St. Louis police shot a black 18-year-old armed with a gun was shot and killed by two officers who were serving a search warrant at a home.
ST. LOUIS (AP) — St. Louis police say a black 18-year-old armed with a gun was shot and killed by two officers who were serving a search warrant at a home.
St. Louis Police Chief Sam Dotson says two suspects fled from the home around noon Wednesday on the city’s north side before the 18-year-old turned and pointed a handgun at the officers, who shot him.
Dotson says the wounded suspect died at the scene. In a statement Wednesday night, police identified him as Mansur Ball-Bey of St. Louis. Authorities are searching for the second suspect. The statement said he is believed to be in his mid- to late teens.
Both officers, who are white, were unharmed, according to a police report.
Dotson said four guns and crack cocaine were recovered at the scene.
A man and woman who were inside the home were arrested.


VIDEO LENGTH: 54 minutes
IN A CONVERSATION PRODUCED FOR THE ACADEMY OF ORGANIZATIONAL & OCCUPATIONAL PSYCHIATRY’S SEASONAL SYMPOSIUM , CHIEF COX AND DR. BROWN DISCUSS A RANGE OF SUBJECTS, INCLUDING:
- The impact of recent events on Police Organizations and Individual Officers
- Community Policing: What is it? How does it work?
- The Public’s perception of police and how such perceptions are formed
- How the police and the public can work together to promote social trust
A CONVERSATION WITH POLICE CHIEF MICHAEL COX
Recorded in November 2020


Official translations are legally valid translations, for example, of a certificate, a decree by an authority or another document to be delivered to an authority. Translations created by sworn translators are always equivalent to the original document. Official translations usually carry a stamp and they are often accompanied by a certification or a statement by a sworn translator.
Documents like these have many uses. They can be used as a proof of studies or degrees completed in another country and in another education system, as a certificate of non-impediment for marriage or when seeking a divorce in another country, for matters related to international company acquisitions or the company register, when drawing up contracts with parties who require them in another language or for criminal or civil proceedings.
As such, a translated document’s function is to prove a certain qualification, right or legality in matters involving more than one language or country.
Legally valid translations can only be provided by sworn translators, who must be familiar with the legal aspects related to certified translations. These are, for example, the translator’s responsibility on the assignment, professional secrecy and confidentiality, the status of the original document and aspects related to the layout and format of the translation.
We at Lingo ask the client for the purpose and the destination of the translation to find out whether an official translation and possibly an apostille are required.
Official translations are always completed as per the current regulations on sworn translators and official documents. Official translations must closely follow the original source document.
When the translation is finished, the sworn translator stamps the completed document and certifies the translation with a statement and signature. Stamps are not mandatory in Finland but authorities in several other countries require a stamp in order to process the translation as an official document.
A sworn translator’s translation is often accepted as is. However, the approval of translations always depends on the matter at hand and the receiving authority.
Many consulates recommend attaching an apostille to translations provided by sworn translators. Apostilles are obtained from city administrative courts, they are usually given in the particular country’s official language and they are not translated.
We always treat your materials as confidential and we request to see the original document. We also request that you provide us with the purpose and destination country of the translation.
We provide official translations usually in language combinations with Finnish as either the source or target language.
We also find sworn translators for other languages.
More information about sworn translations is available on the Finnish National Board of Education’s website.


Welcome to Reumssky.com (Reumssky Business World). Reumssky.com (hereafter referred to as Reumssky services or ‘We’) provides an online market place, that permits you to buy and sell goods and services from various locations when you visit or shop at reumssky.com. The Reumssky platform is both for business to business (B2B) and for individuals.
The conditions of use serve as a guide for the access to and use of the Reumssky website and services by buyers and sellers. To agree to these conditions, you must be of legal age (18), if not you must have obtained parental/guardian consent and your parent/guardian consents to these conditions in your behalf. Violating or not consenting to the conditions of use means your access to Reumssky’s website or services is unauthorized. Additional terms and conditions may apply to some other services offered on the Reumssky website. Such terms and conditions can be found where the relevant service is offered on the Reumssky website.
When you, by yourself or acting on behalf of others, use any of Reumssky’s services, you agree that you will not:
- violate the copyright, trademark, patent, moral, database, and other intellectual property rights that belongs to Reumssky or are connected to us.
- breach any policy that you agree to regarding your use of the Reumssky website.
- use our Services if you are under 18 years old, or if you are a person who has been prohibited by law to go into any legal or economic agreements.
- You will not use the Reumssky’s website, name, logo, or brand to send any unsolicited or unauthorized content like advertising, promotional materials, email, junk mail, spam, or other form of solicitation.
- fail to pay for items you order, unless you have a valid reason as set out in Reumssky’s Unpaid item policy.
- fail to deliver items sold by you, unless you have a valid reason as set out in Reumssky’s Unpaid Item policy;
- manipulate the price of any item or interfere with any other user’s listings.
- Tamper with the feedback or rating systems as against what is in our Feedback policies.
- Upload any content that is not in tandem with our Content Guidelines
- Through any virus or malwares; tamper with, hijack, hinder the smooth operation of any hardware or software used in connection with the Reumssky website.
- Use the Reumssky website for fraudulent or unlawful commercial purpose.
- Scheme ways to get the personal information of the users of Reumssky’s website and services.
- Hack into or deface any part of the Reumssky website or disrupt our servers, computer systems or networks.
- Restrict or inhibit any other person from using the Walmart Sites.
- Exploit any portion of (or any use of) our website except as authorized in these Conditions of Use, without our consent.
- share your log in credentials with any third parties
- Post, upload content or create listings in inappropriate categories or areas on our website.
- post content that does not belong to you
- Post misleading, abusive or defamatory content.
- Violate any law, rule, or regulation, or these Conditions of Use.
VENDORS TERM OF USAGE
- Ensure that all the information you provide during and after your registration is accurate and UpToDate.
- Ensure to update your information regularly.
- Vendors are solely responsible for maintaining the confidentiality and security of their account including username and password.
- We will not be held accountable for any losses caused by the unauthorized use of your account.
- Reumssky will not be held responsible if you lose or share access to your device.
- We may change, charge, modify, or waive any fees required to use any services, functionality or other content available through the Reumssky website or any portion of it.
COPYRIGHT AND TRADEMARK
Reumssky together with our content suppliers own and control all content, intellectual property and material on our website. Contents like, but not excluded to, our logo, audio clips, videos, digital downloads, images, data compilation, and other registered and unregistered trademarks belonging to us. The compilation of all content included in or made available through any Reumssky Service is the exclusive property of Reumssky and protected by both local and international copyright laws.
All other trademarks not owned by Reumssky that appear in any Reumssky Service are the property of their respective owners, who may or may not be affiliated with, connected to, or sponsored by Reumssky.
USERS REGISTRATION AND ACCOUNT
- Both as a vendor or as a buyer, you can register for an account with our online marketplace by completing and submitting the account registration form on Reumssky.com
- A user must be registered on the site to access or use some Services
- All information provided in the registration form must be accurate and updated.
- Keep your login details: email address/user ID and password confidential.
- Report any unauthorized use of your password or account.
- be responsible for any losses caused by your failure to keep your password confidential.
- You shall not transfer the management of your account to a third party. If you do so, Reumssky will not be responsible for any losses.
- All activities that occur under your account, such as: posting product or company information, clicking to accept any additional agreement, making payments, subscribing to services, calling our customer service, sending emails or SMS, will be seen as authorized by you.
- We may suspend or cancel your account, and/or edit your account details, at any time in our sole discretion and without notice or explanation, providing that if we cancel any products or services you have paid for but not received, and you have not breached these general terms and conditions, we will refund you in respect of the same.
- You may cancel your account by contacting us Here
Electronic communication is the transmitting of information via e-mails, text messages, and other internet enabled devices. When you use the Reumssky website, you consent to receive texts, e-mails, mobile push notices, or notices and messages on the site or through our other services. You can retain copies of these communications for your records.
You agree that all agreements, notices, disclosures, and other communications that we provide to you electronically satisfy any legal requirement that such communications be in writing.
See our Privacy Notice, to understand our practices.
Content includes all text, images, graphics, audio and video, audio-visual material, scripts, software and files submitted to us to publish, store, process, post or transmit on the Reumssky marketplace. Communication such as feedback, ideas, questions, reviews and comments can also be referred to as content.
Your content should
- Be accurate, honest, coherent and complete.
- Be in accordance with the generally acceptable standards of behavior on the internet
- Clear, detailed and genuine
Your content must not:
- Be obscene, defamatory, pornographic or illegal.
- Invade on the privacy of other users, infringe on their human and intellectual property rights.
- Be harmful to health and wellbeing of users.
- contain software viruses or any form of unsolicited commercial electronic messages.
- Be misleading, false or impersonate any person or entity.
- Promotes violence in any graphic or written description.
- Be discriminatory or portray any tribal or religious bias.
- Be inflammatory, abusive or fraudulent.
- contains advertisements, solicitations, or spam links to other web sites or individuals, without prior Reumssky’s consent.
- Infringe on patent, copyright, trademark right, moral right, trade secret, design right, or other proprietary rights.
- violate any of the policies on the Reumssky website.
- be intended to harm, damage, disrupt or interfere with the Reumssky website, services or partners.
- Be legally controversial; any material that is or has ever been the subject of any threatened or actual legal proceedings or other similar complaint.
Reumssky has the right to take down or edit any content that does any of the afore mentioned but does not regularly review posted content.
OUR RIGHTS TO USE CONTENT AND IDEAS
Reumssky users grant us an irrevocable, royalty-free, unlimited, worldwide, non-exclusive license to reproduce, use, store, work on, modify, edit, publish and distribute any content provided us.
The content or ideas may be used for any purpose, sub-license our rights as explained above, and can bring an action for infringement of any of these rights.
Reumssky is not obligated to pay any compensation for any content or idea or respond to any content or idea.
We also have the right (but not the obligation), in our sole discretion, to edit, move, delete, or refuse to make available any Content made available on and for our websites. This may be as a result of a user breaching the Terms and Conditions of Use Walmart Sites, for legal reasons or otherwise.
Nevertheless, you are responsible for any Content you make available, and you agree to indemnify us for all claims resulting from any Content you make available.
LICENSE AND ACCESS
Every user of the Reumssky website has a non-exclusive, limited and non-transferrable license to access and make non-commercial use of the website as long as the users comply with the terms and conditions of use and pay any applicable fees as demanded by Reumssky.
This license is not inclusive of:
- any collection and use of any product listings, descriptions, or prices.
- any commercial use of Reumssky website or its contents.
- any use of robots, data mining, or other data gathering and extraction tools.
- all rights not expressly granted to you in the Terms and Conditions of Use.
- framing or copying any trademark, logo, or other proprietary information such as images, text, page layout, without Reumssky’s consent.
- any misuse of Reumssky’s website and services, especially as condemned by the law.
Failure to comply with these conditions results in Reumssky terminating the users license to access and use the website. All rights not expressly granted to you in these Conditions of Use or any Service Terms are reserved by Reumssky or its licensors, publishers, suppliers, rightsholders, or other content providers.
RETURNS AND REFUNDS
An item is not considered returned until it arrives in our center (warehouse). For more information about our returns and refunds, see our Returns and Refunds Policy.
Reumssky does not guarantee that products, product descriptions or other content of the Reumssky website is complete, accurate and reliable because they are made available by third-party (vendors/sellers); although we try to cross-check products for the sake of our users. Such information (product features, specifications, and prices) and the availability of any product is subject to change at any time without notice. If a product delivered by Reumssky is not as described, you can return it in good unused condition.
Limitations to accuracy in product listing may be the inability to display the features of a product, especially the colour and mass. We cannot guarantee this because the actual colours a user sees and that will reflect in the actual product colour or finish depends on the user’s monitor. Also, certain weights, measures, and similar descriptions are approximate.
For orders where you pay online, we do not charge your credit card until after your order has entered the shipping process or until we make the digital product available to you (for digital products).
REGULATIONS AND EXPORT POLICY
All users, especially vendors must comply with all business laws according to the Nigerian constitution. They must also comply with export and re-export restrictions that may apply to goods and services.
Reumssky works with third-parties who upload products for sale on the market place (including marketplace retailers, advertisers, and brands. We also, in some cases, provide links to the sites of affiliated companies and certain other businesses. If you purchase any of the products or services offered by these businesses or individuals, you are purchasing directly from those third parties, not from Reumssky.
Reumssky does not guarantee the proposition of these businesses or individuals nor the content of their websites. We do not warrant the performance of their goods and services. Reumssky is not responsible for examining or evaluating these businesses and their content. We are not liable for such business or individual’s product, actions, and content.
Users should carefully review their privacy statement and conditions of use before transacting with them. They should always read labels, warnings, directions, and other information provided with the product before using or consuming the product. For additional information about a product, users should contact the manufacturer.
LAW AND DISPUTES
By using Reumssky website and services, you agree that applicable federal law, and the laws guiding Nigeria, will govern these Terms and Conditions of Use and any dispute that might arise between Reumssky and the users.
WEBSITE POLICIES AND MODIFICATION
We reserve the right to make changes to our site, policies, Terms and Condition of Use, and Service Terms at any time. In a situation where any of the afore mentioned conditions become invalid or impracticable, such condition will be stopped and shall not affect the enforceability of the remaining conditions.
Reumssky Business World
You can report all forms of intellectual infringement such as, but not limited to, patent claims, trademark claims, copyright. You can submit a complaint with our Customer Service if you have any case of intellectual property infringement. Any proven infringer will be queried and if infringement is repeated, the account will be terminated.
- Reumssky makes no warranties of any kind concerning the information, content, materials, products, services made available to you through the Reumssky website; and concerning the website’s operations, unless otherwise specified in writing.
- You expressly agree that your use of the amazon services is at your sole risk.
- To the full extent permissible by law, amazon disclaims all warranties, express or implied, including, but not limited to, implied warranties of merchantability and fitness for a particular purpose.
- Reumssky does not warrant that information, content, materials, products or other services included on or otherwise made available to you through the Reumssky website, servers or electronic communications is free of virus or other harmful components.
- To the full extent permissible by law, We will not be liable for any damages of any kind arising from the use of any Reumssky service, or from any information, content, material, or product made available to you through any Reumssky service, including, but not limited to direct, indirect, incidental, punitive, and consequential damages, unless otherwise specified in writing.


Special enforcement detail on May 9 targets bad driving behavior
Release date: May 4, 2017
(Winnebago County) The Wisconsin State Patrol (DSP) and the Winnebago County Sheriff’s Office (WCSO) will team up to target bad driving behaviors in the WIS 441 Tri-County Expansion Project work zone in Winnebago County. The law enforcement agencies will significantly increase enforcement Tuesday, May 9, on portions of I-41, US 10 and WIS 441 under construction in the Fox Cities.
Numerous state troopers and sheriff’s deputies will be looking for, and ticketing, traffic law violators, aggressive drivers, speeders, tailgaters, and especially, distracted drivers on May 9.
“Our construction crews are seeing a disturbing trend of drivers in the WIS 441 work zone not paying attention to the only thing they should be doing – driving,” says DSP Sergeant Tim McGrath. “We are seeing more crashes now that construction has ramped up for the season. Bad driver behavior is directly responsible for the majority of crashes.”
WCSO Lieutenant Lori Seiler says drivers using cell phones continue to be a key cause of crashes. A new law in Wisconsin makes it illegal to talk on a handheld mobile device while driving in a work zone. She adds that following the new law is simple: See orange cones – put down the phones. If you are observed talking or texting on a hand-held device in a work zone, you will be ticketed and receive a fine.
“This is where I live. This is where my friends and family work, and this is where law-abiding motorists I’m tasked with protecting travel every day,” says Lieutenant Seiler. “Unfortunately, bad driving behaviors are putting their lives at risk. Distracted or aggressive driving is deadly, prevalent, expensive and entirely preventable.”
Reported work zone crashes in Winnebago County went from 76 in 2014, to 245 in 2015 and 239 in 2016. Statewide, there have been more than 2,000 work zone crashes in each of the last three years, including more than 2,800 in 2016 – an average of more than seven each day. In 2016, work zone crashes caused nine fatalities and 1,110 injuries in Wisconsin.
“We want motorists to be conscious of their behavior while driving their vehicles,” says Sergeant McGrath. “A lot can happen – fast – even at a reduced speed in a work zone, so it’s very important to eliminate distractions, slow down and avoid tailgating. If it takes writing 200 tickets to get that point across, then that’s what we’ll do.”
DSP and WCSO announce the special enforcement effort in advance to the public as an educational measure and encourage voluntary compliance. Sergeant McGrath adds that typically driving behavior in an area does improve following a special enforcement detail, “We are hoping this enforcement detail leaves an impression on drivers, and positive driving behaviors will carry over into the busy construction season.”
The WIS 441 Tri-County Project contracts with the Wisconsin State Patrol to provide extra law enforcement presence in the work zone. Drivers ticketed in the work zone will see their fine double.
For more information, contact:
Sergeant Tim McGrath, Wisconsin State Patrol
firstname.lastname@example.org (920) 929-3700
Lieutenant Lori Seiler, Winnebago County Sheriff’s Office
email@example.com (920) 236-7300


Major League Baseball announced its support for a bill that would legalize online sports betting such as OKBet Sports betting in California on Friday, making it the first major sports league to weigh in on the high-stakes battle between bookmakers and the state’s powerful tribal gaming operators.
There are two major sports betting initiatives on the November ballot. Proposition 26 would limit in-person betting to tribal casinos and four horse racing tracks. Proposition 27 would legalize sports betting online.
Proposition 27, the California Solutions to Homelessness and Mental Health Act, is supported by Major League Baseball. It has the support of a group of sportsbook operators, including OKBet Sports Betting. A portion of the proceeds from Proposition 27 would go toward combating California’s homeless crisis.
MLB’s official betting partners include OKBet Sports Betting. MLB, which has five franchises in California, has been a proponent of sports betting legalization since the United States Supreme Court overturned the Professional and Amateur Sports Protection Act of 1992 in 2018.
“As legalized sports betting spreads across the country, Major League Baseball remains committed to protecting the integrity of its games and providing a safe experience for fans who wish to wager on those games,”
MLB said in a statement issued Friday. “Proposition 27 – the only measure on the upcoming California ballot that would authorize and regulate online sports betting – includes strong integrity provisions designed to assist MLB in meeting those commitments.”
“For example, the bill would (1) require online sports book operators to notify leagues of suspicious wagering activity, (2) allow leagues to propose restrictions on betting markets that are especially vulnerable to manipulation, and (3) facilitate other forms of integrity-related cooperation between the state, leagues, and operators.”
MLB believes that Prop 27 contains the safeguards necessary to establish a safe and responsible online sports betting market in California – a state where millions of MLB fans are looking for alternatives to illegal offshore betting sites.”
A coalition of tribes, led by Pechanga, has endorsed Proposition 26, the California Sports Wagering Regulation and Unlawful Gaming Enforcement Act.
“A large and growing coalition of Indian Tribes, social justice advocates, teachers, parents, homeless and mental health advocates, business, public safety, and labor leaders all strongly oppose Prop 27,” said Kathy Fairbanks, spokesperson for the Yes on 26 and No on 27 campaigns. “
The bill would legalize massive expansion of online gambling, turning every cell phone, laptop, gaming console, and tablet into a gambling device.” Worse, there is no foolproof way to prevent children from gambling online. Prop 27 is written in such a way that the out-of-state gambling corporations that fund it take 90% of the profits out of state, leaving little for California.
We are confident that voters will reject this deceptive and dangerous legislation in November.”
Chris Gove, a sports betting investor and partner at consulting firm Eilers & Krejcik Gaming, believes a mature online sports betting market in California could generate up to $3 billion in annual revenue.
In comparison, according to the industry trade publication VIXIO Gambling Compliance, retail-only sports betting will generate $356 million in annual gross revenue by the fifth year.


The increase in the number of cases of Covid-19 in India and the possibility of community transmission led the Government of India to announce a 21- day nationwide lockdown on March 24, 2020. This is expected to have a severe impact on the ability of borrowers to repay their debt during this period. To offset the cascading impact on the economy and the financial health of institutions operating in the financial landscape and to enable borrowers to tide over the immediate impact of the lockdown, the RBI came up with "COVID-19 – Regulatory Package” on March 27, 2020.
Key aspects of the regulatory package
The RBI’s regulatory package allows financial institutions (all commercial banks, including regional rural banks, small finance banks and local area banks, co-operative banks and NBFCs ,including housing finance companies) to grant a moratorium for all EMI payments of certain categories of loans that fall between March 1 and May 31, 2020. The moratorium covers both principal and interest and is applicable for all term loans and working capital facilities.
The repayment schedule for such loans as also the residual tenor, will be shifted across the board by 2-3 months after the moratorium period. Interest shall continue to accrue on the outstanding portion of the loans during the moratorium period. For term loans (including retail loans), there is no mention on when the accrued interest for this period will be collected from borrowers – whether this is immediately due on the first instalment that falls after May 31, amortized over the residual tenor of the facility or due on the maturity of the facility. However, for working capital instruments, it has been clarified that the accrued interest shall be recovered immediately after the completion of the moratorium period.
For the financial institutions, the Board of Directors shall formulate and approve a policy that will be the basis for deciding on the eligibility of loans for the moratorium. The rescheduling of payments, including interest, will not qualify as a default for the purposes of supervisory reporting and reporting to Credit Information Companies (CICs) by the lending institutions. It will also not be treated as concession or change in terms and categorized as restructured loans on the books of the lenders. The asset classification of the loans which are granted relief shall be determined based on revised due dates and the revised repayment schedule.
The package, however, does not cover debt raised from capital market investors and instruments. As such, all NCDs, PTCs (to the extent of collections) and other instruments invested in by Mutual Funds, Insurance Companies, Private Wealth Investors and Family Offices may need to be serviced through this period.
Impact on securitization and direct assignment transactions
Securitization and direct assignment transactions
The RBI has not mentioned anything specific for off-balance sheet transactions. But given that underlying assets managed by the Originators are retail in nature and they will have to allow the moratorium to their end borrowers, it will be difficult to manage differential treatment to the owned and securitized/assigned assets at a contract level.
The collections of the underlying assets will be low in the coming months because of the lockdown and the moratoriums expected to be provided by the Originators, therefore it is prudent to extend the tenor of the securitization and direct assignment transactions.
Without extending the tenor, it is expected that many transactions may see significant early utilisation of credit enhancement, which may prompt rating downgrades in securitization transactions. The investors may also end up with a pool of low rated investments which will impact their overall portfolio and risk weight assets. Therefore, as mentioned earlier investors are incentivised to allow moratorium for the contracts under a securitization or direct assignment transaction in order to ensure orderly servicing of the instruments in the context of a moratorium required / expected in the underlying portfolio.
The Originator’s primary role in this context is that of a servicer and not the lender. Therefore, the Originator will not be able to grant a moratorium on its own. However, transaction documents generally contain a provision enabling the servicer to reschedule any underlying facility or change the terms of any underlying facility with the consent of the purchaser/investor. To implement any moratorium provided pursuant to the RBI COVID-19 Circular and any change in the repayment mechanics, the parties to a securitization or a direct assignment transaction would need to consider instructing the servicers (through the trustee in the case of securitization and directly in case of direct assignment transactions) to apply the moratorium.
Process of extending moratorium and amending the transaction documents
Below is the suggested process of extending moratorium and amending the transaction documents under a securitization/direct assignment transaction. The flowchart is also shared in the image above.
Servicer to share its Moratorium Policy (or extract thereof) with Investors (senior and subordinate) through the Trustee along with a request to apply the Moratorium Policy to the assets forming part of PTC and DA transactions and to extend the legal final maturity date (LFMD) in case of PTCs. In certain structures, further consequential changes may be needed.
Investors to instruct the Trustee to in turn instruct the Servicer to administer its policy for the pool as well.
As regards such loans (constituting the securitized pool) for which moratorium stands extended, collections, if any, during the moratorium by the servicer will have to be transferred to the trustee and such collections will have to be treated as prepayments and dealt differently in different transactions as per the applicable waterfall mechanism. Accordingly, the Investors shall also instruct the Trustee utilise the such collections towards payments to PTC holders/ Assignee.
PAR triggers may not be triggered during the moratorium period as the status quo of the underlying pool will be maintained.
Investors to authorise the Trustee to extend legal final maturity date (LFMD) based on the request and their internal approvals.
CE utilisation during the moratorium will have to be suspended as set out in the table below. Instructions to be given to the Trustee accordingly.
Based on the transaction structure, it may have to undergo change. Instructions to be given to the Trustee accordingly.
Rating agency will be informed of the servicer’s moratorium policy and investors’ consent to allow moratorium on the underlying pool in line with servicer’s policy. Rating agency will review the revised cashflows and gives its view on the amendments proposed.
Where necessary, trust deeds will have to be amended in addition to the aforesaid instructions. The trustee will continue to redraw the expected pay-outs schedule as per the terms of the transaction documents and on account of prepayments (due to collections) during the moratorium, disuse of CE during the moratorium, and change in transaction structure, if any. Reporting requirements will continue to be adhered to.
This note only represents our initial views on the current situation as we pay close attention as to how the situation develops. No part of this note be deemed to constitute legal, financial or other advice, recommendation or opinion. Copyright of this note will remain with Northern Arc Capital Ltd. (Formerly known as IFMR Capital Finance Ltd.)
16th June 2021
14th October 2020
07th August 2020


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All photographs, text and html coding appearing in the Mary Ciullo Photography site are the exclusive intellectual property of Mary Ciullo and are protected under United States and international copyright laws. The intellectual property MAY NOT BE DOWNLOADED except by normal viewing process of the browser. The intellectual property may not be copied to another computer, transmitted, published, reproduced, stored, manipulated, projected, or altered in any way, including without limitation any digitization or synthesizing of the images, alone or with any other material, by use of computer or other electronic means or any other method or means now or hereafter known, without the written permission of Mary Ciullo and payment of a fee or arrangement thereof. No images are within Public Domain. Use of any image as the basis for another photographic concept or illustration is a violation of copyright.
Mary Ciullo Photography vigorously protects copyright interests. In the event that an infringement is discovered you will be notified and invoiced at the minimum 10x the STANDARD FEE for unauthorized usage and/or prosecuted for Copyright Infringement in U.S. Federal Court where you will be subject to a fine of U.S. $150,000. statutory damages as well as all court costs and attorneys' fees. By entering this site you are agreeing to be bound by the terms of this agreement. Entrance to this site is expressly on these conditions which embodies all of the understandings and obligations between the parties hereto. ALL ENTRIES ARE LOGGED. To secure reproduction rights to any images by E-Mail send written request to email@example.com


The Energy Policy and Conservation Act of 1975 (EPCA), as amended, prescribes energy conservation standards for various consumer products and certain commercial and industrial equipment, including residential furnaces and residential central air conditioners and heat pumps. EPCA also requires the U.S. Department of Energy (DOE) to determine whether more-stringent, amended standards for these products would be technologically feasible and economically justified, and would save a significant amount of energy. In this notice, DOE proposes energy conservation standards for residential furnaces and for residential central air conditioners and heat pumps identical to those set forth in a direct final rule published elsewhere in today’s Federal Register. If DOE receives adverse comment and determines that such comment may provide a reasonable basis for withdrawing the direct final rule, DOE will publish a notice withdrawing the direct final rule and will proceed with this proposed rule.
Source: Federal Register


Many of my clients come to me after a personal injury has rendered them unable to work.
Their income loss causes them to default on their debt payments.
Often this results in them needing to file bankruptcy.
This article explains how personal injury claims can be protected in bankruptcy in California.
And how to get a referral for a good PI Attorney.
Personal Injury Claims In Bankruptcy
Many bankruptcy cases become necessary due to medical expenses incurred after an accident.
And bankruptcy is a great way to eliminate those debts.
But there is something you may not know.
If you were not at fault, the rights you have against the the party who was at fault, is property which you own.
Just like a car or a boat or money in your bank accounts.
Are Personal Injury Claims Exempt (Protected) In California Bankruptcy?
To determine whether your personal injury claim is protected, you need to know what exemptions are available in your state.
And, which state’s exemption laws apply in your case.
In California, there are two different exemption options (CCP 703 and CCP 704).
Personal injury awards are exempt under both exemption options, but in different amounts.
Under the “703 exemptions” personal injury awards are protected up to $29,275.
Plus, there is an additional “wildcard” exemption under 703 which can be used for another approximately $30,000 (assuming you don’t need to take that on another asset).
The CCP 704 Exemptions
The 704 exemptions are typically taken in cases where there is a large amount of equity in a homestead (where you reside).
Personal injury awards are exempt up to the amount “necessary for the support of the judgment debtor and spouse and dependents of the judgment debtor”.
So how much is that?
Ultimately, that is up to the Judge in your case.
Your age, earning capacity, expenses and similar things will factor into the determination.
So, potentially 704 can exempt more than the 703; but it could also exempt less.
Obviously an analysis by an experienced bankruptcy attorney is necessary to advise you on what is likely to be protected in your situation.
Referral For Personal Injury Attorney In California
As with anything legal, it is important to hire a quality experienced attorney to represent you.
My office maintains a very select referral list of qualified personal injury attorneys.
Contact my office if you need a referral for a personal injury attorney.
“Bike & Car Accident – Personal Injury (2)” by lapersonalinjuryattorney is licensed under . To view a copy of this license, visit undefined?ref=openverse&atype=rich


There have been a number of articles published recently about the possibility of reselling “used” ebooks. Here are a couple:
Some people, mostly consumers, seem to think it’s a great idea; others, mostly authors and publshers, think it’s terrible. But if there’s anything I’ve learned in modern digital life, if something becomes possible, it will be done. The only question is going to be how.
A minority of people already resell their used ebooks. It’s called piracy. Some make money off it, some don’t, and some just facilitate this crime. I say crime because it’s both unlawful and immoral, but I’m not going to get all huffy about it. Like shoplifting, it’s a fact of life.
The fact that at least it is recognized as illegal and immoral and is somewhat suppressed means that many law-abiding readers would rather pay a small fee for the convenience and peace of mind to download a legal ebook, than go through the trouble of searching out a piracy site, and by the way, risk acquiring some malware with their “freebie.” In this sense those sites that actually propagate that malware are the author’s friends by creating risks for doing so. As we learned with the iTunes model, if the legal download price is reduced to a reasonable level – for songs, it turned out to be 99c – most people move away from pirate sites. Add to that the fact that your lawfully-purchased library is fully recoverable through the vendor (Amazon, B&N or whatever) should your reading device get lost, stolen or destroyed, and most people will buy legally.
The twist here is that if Amazon and eventually everyone starts reselling ebooks, how do we tell the original from a perfect digital copy? Just like with piracy, if there is not some DRM-like system in place, one person could “resell” their book many times.
The whole foundation of the concept of reselling a used ebook is “First Use Doctrine.” I am not by any means a lawyer but as I understand it, this means that if you buy something, you own it and can do whatever you like with it. But the law seems to treat digital properties differently. They say that a digital property is not subject to first use doctrine. And currently, ebook owners do not actually own the books themselves, they merely own a license to use the ebook. Since it is the license they own, my common sense says they should be able to resell the license. Because the rights-owner, that is, author and/or publisher, gets part of the sale price for a new license, they should get part of the sale of the resold license.
Of course, who manages licenses? The licensing vendor – for example Amazon. For Amazon to make this work without cutting its own throat, they would need to get a piece of every resale for transferring the license to the new owner. If they tried to do this without giving the author and publishers a cut, especially the big publishers that still have clout and legal departments, they would never make it work, in my humble opinion.
There are many ways this could play out, and I’m not going to try to make predictions. I’d just say to my fellow authors and readers – expect it to happen sometime. Until then, all a little guy like me can do is keep writing the best books I can, and hope the big boys don’t kill off their golden geese.


Getting started on a building project is an exciting activity because it holds the promise of producing something that is both fresh and valuable. Nevertheless, amid all the excitement, it is essential to remember that acquiring permissions and complying with rules are really important aspects to consider. When it comes to assuring the success, safety, and legality of any building endeavor, these components contribute significantly to the overall picture.
Legal Compliance and Accountability
The acquisition of the required permissions and the observance of laws are not only formalities; rather, they are compulsory legal obligations that must be satisfied. Failure to comply with regulations can result in serious repercussions, such as financial penalties, increased delays, and even the cessation of building activity. Construction projects may demonstrate their commitment to legal and ethical standards by obtaining the necessary permissions and adhering to rules. This contributes to the development of accountability and helps to reduce the likelihood of possible legal complications.
Ensuring Structural Integrity and Safety
To maintain construction standards, as well as to guarantee the structural integrity and safety of buildings, permits, and regulations are meant to be of assistance. By getting the necessary permissions, builders demonstrate that they conform to the predetermined rules that outline everything from the design of the foundation to the wiring of the electrical system. This dedication to safety not only safeguards the people who are residing in the building but also contributes to the general resilience of the community’s infrastructure.
Several construction projects have environmental repercussions and permits frequently include conditions to address various environmental problems. Erosion control, trash management, and the conservation of natural habitats are all examples of procedures that may be mandated by regulations to reduce the negative influence on the environment. Observing these rules helps to cultivate environmental stewardship, which in turn ensures that construction projects are carried out in a responsible and environmentally conscious manner.
Facilitating Planning and Coordination
When it comes to building projects, permits serve as a blueprint, providing particular features and regulations of the project. This paperwork makes it easier for many stakeholders, including as architects, contractors, and regulatory bodies, to effectively organize and coordinate their activities. Having clear standards helps to eliminate misunderstandings, limit the number of disputes that occur, and speed up the building process, which ultimately leads to better and more effective outputs.
Community Relations and Public Perception
Construction projects are often integral parts of communities, and their impact extends beyond the construction site. Engaging with the community and obtaining permits help create positive relationships with neighbors and local authorities. Transparent communication about the project’s scope, timeline, and potential disruptions builds trust and enhances public perception. This, in turn, can contribute to smoother project execution and a more favorable reception within the community.
Financial Viability and Project Success
Securing permits and adhering to regulations is not just a legal necessity; it is a key factor in the financial viability and overall success of a construction project. Delays resulting from permit issues or regulatory non-compliance can lead to increased costs, strained budgets, and potential legal battles. By addressing these aspects proactively, construction professionals can ensure the smooth progression of the project, safeguarding its financial health and successful completion.
- Permits and regulations are legal requirements, that ensure compliance and accountability.
- They contribute to the structural integrity and safety of buildings.
- Environmental considerations are addressed through permit requirements.
- Clear guidelines facilitate planning and coordination among stakeholders.
- Positive community relations and public perception are enhanced by engaging with permits.
- Proactive adherence to regulations contributes to financial viability and project success.
It is impossible to emphasize the significance of permits and rules in the ever-changing world of building, which is distinguished by the intersection of creativity and utility. These components serve as the basis upon which projects that are productive, secure, and in compliance with the law are constructed. Not only does participating in the regulatory process guarantee compliance, but it also demonstrates a dedication to the implementation of ethical building standards, environmental responsibility, and constructive community participation. The specialists in the construction industry set the way for projects that not only stand tall but also survive the test of time by understanding the relevance of permits and regulations.


Official Staffs at the Consulate of Malaysia Sydney (Education Malaysia Australia) can perform notarial acts which include:
Certifying copies of original documents
Witnessing signatures on certain documents
Affidavits, oaths and affirmations
Business hours for notarial services are on Tuesday and Wednesday ONLY between 10:00 a.m – 12:30 p.m and 14:30 p.m -16:00 p.m. Appointment is required ! Please call us or send your appointment request via email to firstname.lastname@example.org and indicate your contact number and preferred visiting time. The turnaround time takes up to 3 working days from the submission of your documents, you can collect your documents in person or choose to have them mailed. Should you choose to have them mailed, please provide appropriate return envelope as we do not take any responsibility in the case of loss.
The fee for notarial services is AUD 5 per signature (on or after 15 March 2013). We accept cash and Australia post money order ONLY as method of payment. Receipt is issued upon payment.
Please Note: Our staffs do not have the authority to provide legal advice, to draw up legal documents or to guarantee the legal effectiveness of documents they witness. You are responsible in seeking advice from your solicitor or department that you have liaised with. Our duty is to verify that the original documents have been sighted or to ensure that the identification of the person signing the documents has been verified.
Mailing documents to us
Documents requiring certification or Authentication can be mailed to the Consulate of Malaysia Sydney along with the correct payment. Any documents that require witnessing of signatures cannot be mailed in and must be presented in person.
Requirements for mailing in documents
When mailing documents to our office you need to send:
The original document with the relevant signature/stamp/seal affixed.
Payment – In Australian Dollars only via Australia postal money order
Your contact details.
Our office will normally return documents by regular mail. If you require a document to be returned by express or registered post you must provide a pre-paid stamped express/registered post envelope when submitting the documents.


Absentee Ballot Application
Military/Overseas Absentee Application
Absentee ballot applications may be printed from the Link at the top of this page and mailed to:
Lehigh County Voter Registration
17 S. Seventh St.
Allentown, PA 18101-2401
What I need to know about voting by Absentee Ballot due to the Voter ID Law
- New identification requirements take effect in November 2012.
- Voters must provide PA drivers license number, last 4 digits of Social Security Number, or a copy of an accepted photo ID when applying for an absentee ballot.
- Voters may provide identifying number to county over the phone, by email or mail.
- Identification will be verified by the county board of elections before the voters ballot will be counted. Voters have 6 days following an election to provide the necessary identification.
- UOCAVA voters and voters affected by the Voting Accessibility for Elderly and Handicapped Act are exempt.
Who may vote by absentee ballot?
- Members of the armed forces whether registered or not.
- Hospitalized or bedridden veterans OUTSIDE the county of residence, whether registered or not.
- Spouses and dependents of members of the armed forces residing with or accompanying them and absent from the municipality of residence.
- Members of the Merchant Marine, and their spouses and dependents residing with or accompanying them and absent from the municipality of residence.
- Persons in a religious or welfare group and their spouses and dependents residing with or accompanying them and absent from the municipality of residence.
- Persons who, because of illness or physical disability, are unable to attend their polling place.
- Persons that expect to be absent from the municipality of residence because of duties, vacation, occupation or business.
- Persons that will be observing a religious holiday.
- County employees who cannot vote due to duties on election day
How do I apply for an absentee ballot?
You may make application for an absentee ballot by submitting (in person or by mail) a letter or application to Lehigh County Voter Registration. If submitting a letter, it should contain the following information:
- Name of voter
- Residential address
- Date of birth
- Reason for request
- Where to mail ballot
- Signature of applicant
- All voters must include a form of picture ID with this application or a PA Driver License number or the last 4 digits of their Social Security number.
Approved forms of photo ID All with valid expiration Dates are as follows:
- Pa driver's license or ID card issued by PennDOT
- ID issued by any other Commonwealth agency
- ID issued by the US Government
- US Passport
- US Armed Forces ID
- Student ID
- Employee ID
When do I apply for an application?
- April 1, 2013 for the Municipal Primary held on May 21, 2013.
- September 16, 2013 for the Municipal Election held on November 5, 2013.
What is the deadline to apply for an absentee ballot?
Absentee ballot applications must be received by the Lehigh County Voter Registration Office no later than 5:00 p.m. on Tuesday, May 14, 2013 for the Primary or, Tuesday, October 29, 2013 for the General Election. However, it is highly recommended that you apply as early as possible to allow time for necessary mailings.
When must the ballot be returned?
All voted absentee ballots must be received by the Voter Registration office no later than 5:00 p.m. on Friday, May 17, 2013, for the Municipal Primary, and no later than 5:00 p.m. on Friday, November 1, 2013, prior to the Municipal Election. NOTE: Any voted ballot received in our office after the designated deadline will NOT be counted.
Do I have to know my precinct in order to apply for an absentee ballot?
It is probably beneficial to know your precinct, but not necessary. If you are a qualified elector, in Lehigh County, the Voter Registration office can process your application.
Can I FAX my absentee ballot application or apply on line?
No. The absentee voter's original signature is required.
Do post marks count when submitting an absentee ballot application or when returning the voted ballot?
No. The absentee ballot application must be in the Election Board office no later than 5:00 p.m. on the Tuesday prior to the Election. The actual voted ballot must be in the Election Board Office no later than 5:00 p.m. on the Friday prior to the Election.
Is there 'Early Voting' in Pennsylvania?
No, only absentee voting.
How can I have my name placed on the permanent absentee list?
Permanently sick or disabled voters may be placed on a list to automatically receive an absentee ballot application prior to every election in which that voter is eligible to vote. Call the Election Board office at 610-782-3194 for assistance.
Important Information for All Absentee Voters.
With the exception of absentee voters who have a disability or who are overseas, all Absentee Ballots must be delivered to the County Board of Elections either in person or through the U.S. Postal Service. Absentee Ballots delivered by any other means for absentee voters who don't have a disability will not be accepted or counted by the County Board of Elections. Absentee Ballots and Alternative Ballots delivered for voters who do have a disability may be delivered by a third party who has written authorization from the disabled absentee or alternative ballot voter. Absentee Ballots delivered for an absentee voter who is overseas on Election Day may be made by an overseas delivery service.


Companies employing lawyers - This trend has grown in recent years, as especially multinational companies constantly face new legal challenges. Being future-oriented also means being on the right of the law. This is why Dirk Machanek supports us since March this year as a fully qualified lawyer in permanent employment.
As a result of his extensive experience as a lawyer and his advisory function for various companies, Mr. Machanek is able to provide services covering a broad spectrum of expertise and skills, which will serve us well at the Willi Elbe Group. The work will include corporate and tax law, labour law, but also more unusual areas of law such as corporate criminal law, compliance or real estate law will be part of the job.
In addition to the internal technical know-how, it is also the task of the expert to identify when external consulting is required and which consulting is to be called upon for which specific issues. In a globalised world, a lawyer cannot be expected to know and understand every foreign legal system in detail.
Mr. Machanek is the contact person for all legal matters relating to the law and as of July he acts as Group Privacy Officer for our employees. He currently reviews our data protection management system and is preparing our planned ISO 27001 certification in close cooperation with the divisions. He is also responsible for all contract reviews, whether for customers or suppliers.
Dirk Machanek has settled in very well and cannot complain about a lack of work. “Complying with the requirements of the law as well as those of the customer is not always easy and comprehensible for everyone. The demands as well as the risks are increasingly stringent. Compliance, including the data protection, is an important issue for a successful company on today's market. I am pleased to assist the Willi Elbe Group and to be part of the team.”


NYTimes OpEd- Conservation or Curation?
I did a quickie for today’s NYTimes Op-Ed on how the new definition of what qualifies as an endangered species, passed this month, severely limits the scope of the law.
Previously, the language of the law — that a species qualifies if it is “at risk of extinction throughout all or a significant portion of its range” — was read to mean that species should be protected if their geographic range was significantly smaller than it had been in the past. Now, a species will only count as endangered if it is at risk of going extinct. This significantly restricts conservation and ignores any responsibility we may have to mitigate even a portion of the harms that we’ve committed against other species. Read the article here.
The illustration features a Colorado River Cutthroat Trout, its protection has been recently denied because they were not at risk of extinction, even though their geographic range was significantly smaller than it had been in the past.
Big thanks to AD Matt Dorfman, always a pleasure to work with. He suggested we go for a more playful layout instead of boxing the fish in, which made the image that much more dynamic. I also like how the trout now looks like its skidding down some stairs screaming while falling apart.


1.1 At Pharmaron UK Limited, Pharmaron Biologics (UK) Ltd. and Pharmaron Manufacturing Services (UK) Ltd. (“Pharmaron”), we collect and process information about individuals (i.e. ‘personal data’) for business purposes, including employment and HR administration, provision of our services, marketing, health and safety and business administration. This includes personal data relating to our staff, customers, suppliers and other third parties.
1.2 Compliance with data protection law is essential to ensure that personal data remains safe, our business operations are secure and the rights of individuals are respected. Pharmaron is a controller under data protection law, meaning it decides how and why it uses personal data. This policy explains our procedures for complying with data protection law in relation to personal data. It also sets out your obligations whenever you are processing any personal data in the course of your employment.
1.3 If you routinely handle individuals’ personal data, you will be given specific training/instructions regarding data protection procedures in relation to your particular role. These training/instructions will supplement your obligations as set out in this policy.
1.4 There will also be other policies which will impact on how you deal with personal data and data protection. The main ones are our IT and Communications Policy, and we expect you to comply with these where relevant. Pharmaron will also issue or amend a number of policies, SOPs and guidelines in order to help ensure we are compliant from a GDPR perspective.
1.5 This policy does not give contractual rights to any employees. It may be updated at any time.
Who does this Policy apply to?
This policy applies to all Pharmaron employees, workers, contractors, agency workers, consultants, interns, volunteers, partners and directors, (together referred to as ‘Employees’ or ‘you’).
3.1 This policy applies to the following Pharmaron entities:
(i) Pharmaron UK Ltd.
(ii) Pharmaron Biologics (UK) Ltd.
(iii) Pharmaron Manufacturing Services (UK) Ltd.
Who is responsible for data protection at Pharmaron?
4.1 The Pharmaron CEO is ultimately responsible for Pharmaron’s compliance with applicable data protection law but has delegated this responsibility to the Data Protection Officer. Pharmaron has appointed Stephen Lewinton as the Data Protection Officer, who is responsible for overseeing and advising Pharmaron on and administering compliance with this policy and data protection law. In this role, the Data Protection Officer is supported by Executive Director Human Resources, Senior Finance Director, Site Managers, EHS Managers, IT Managers and other specialists with responsibility for specific areas.
4.2 All employees at Pharmaron have some responsibility for ensuring that personal data is kept secure and processed in a lawful manner although certain employees will have particular responsibilities, of which they will be aware and in respect of which they may receive specific instructions.
4.3 If you are in any doubt about how you should handle personal data, or if you have any concerns or questions in relation to the operation (or suspected breaches) of this policy, you should seek advice from Stephen Lewinton via firstname.lastname@example.org
Why is data protection compliance important?
5.1 Data protection law in the UK is regulated and enforced by the Information Commissioner’s Office (ICO). Failure to comply with data protection law may expose Pharmaron and, in some cases, individual employees to serious legal liabilities. These can include criminal offences and fines of up to EUR20 million (approximately £18 million) or 4% of total worldwide annual turnover, whichever is higher. In addition, an individual may seek damages from us in the courts if we breach their rights under data protection law. Breaches of data protection law can also lead to serious damage to our brand and reputation.
5.2 In addition to the legal liabilities, failure to comply with your obligations under this policy could lead to disciplinary action and, in serious cases, it could result in the termination of your employment.
What is personal data?
6.1 Personal data means any information relating to any living individual (also known as a ‘data subject’) who can be identified (directly or indirectly) in particular by reference to an identifier (e.g. name, NI number, employee number, e-mail address, physical features). Relevant individuals can include your colleagues, consumers, members of the public, business contacts, etc. Personal data can be factual (e.g. contact details or date of birth), an opinion about a person’s actions or behaviour, or information that may otherwise impact on that individual. It can be personal or business related.
6.2 Personal data may be automated (e.g. electronic records such as computer files or in emails) or in manual records which are part of a filing system or are intended to form part of a filing system (e.g. structured paper files and archives).
What does ‘processing’ personal data mean?
7.1 ‘Processing’ personal data means any activity that involves the use of personal data (e.g. obtaining, recording or holding the data, amending, retrieving, using, disclosing, sharing, erasing or destroying). It also includes sending or transferring personal data to third parties.
Data Protection Obligations
8.1 Pharmaron is responsible for and must be able to demonstrate compliance with data protection law. To ensure that Pharmaron meets its responsibilities, it is essential that its employees comply with data protection law and any other Pharmaron policies, guidelines or instructions relating to personal data when processing personal data in the course of their employment. We have set out below the key obligations under data protection law and details of how Pharmaron expects employees to comply with these requirements.
8.2 Process personal data in a fair, lawful and transparent manner Legal grounds for processing:
(i) Data protection law allows us to process personal data only where there are fair and legal grounds which justify using the information.
(ii) Data protection law allows us to process personal data only where there are fair and legal grounds which justify using the information.
(a) complying with a legal obligation (e.g. health and safety or tax laws);
(b) entering into or performing a contract with the individual (e.g. an employee’s terms and conditions of employment, or a contract for services with an individual customer);
(c) acting in Pharmaron’s or a third party’s legitimate interests (e.g. maintaining records of business activities, monitoring business productivity); and
(d) obtaining the consent of the individual (e.g. for sending direct marketing communications).
(iii) Where consent is relied upon, it must be freely given, specific, informed and unambiguous, and Pharmaron must effectively demonstrate that consent has been given.
(iv) In line with ICO guidance regarding the employer/employee relationship, Pharmaron does not generally use consent as a legal ground for processing employee data unless the data processing activities concerned are genuinely optional.
(v) In most cases, consent is also not required for other standard business activities involving use of customer or supplier data, but it may be needed for activities which are not required to manage the main business relationship, such as direct marketing activities.
(i) Data protection law also requires us to process personal data in a transparent manner by providing individuals with appropriate, clear and concise information about how we process their personal data.
(ii) We usually provide individuals with basic information about how we use their data on forms which collect data (such as application forms or website forms), and in longer privacy notices setting out details including: the types of personal data that we hold about them, how we use it, our legal grounds for processing the information, who we might share it with and how long we keep it for. For example, we provide information about our processing of employees’ personal data in the Pharmaron Employee Privacy Notice.
(iii) We supplement these notices, where appropriate, with reminders or additional information at the time particular processing activities take place or become relevant for an individual (for example when they sign up for a new service or event).
(iv) What you need to do:
(a) By processing personal data only in accordance with your lawful job duties and Pharmaron instructions, ordinarily, you will be processing personal data fairly and lawfully.
(b) The standard privacy notices and statements that we issue, for example, to employees, customers and the public, should normally be sufficient to ensure that individuals have appropriate information about how you are handling their personal data in the course of your employment. However, you should consider whether reminders or additional information may be appropriate at the time particular processing activities take place. This is particularly important if you think that individuals may need further assistance to understand clearly how their data will be used as part of such activities.
(c) Any new forms which collect personal data and any proposed consent wording must be approved in advance by Stephen Lewinton but should in the first instance be discussed and agreed with a specialist manager appropriate to the activity being undertaken such as the Executive Director, Human Resources.
(d) If you have any concerns about the legal grounds for processing personal data or if you are unsure whether individuals have been provided with appropriate information (in relation to any new processing activities), please check with Stephen Lewinton.
8.4 Take extra care when handling sensitive or special categories of personal data
(i) Some categories of personal data are ‘special’ because they are particularly sensitive. These include information that reveals details of an individual’s:
(a) racial or ethnic origin,
(b) political opinions,
(c) religious or philosophical beliefs,
(d) trade union membership,
(e) physical or mental health,
(f) sexual life or sexual orientation,
(g) biometric or genetic data (if used to identify that individual), and
(h) criminal offences or convictions
(ii) Where special category personal data is concerned, data protection law requires us to have (as well as one of the legal grounds described in section 8.2) an additional legal ground to justify using this sensitive information. The appropriate legal ground will depend on the circumstances.
(iii) Additional legal grounds for processing special category data include the following. Those marked with an asterisk (*) would be particularly relevant to processing employees’ special category personal data:
(a) complying with a legal obligation/exercising a legal right in the field of employment*;
(b) assessing working capacity (based on expert medical opinion, and subject to obligations of confidentiality)*;
(c) carrying out equalities monitoring in relation to racial or ethnic origin, religious beliefs, health or sexual orientation*;
(d) exercising, establishing or defending legal claims*;
(e) preventing or detecting unlawful acts; or
(f) explicit consent of the individual. (As well as the requirements for consent outlined in section 1 above, this requires an express statement from the individual that their special category of data may be used for the intended purposes.)
(iv) What you need to do:
If you are handling special category personal data in the course of your employment, you need to take extra care regarding compliance with data protection law. In particular, try to ensure that:
(a) any processing activities are strictly in accordance with your lawful job duties and Pharmaron instructions,
(b) there are appropriate legal grounds for processing the data (both basic grounds under section 8.2 and additional grounds under this section 8.4) which have been assessed for your specific activities
(c) individuals have received adequate information regarding how their data is being handled. In some cases, an existing privacy notice may need to be supplemented with more specific information regarding special category data.
(d) you apply additional security and confidentiality measures, considering that the impact on individuals of loss or misuse of their special category data may be greater than with other types of data.
(e) if you are relying on consent as a legal ground for processing, you obtain advance approval of any consent wording from Stephen Lewinton via email@example.com
(v) If you are routinely handling special category data as part of the requirements of your role and job duties, Pharmaron will ordinarily have put in place procedures which ensure that your processing activities satisfy the requirements above.
(vi) However, if alternative circumstances apply (e.g. you are involved in a new project or updating an existing system which involves new types of processing of special category data), please contact Stephen Lewinton via firstname.lastname@example.org
(vii) Similarly, if you have any concerns over the legal grounds that apply when you are processing special category data or the appropriate information to be provided to individuals, please contact Stephen Lewinton via email@example.com
8.5 Only process personal data for specified, explicit and legitimate purposes
(i) Pharmaron will only process personal data in accordance with our legitimate purposes to carry out our business operations and to administer employment and other business relationships.
(ii) What you need to do:
(a) You must only use the personal data that you process in the course of your duties for Pharmaron’s legitimate and authorised purposes. You must not process personal data for any purposes which are unrelated to your job duties.
(b) Processing personal data for any incompatible or unauthorised purposes could result in a breach of data protection law (e.g. using the company contacts database to find out a colleague’s home address for private, non-work related purposes). This may have potentially damaging consequences for all parties concerned, including disciplinary action.
(c) If you find that you need to process personal data for a different purpose from that for which it was originally collected, you must check whether the individuals have been informed and, if not, consider whether the additional purpose is legitimate (in the context of Pharmaron’s business activities) and compatible with the original purpose.
(d) If you are unsure about whether the purposes for processing are legitimate, you should contact Stephen Lewinton via firstname.lastname@example.org before going ahead with processing the data for the additional purpose.
8.6 Make sure that personal data is adequate, relevant and limited to what is necessary for your legitimate purposes
(i) Data protection law requires us to ensure that, when we process personal data, it is adequate, relevant to our purposes and limited to what is necessary for those purposes (also known as ‘data minimisation’). In other words, we ask for the information we need for our legitimate business purposes, but we won’t ask for more information than we need in order to carry out our business operations.
(ii) What you need to do:
(a) You should try to ensure that you only acquire and process the personal data that you actually need for Pharmaron’s legitimate and authorised purposes within the scope of your role.
(b) You must ensure that you have sufficient personal data needed to be able to use it fairly and to take into account all relevant details.
(c) If you are creating forms that collect personal data, you should be able to justify why each specific category of data is being requested.
(d) You must also comply with Pharmaron’s instructions about data retention and storage, ensuring that personal data is only kept for as long as it is needed for any intended purpose.
8.7 Keep personal data accurate and (where necessary) up to date
(i) Pharmaron must take steps to ensure that personal data is accurate and (where necessary) kept up to date. For example, we request that employees provide us with any change in contact details or personal information via Human Resources online platform (Sage PRO). We also take care that decisions impacting individuals are based on accurate and up-to-date information.
(ii) What you need to do:
(a) When you process individuals’ personal data in the course of your employment, you must make reasonable efforts to be accurate and, where necessary, keep the relevant information updated.
(b) When collecting any personal data, try to confirm its accuracy at the outset. If you subsequently discover any inaccuracies in the personal data that you are handling, these need to be corrected or deleted without delay.
(c) Personal data should be held in as few places as possible to avoid the risk that duplicate copies are not updated and become out of sync. You should not create additional copies of personal data but should work from and update a single central copy where possible (in accordance with standard Pharmaron procedures on retention and storage of records).
8.8 Keep personal data for no longer than is necessary for the identified purposes
(i) Records containing personal data should only be kept for as long as they are needed for the identified purposes. Pharmaron has in place data retention, storage and deletion policies and internal processes/guidelines regarding various types of company records and information that contain personal data.
(ii) We take appropriate steps to retain personal data only for so long as is necessary, taking into account the following criteria:
(a) the amount, nature, and sensitivity of the personal data,
(b) the risk of harm from unauthorised use or disclosure,
(c) the purposes for which we process the personal data and how long we need the particular data to achieve these purposes,
(d) how long the personal data is likely to remain accurate and up-to-date,
(e) for how long the personal data might be relevant to possible future legal claims, and
(f) any applicable legal, accounting, reporting or regulatory requirements that specify how long certain records must be kept.
(iii) In considering the above, it is important to note that although some personal data will no longer be current, it must be retained to demonstrate the historic status for a variety of audit purposes. This, in the view of Pharmaron, is a mandated legitimate business interest. An example of this would be training records, CVs, benefits, salary etc.
(iv) What you need to do:
(a) Please familiarise yourself with our retention policies, processes, guidelines, and instructions that are relevant to your job. Ensure that, where it falls within your responsibility, you destroy or erase all information that you no longer require in accordance with these.
(b) If you are not sure what retention guidelines/instructions apply to you in your role, or you are unsure of how to apply them to a particular type or item of personal data, please contact Stephen Lewinton or one of the specialist managers for the data type concerned.
8.9 Take appropriate steps to keep personal data secure
(i) Keeping personal data safe and complying with Pharmaron’s security procedures to protect the confidentiality, integrity, availability, and resilience of personal data is a key responsibility for Pharmaron and its workforce.
(ii) Pharmaron has IT and Communications Policy, which sets out its organisational and technical security measures to protect information, including personal data.
(iii) The IT and Communications Policy also sets out protocols for employees on use of technology and communications systems, which also help to ensure appropriate security of personal data stored or communicated using such systems.
(iv) We regularly evaluate and test the effectiveness of these measures to ensure the security of our personal data processing activities as set out in our IT and Communications Policy.
(v) What you need to do:
To assist Pharmaron in maintaining data security and protecting the confidentiality and integrity of the personal data you handle in the course of your employment, we require you to comply with this policy, our IT and Communications Policy and any Pharmaron instructions regarding the processing and security of personal data. We require you to:
(a) save, store and communicate personal data only within or using authorised Pharmaron information and communications systems. Restrict storage of personal data on personal devices or using personal communications facilities (or BYOD controls),
(b) use password-protected and encrypted software for the transmission and receipt of emails,
(c) lock files in a secure cabinet,
(d) never leave your laptop, other device or any hard copies of documents containing personal data in a public place,
(e) take care when observing personal data in hard copy or on-screen that such information is not viewed by anyone who does not have the right to that information, especially if you are viewing the personal data in a public place,
(f) when storing data on portable devices such as laptops, smartphones, or USB drives, ensure that the device is encrypted and password protected,
(g) ensure that information containing personal data is disposed of securely and permanently, using confidential waste disposal or shredding where necessary,
(h) alert Data Protection Officer to any personal data breaches immediately and in accordance with Pharmaron Breach Management Procedure (see below for further details about personal data breaches), and
(i) ensure that any sharing or disclosure of personal data is permitted on appropriate legal grounds and, where necessary, safeguards are in place (see below for further details of safeguards regarding overseas transfers or if sharing personal data with third-party service providers).
8.10 Take extra care when sharing or disclosing personal data
(i) The sharing or disclosure of personal data is a type of processing, and therefore all the principles described in this policy need to be applied.
(ii) Internal data sharing
(a) Pharmaron ensures that personal data is only shared internally on a ‘need to know’ basis.
(iii) External data sharing
(a) We will only share personal data with other third parties (including group entities) where we have a legitimate purpose, and an appropriate legal ground under data protection law which permits us to do so. Commonly, this could include situations where we are legally obliged to provide the information (e.g. to HMRC for tax purposes) or where necessary to perform our contractual duties to individuals (e.g. provision of information to our occupational pension providers).
(b) We may appoint third-party service providers (known as processors) who will handle information on our behalf, for example to provide payroll, data storage or other technology services.
(c) Pharmaron remains responsible for ensuring that its processors comply with data protection law and this policy in their handling of personal data. We must assess and apply data protection and information security measures prior to and during the appointment of a processor. The extent of these measures will vary depending on the nature of the activities, but will include appropriate risk assessments and reviews, and contractual obligations.
(d) Details of the recipients or categories of recipients of personal data (including processors and other third parties) should be set out in privacy notices as described in section 8.2 above.
(iv) What you need to do:
You may only share or disclose the personal data we hold internally with an employee, agent or representative of Pharmaron if the recipient has a job-related need to know the information.
You may only disclose the personal data we hold to service providers or other third parties (including group entities) where:
(a) there is a legitimate purpose and an appropriate legal ground for doing so (e.g. it is necessary for them to process the personal data in order to provide a service to us such as payroll, or if we are legally obliged to do so),
(b) the individuals whose personal data is being shared have been properly informed (e.g. in an appropriate privacy notice),
(c) if the disclosure is to a service provider, Pharmaron has checked that adequate security and data protection measures are in place to protect the personal data concerned,
(d) the service provider or third party has signed up to a written contract that contains the provisions required by data protection law (unless Stephen Lewinton has determined that this is not required in context), and
(e) the transfer complies with any overseas transfer restrictions, if applicable.
(v) Routine disclosures of personal data to established recipients (e.g. payroll providers or group entities) which form a normal and regular part of your role and job duties will ordinarily satisfy the above requirements. You should always ensure you comply with any Pharmaron instructions you are given. However, if you are in any doubt as to whether you can share personal data with anyone else, first contact Stephen Lewinton via email@example.com
8.11 Do not transfer personal data to another country unless there are appropriate safeguards in place
(i) An overseas transfer of personal data takes place when the data is transmitted or sent to, viewed, accessed or otherwise processed in, a different country. European Union data protection law restricts, in particular, personal data transfers to countries outside of the European Economic Area (EEA – this is the European Union plus Norway, Liechtenstein and Iceland), to ensure that the level of data protection afforded to individuals is not compromised (as the laws of such countries may not provide the same level of protection for personal data as within the EEA).
(ii) To ensure that data protection is not compromised when personal data is transferred to another country, Pharmaron assesses the risks of any transfer of personal data outside of the UK (taking into account the principles in this policy, as well as the restrictions on transfers outside the EEA) and puts in place additional appropriate safeguards where required.
(iii) Pharmaron has in its notices and documentation highlighted the disclosure of personal data to its parent and sister companies in China and USA. These Group companies have adequate data security measures for personal data and in the view of the Management such disclosures form part of the legitimate operation of the Company. Disclosure to these companies should be dealt with on the basis it is an internal company disclosure but with due consideration to the security of the method of transfer.
(iv) What you need to do:
(a) Outside of the Pharmaron Group, if you are required to transfer individuals’ personal data outside of the UK or EEA in the course of your employment, adequate safeguards will need to be in place. Where these overseas transfers are a normal part of your role and job duties, Pharmaron’s current safeguards are likely to provide the required levels of data protection.
(b) However, if you are transferring personal data overseas in alternative circumstances (e.g. for new types of processing activities which haven’t previously formed part of your job scope and activities, or to countries with which you haven’t previously dealt) you should contact Stephen Lewinton via firstname.lastname@example.org for further guidance before going ahead with the transfer.
8.12 Report any data protection breaches without delay
(i) Pharmaron takes any data protection breaches very seriously. These can include lost or mislaid equipment or data, use of inaccurate or excessive data, failure to address an individual’s rights, accidental sending of data to the wrong person, unauthorised access to, use of or disclosure of data, deliberate attacks on Pharmaron’s systems or theft of records, and any equivalent breaches by Pharmaron’s service providers.
(ii) Where there has been a breach of security leading to the accidental or unlawful destruction, loss, alteration, unauthorised disclosure of or access to individuals’ personal data, Pharmaron will take immediate steps to identify, assess and address it, including containing the risks, remedying the breach, and notifying appropriate parties (see below). Pharmaron has a Breach Management Procedure which sets outs its procedures for identifying, assessing and addressing security breaches.
(iii) If Pharmaron discovers that there has been a personal data security breach that poses a risk to the rights and freedoms of individuals, we will report it to the ICO within 72 hours of discovery.
(iv) We also keep an internal record of all personal data breaches regardless of their effect and whether or not we report them to the ICO.
(v) If a personal data breach is likely to result in a high risk to the rights and freedoms of individuals, we will tell affected individuals that there has been a breach and provide them with information about its likely consequences and the mitigation measures we have taken.
(vi) What you need to do:
(a) If you become aware of any breach (or suspected breach) of this policy (including, in particular any security breach), you must report it to Stephen Lewinton immediately via email@example.com to ensure that the breach is effectively assessed and addressed, and that we comply with Pharmaron’s data breach reporting obligations.
8.13 Do not use profiling or automated decision-making unless you are authorised to do so
(i) Profiling, or automated decision-making, occurs where an individual’s personal data is processed and evaluated by automated means resulting in an important decision being taken in relation to that individual. This poses particular risks for individuals where a decision is based solely on that profiling or other automated processing.
(ii) One example of solely automated decision-making would be using an online psychometric test to automatically reject job applicants who do not meet a minimum pass mark (without any human oversight such as a review of the test results by a Recruiting Manager).
(iii) Data protection law prohibits decision-making based solely on profiling or other automated processing, except in very limited circumstances. In addition, where profiling or other automated decision-making is permitted, safeguards must be put in place and we must give individuals the opportunity to express their point of view and challenge the decision.
(iv) Pharmaron will not make decisions solely on profiling data or use automated decision-making in respect of personal data. If you identify this as a potential risk, an alternative approach must be followed.
8.14 Integrate data protection into operations
(i)Data protection law requires Pharmaron to build data protection considerations and security measures into all of our operations that involve the processing of personal data, particularly at the start of a new project or activity which may impact on the privacy of individuals. This involves taking into account various factors including:
(a) the risks (and their likelihood and severity) posed by the processing for the rights and freedoms of individuals,
(b) technological capabilities,
(c) the cost of implementation, and
(d) the nature, scope, context and purposes of the processing of personal data.
(ii) We also seek to assess data protection risks regularly throughout the lifecycle of any project or activity which involves the use of personal data.
(iii) What you need to do:
(a) If you are involved in the design or implementation of a new project or activity that involves processing personal data, you must give due consideration to all the principles of data protection set out in this policy.
(b) You should assist Stephen Lewinton with regular reviews of projects or activities to ensure data protection risks continue to be addressed
(c) A useful tool for assessing data protection and privacy considerations is a Data Protection Impact Assessment or ‘DPIA’. A DPIA will consider the necessity and proportionality of a processing operation and assess the risks to individuals and the measures that can be put in place to mitigate those risks. A DPIA must be carried out if a data processing operation is likely to give rise to a high risk to individual rights and freedoms.
(d) If you are involved in the design or implementation of a new project that involves processing personal data, you must check whether it is necessary to conduct a DPIA or similar risk or compliance assessment by contacting Stephen Lewinton via firstname.lastname@example.org. He will also be able to advise you on how we expect you to conduct, or otherwise contribute to, a DPIA or similar risk assessment.
8.15 Individual Rights and Requests
(i) Under data protection law, individuals have certain rights when it comes to how we handle their personal data. For example, an individual has the following rights:
(a) The right to make a ‘subject access request’. This entitles an individual to receive a copy of the personal data we hold about them, together with information about how and why we process it and other rights which they have (as outlined below). This enables them, for example, to check we are lawfully processing their data and to correct any inaccuracies.
(b) The right to request that we correct incomplete or inaccurate personal data that we hold about them.
(c) The right to withdraw any consent which they have given.
(d) The right to request that we delete or remove personal data that we hold about them where there is no good reason for us continuing process it. Individuals also have the right to ask us to delete or remove their personal data where they have exercised their right to object to processing (see below).
(e) The right to object to our processing of their personal data for direct marketing purposes, or where we are relying on our legitimate interest (or those of a third party), where we cannot show a compelling reason to continue the processing.
(f) The right to request that we restrict our processing of their personal data. This enables individuals to ask us to suspend the processing of personal data about them, for example if they want us to establish its accuracy or the reason for processing it.
(g) The right to request that we transfer to them or another party, in a structured format, their personal data which they have provided to us (also known as the right to ‘data portability’). The applicability of this right depends on the legal grounds on which we process it.
(h) The right to challenge a decision based solely on profiling/automated processing, to obtain human intervention, and to express their point of view.
(ii) We are required to comply with these rights without undue delay and, in respect of certain rights, within a one-month timeframe.
(iii) Individuals also have rights to complain to the ICO about, and to take action in court to enforce their rights and seek compensation for damage suffered from, any breaches.
(iv) What you need to do:
(a) If you receive a request from an individual seeking to exercise a right in relation to their personal data, or making an enquiry or complaint about our use of their personal data, you must forward the request, enquiry or complaint to Stephen Lewinton via email@example.com immediately so that it can be dealt with appropriately and within the applicable time limit and in accordance with Pharmaron’s individual personal data rights procedures. Your assistance may be needed to address and respond to the request, enquiry, or complaint.
8.16 Record Keeping
(i) In order to comply, and demonstrate our compliance, with data protection law, Pharmaron keeps various records of our data processing activities. These include a Record of Processing which must contain, as a minimum: the purposes of processing; categories of data subjects and personal data; categories of recipients of disclosures of data; information about international data transfers; envisaged retention periods; general descriptions of security measures applied; and certain additional details for special category data.
(ii) What you need to do:
(a) You must also comply with our applicable processes/guidelines and any specific instructions you are given concerning the keeping of records about our processing of personal data.
(b) If you are processing individuals’ personal data in the course of your employment and you collect any new types of personal data or undertake any new types of processing activities, either through the introduction of new systems or technology or by amending existing ones, please inform Stephen Lewinton via firstname.lastname@example.org so that we are able to keep our records up-to-date.
9.1 We require all employees to undergo some basic training to enable them to comply with data protection law and this policy. Additional training may be required for specific roles and activities involving the use of personal data.
9.2 To this end, we provide training as part of our induction process for new joiners to Pharmaron and operate an ongoing training programme to make sure that employees’ knowledge and understanding of what is necessary for compliance in the context of their role is up to date. Attendance at such training is mandatory and will be recorded.
Departures from this Policy
10.1 There are some very limited exemptions from data protection law, which may permit departure from aspects of this policy in certain circumstances.
10.2 You will be given specific instructions if any exemptions are relevant to your role.
10.3 If you think you should be able to depart from this policy in any circumstances, you must contact Stephen Lewinton via email@example.com before taking any action.