct business processes must comply with the Freedom of Information and Protection of Privacy Acts, relevant portions of the Gramm-Leach-Bliley Act and all relevant Kirkwood Direct Corporate Privacy Directives. Personal data, including information about organizations and business partners, collected and maintained by any Kirkwood Direct associates must:

• Be used only for the stated purpose for which it was gathered.
• Be kept for the amount of time required by law or regulations or as long as it remains relevant for its primary purpose.
• Not be disclosed without specific consent of the individual about whom the data pertains.
• Be available for review by the affected individual.
• Be corrected if errors are known to exist or if the individual identifies errors.