Introduction. 

Go Pony Express in its capacity as a contracted transportation service provider hereby establishes the following policies and procedures to ensure the protection of privacy and the public’s trust during operations of the Go Pony Express.  This privacy policy is intended to conform to Fair Information Practice Principles.

Requirements of the Policy

Compliance with Applicable Privacy Laws. For purposes of this Agreement, the term “Applicable Law” shall mean (i) a law, order, regulation, or rule of an administrative or legislative government body with jurisdiction over the matter in question, or (ii) a ruling, order, decision or judgment of a court with jurisdiction over the matter in question. Go Pony Express, Inc. and its team members must operate in accordance with all Applicable Law regarding the protection of an individual’s right to privacy (hereinafter referred to as “Privacy Laws”).

1. Change in Law. If an Applicable Law comes into effect that may have an impact on linehaul operations, including impacts on the privacy interests of individuals or entities affected by any operation of Go Pony Express, such Applicable Law is applicable to this privacy policy.
2. Transmission of Data to contracted entities. Go Pony Express should not provide or transmit to contracted entities any data other than the data requested by the entity.
3. Other Requirements. Go Pony Express must maintain a record of all linehaul operated and have a written plan for the operator’s use and retention of data collected by the operator and how it will comply with this privacy policy.

Go Pony Express Policy. During the planning phase for potential operations across the United States, Go Pony Express will analyze proposed operations to ensure that they meet applicable Federal and State transportation privacy regulations, statutes, and guidance. The objective is to prevent inappropriate collection of data which invades an individual’s privacy.

Policy Informed. By This policy is informed by numerous sources such as:

1. Department of Justice/National Institute for Justice research and development and policy recommendations;
2. NTIA suggested best practices for transportation over-the-road privacy.

Operations Planning. The Go Pony Express Planning Guides and additional information collected from prospective customers will help to ensure that transportation operations meet the currently established privacy laws and policies within the United States. Examples of the information that Go Pony Express will request from potential customers which will be used to evaluate privacy issues include:

1. Highway traffic requirements;
2. Operating requirements (distances, direction, profiles, data handling);
3. Data collection requirements;
4. Data retention requirements (what and for how long);

This information will be used by Go Pony Express staff to select appropriate locations for the linehaul operations to provide for the greatest privacy protection. Go Pony Express will create a detailed roadway plan with realistic limitations on roadway data during the missions.

Go Pony Express will only keep collected data for a specific period. Normal retention periods will not exceed 90 days unless specific circumstances require a longer period. Exceptions to and modifications of the GO PONY EXPRESS Privacy Policy authorized by this Section 5 for any operation will be recorded and described in the post mission report required by the post-mission procedures described in Section 7 below.

Operations Execution. Specific data collection limitations and retention agreements will be reviewed throughout the planning stages and again at the post-mission debrief. Daily operations briefings will re-emphasize these limits to ensure that the privacy policies are being adhered to during linehaul operations. The on-site operations manager will be responsible for ensuring compliance with these limitations, including designation of personnel to monitor operations and data collected.

Post-Mission Procedures. Following operations, Go Pony Express staff will provide a written report of the linehaul activities and will include a summary of operations and the collection of data, if applicable. If any privacy issues or concerns arise during an operation, they will be documented, and corrective action shall be documented by the reviewing authority with feedback to the Operations Manager.

Change in Law. Go Pony Express will review this privacy policy annually in reference to changes in both Federal and State privacy laws, as well as any newly established DOT regulation and policies. Go Pony Express