六合彩
Upcoming SlideShare
Loading in...5
×
 

六合彩

on

  • 1,318 views

平静!你换好衣服再下来,可以吗?最后三个字是从牙缝里挤出来的。 ...

平静!你换好衣服再下来,可以吗?最后三个字是从牙缝里挤出来的。

我不觉得这样有什么不好,火曦抬起袖子看看自己,那动作又让香港六合彩的大腿多暴露一寸,急得度一舟想伸出手帮香港六合彩拉下摆,却又害怕碰到香港六合彩粉嫩的大腿——天要亡香港六合彩!香港六合彩还一副无辜的表情,而且我没带换洗衣服来,原来的衣服被你弄得脏脏的,我不想穿了。

香港六合彩什么时候弄脏了香港六合彩的衣服?对了,想起来了,香港六合彩昨天要用香港六合彩的浴室,香港六合彩坚持要香港六合彩回家沐浴,两人僵持不下,结果花洒喷了香港六合彩一身的水——这也叫香港六合彩弄脏的吗?

想到旁边还坐着公主,度一舟连忙解释起来:我跟火曦小姐之间没……没什么的。

公主看看度医生,再瞧瞧火曦小姐,香港六合彩的脑海中很难不想到有色彩的镜头。

不能让学生误会,这有损教师形象。虽然度一舟不是教师,但香港六合彩的脸皮绝对比身为老师的火曦要薄。拉住公主的手,香港六合彩试图解释清楚:不是你想象的那样,实际上我……

谁在窃笑?香港六合彩听到有人在窃笑,笑什么笑?谁允许你笑了?度一舟一双横眉冷对火曦,还真有点儿犀利。

将心一横,既然人家小姐都无所谓了,香港六合彩一个大老爷们还计较什么。扶了扶眼镜,香港六合彩正经八百地坐在公主面前,满脸坦然。我看你还是多做些运动吧!人疲劳后比较容易睡着,将自己累到什么也想不起来,自然也就睡着了。

听起来似乎很简单,实效性不知道如何。公主瞅着火曦个姐暴露在外的大腿,不好再逗留下去,向度医生道了谢,香港六合彩这就要离开。

公主……

叫住香港六合彩,度一舟一时间也不知道说些什么才好。

如果,只是说如果,如果有一天度天涯不再是全能的王储殿下,香港六合彩之间还有这么多矛盾吗?

您……什么意思?公主不懂,度天涯是王储

Statistics

Views

Total Views
1,318
Views on SlideShare
1,318
Embed Views
0

Actions

Likes
0
Downloads
0
Comments
0

0 Embeds 0

No embeds

Accessibility

Categories

Upload Details

Uploaded via as Microsoft PowerPoint

Usage Rights

© All Rights Reserved

Report content

Flagged as inappropriate Flag as inappropriate
Flag as inappropriate

Select your reason for flagging this presentation as inappropriate.

Cancel
  • Full Name Full Name Comment goes here.
    Are you sure you want to
    Your message goes here
    Processing…
Post Comment
Edit your comment

六合彩 六合彩 Presentation Transcript

  • THE U.S.-EU SAFE HARBOR: Requirements and Self Certification Procedures Lauren Saadat U.S. Department of Commerce International Trade Administration Office of Technology & E-Commerce
  • Implications of the different approaches to data flows and trade
    • European Data Protection Authorities have broad legal authority to stop data flows.
    • Implications of EU Directive:
      • According to the U.S. Census Bureau, Foreign Trade Division, in 2004, the U.S. and its top six European trade partners shared approximately $355 billion in trade.
      • Most of this trade could be dependent on the exchange of personally identifiable information.
  • Finding a Solution
    • U.S. and EU expressed commitment to bridge their different approaches to privacy while maintaining data flows and high level of privacy protection
    • FTC Act permitted each side to maintain their position
      • U.S. companies made voluntary commitments
      • EU satisfied because FTC Act made those commitments legally binding
  • Finding a Solution
    • Safe Harbor registration is a voluntary “representation” to European business partners and European citizens that U.S. companies will comply with the framework.
    • Failure to comply with Safe Harbor could constitute an unfair or deceptive trade practice under FTC Act
      • Could result in injunctions and redress
  • Finding a Solution
    • July 2000: U.S. Receives “adequacy” determination from European Commission for the Safe Harbor framework
    • However, U.S. companies only eligible if their regulator (i.e., FTC or DoT) agrees to enforce their commitments
  • The Safe Harbor Framework
    • November 1, 2000:
      • Safe Harbor becomes effective
      • DoC launches Safe Harbor website at http://export.gov/safeharbor
  • What Is the Safe Harbor Framework?
    • Safe Harbor framework includes:
      • 7 privacy principles
      • 15 FAQ’s
      • EU’s “adequacy” determination
      • Letters between DoC and European Commission (EC); the Federal Trade Commission and the Department of Transportation and the EC; etc.
  • Where Can We Find Information About It?
    • Safe Harbor website includes:
      • Safe Harbor List (currently more than 820 organizations, including multinationals and SMEs)
      • Safe Harbor Workbook
      • Compliance Checklist/Helpful Hints
      • Safe Harbor Documents (including principles, FAQ’s, correspondence, etc.)
      • Historical documents (including public comments)
  • Helpful Hints
    • Confirm the jurisdiction of FTC or DOT
    • Establish independent recourse mechanism
    • Ensure verification mechanism
    • Designate contact point
    • Develop Compliant Privacy Statement
      • Conforms to principles
      • Makes specific reference to SH adherence
      • Provide accurate privacy policy statement location, available to the public
  • Benefits of the Safe Harbor
    • Benefits of Implementing the Safe Harbor Framework:
      • Predictability and Continuity (all 25 Member States, plus EEA countries, bound by “adequacy” determination)
      • Eliminates need for prior approval to begin data transfers
      • Flexible privacy regime congenial to U.S. approach
      • Simpler/more efficient means of compliance
  • Who may join the Safe Harbor?
    • What organizations may join Safe Harbor?:
      • U.S. Organizations subject to jurisdiction of the Federal Trade Commission with respect to unfair or deceptive acts or practices under Section 5 of the Federal Trade Commission Act or the U.S. Department of Transportation
      • Companies that are uncertain as to whether they fall under the jurisdiction of these agencies can seek clarification from the agencies.
  • Who should join the Safe Harbor?
    • What organizations should join Safe Harbor?:
      • Organizations that receive personally identifiable information from EU member states must demonstrate “adequate” privacy protections
      • Organizations that have not identified another basis for demonstrating “adequacy” should consider joining Safe Harbor
  • Compliance & Enforcement
    • How and where will Safe Harbor be enforced?:
      • In general, enforcement will take place in the U.S ., in accordance with U.S. law , and will rely, to a great extent, on private sector enforcement .
      • Private sector enforcement has three components: verification, dispute resolution, and remedies.
  • Compliance & Enforcement
    • Failure to comply with Safe Harbor requirements:
      • If an organization persistently fails to comply with Safe Harbor requirements, it is no longer entitled to Safe Harbor benefits.
      • Independent recourse mechanisms are required to notify DoC of such facts. Safe Harbor list will indicate failure to comply.
      • Failure to comply may also result in an enforcement action by the FTC or DoT.
  • The Safe Harbor Principles
    • An organization entering the Safe Harbor must adhere to seven privacy principles:
    • Notice
    • Choice
    • Onward Transfer
    • Security
    • Data integrity
    • Access
    • Enforcement
  • The Safe Harbor Principles
    • (7) Enforcement : Organizations must have the following enforcement mechanisms in place:
      • follow-up procedures for verifying that safe harbor policies and mechanisms have been implemented
      • readily available and affordable independent recourse mechanisms to investigate and resolve complaints brought by individuals
      • obligations to remedy problems arising out of a failure by the organization to comply with the principles
  • The Safe Harbor Principles
    • Verification :
      • An organization may use a self-assessment (in-house) or an outside/third-party assessment program.
      • Under self-assessment, a statement verifying the assessment should be signed by a corporate officer or other authorized representative at least once a year.
      • Under outside assessment, a verification statement should be signed either by the reviewer or by the corporate officer/authorized representative at least once a year.
  • The Safe Harbor Principles
    • Dispute Resolution :
      • Organizations may choose to have disputes resolved by third-party dispute resolution programs (such as TRUSTe, BBBOnLine, DMA, AICPA WebTrust, JAMS, Entertainment Software Rating Board, etc.), or they may choose to cooperate and comply with the European Data Protection Authorities (DPA’s).
      • In the case of human resources data , the organization must agree to cooperate and comply with the DPA’s (See FAQ 9).
  • The Safe Harbor Principles
    • Human Resources Data:
      • See FAQ 9
      • Organizations transferring employee data from Europe to the U.S. must:
        • Submit to the EU DPAs for purposes of dispute resolution; and
        • Comply with member state law regarding the use of information (i.e. processing requirements) as well as any restrictions under national law for transfer of such data.
      • Access : Employers in the EU must comply with member state regulations and ensure that employees have access to such information. Organizations processing such data in the U.S. must provide access either directly or through the EU employer.
  • The Safe Harbor Self-Certification Procedure
    • How do organizations join Safe Harbor?:
      • Organizations must comply with the framework’s requirements and publicly declare that they do so (see FAQ 6).
    • Organizations that decide to join the Safe Harbor may do so by:
      • Self-certifying via the Safe Harbor website at http://www.export.gov/safeharbor; or
      • Sending a letter to the Department of Commerce.
  • The Safe Harbor Self-Certification Procedure (cont.)
    • Once received, the DoC reviews the information submitted for completeness and to verify that the information submitted is consistent.
    • To be assured of Safe Harbor benefits, an organization needs to reaffirm its self-certification annually to the DoC.
    • The Safe Harbor includes a searchable list with compliance status.
  • Since Then and Moving Forward
    • January 2002: First joint EC/DOC review of Safe Harbor completed
    • February 2002: EC submits interim report on functioning of the Safe Harbor
    • March 2002: Data Protection Authorities visit Washington
    • Late 2003: DoC and EC resume dialogue and review implementation of the Safe Harbor
    • October 2004: EC releases second report/staff working paper on Safe Harbor compliance/implementation
  • Other Options for Meeting the EU Directive’s Requirements
    • Joining Safe Harbor is not the only means of meeting the EU Directive’s requirements
    • Other alternatives include:
      • “ Unambiguous” consent
      • Necessary to perform contract
      • Codes of Conduct
      • Model Contract Clauses
      • Direct compliance/registration with EU Authorities
  • Contact Information
    • Questions? Comments?:
    • Lauren Saadat or Shannon Ballard
    • U.S. Department of Commerce
    • International Trade Administration
    • HCHB 2003
    • 14th & Constitution Avenues, NW
    • Washington, DC 20230
    • Ph: (202) 482-3709
    • E-mail: Lauren.Saadat@mail.doc.gov
    • [email_address]