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”).
- 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.
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:
- Department of Justice/National Institute for Justice research and development and policy recommendations;
- 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:
- Highway traffic requirements;
- Operating requirements (distances, direction, profiles, data handling);
- Data collection requirements;
- 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.
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.