SUBJECT ACCESS REQUEST POLICY
To perform its work, Vital Strategies gathers, stores and processes certain information about individuals that have relationships with the organization. Those individuals may request information about the data Vital Strategies has on them.
This Policy describes how to respond to requests for information about the data Vital Strategies holds on an individual and what rights an individual has with respect to his or her data.
Collection of Personal Information
Subject Access Request
An individual (“subject”) may request information about what data Vital Strategies holds on them, how it was acquired and for what purpose. Subjects may make request by emailing firstname.lastname@example.org or otherwise contacting Vital Strategies through any other standard communication method, such as mail. All requests must be in writing. Requests can be made through a general communication channel with Vital Strategies (such as email@example.com), but all requests must be immediately routed to the IT Department. The IT Department is responsible for responding to all requests. Vital Strategies will confirm receipt of the request within 2 business days of the request being submitted, and requests will receive a more detailed response within a timeframe that is commercially reasonable and as required by law.
Subject Access Rights
Each subject may have one or more of the following rights, as accorded in legislation relevant to the subject:
• The right to be informed
• The right to access one’s own personal data
• The right to correct inaccurate data
• The right to erasure
• The right to restrict processing
• The right to data portability
• The right to object
• The right to be informed of a data breach (see Data Breach Policy)
Vital Strategies will comply with these rights to the extent required by law. Any expansion of Subject Access Rights in favor of the subject beyond what is required by law will not constitute a waiver of Vital Strategies rights to curtail any and all rights as permitted by relevant law. Vital Strategies reserves the right to treat subjects differently based on their geographic location and the rights granted to them under relevant laws.