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Welcome to The Strengths Empowered Entrepreneur!
A complimentary session discussing a particular pain point you're having in your business - I'll provide you with laser coaching and 1-3 action steps to move forward in your business.
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To be certified as a PADI Advanced Open Water Diver, you have to complete five PADI Adveture Dives. Two of which are compulsory- PADI Deep Adventure Dive and PADI Underwater Navigation Adventure Dive. You have the option to choose the other three from the following list to make up a total of five adventures. You also have to complete the Knowledge Review in the manual for each of the adventure.
▪	Each of the adventure dive can be credited towards the correspondent PADI Specialty Course. For example, PADI Deep Diver Specialty requires four dives. If you have done the PADI Deep Adventure Dive (maximum depth 30 meters), you can go on and complete the PADI Deep Diver Specialty (maximum depth 40 meters) with only three additional dives.
If you would like to enjoy your course with your friends and family onboard a chartered boat, we are more than happy to arrange that for you. We can offer multiple choices of speedboats and yachts.
If you'd like to do the course from your own boat or simply want to fun dive, our instructor will jump onboard with you along with our equipment if needed. Talk to us and we will arrange an unforgettable experience for you.
When can I start my PADI Advanced Open Water Diver course?
As soon as you have completed your PADI Open Water Diver course.
I'm a certified Scuba Diver and would like an upgrade to Open Water Diver?
No Problem. All you need to do is to participate in the last two days of the Open Water Diver course and bring 4 passport photos.
How will I get to iDivecenter?
We are located in Phuket Boat Lagoon by the quay, about 15-20 min drive from the airport and Patong.
What material do I need for my course?
You will be able to download the required material as soon as you sign up for the course and getting the confirmation email from us.
A passport photo, swim suit, towel, sun screen and scuba gear if you already own it.
How long does the PADI Advanced Open Water Diver course take?
Depending on the option you go for, usually minimum of 2 days.
How many open water training dives are included in my course?
How deep will I dive during my course?
Maximum 30 meters / 100 feet.
Just click on the contact us button below the option you wish to choose.
As described under each packages.


The small village of Strathyre (from the Gaelic "sheltered valley"), lies at the head of Loch Lubnaig ("Crooked Loch") sheltered by Ben Ledi, Ben Vane and Ben Shian ("Mountain of the Fairies"), just 10 miles from the historic town of Callander. This S shaped glen was chiselled out of the land by the brute force of a glacier during the Ice Age. Beautiful scenery and extensive forests cover the hills on each side of the valley attracting walkers, cyclists all year round and fell runners annually, with the Strathyre Stuc a 'Chroin hill race every May. Highland games are held every July at Lochearnhead. This area is steeped in Scottish history and many stories abound especially of local legend Rob Roy MacGregor whose grave is in the Kirkyard at Balquhidder.
Strathyre village (local shop, playground and pub providing food) is a short 5-10 minute walk away.
From Callander, take the A84 towards Crianlarich, for 10 miles. The cottage is located to the north of Strathyre on the right hand side of the road.
Ordnance Survey Reference NN 564179. For satnav, use the postocde FK18 8ND.
Walks from the door include woodland strolls from the back of the cottage linking with the Rob Roy Way, and along the River Balvaig to the front. More challenging nearby hills include the Munros of Ben Vorlich, Ben More and Stuc a 'Chroin. Sustrans Cycle Route 7 passes nearby.. There are many local walks, permit fishing on the River Balvaig and surrounding lochs, watersports at nearby Lochearnhead, and boat trips on Loch Katrine. Nearby Callander has numerous shops (Tesco & Co-op) and cafés, a swimming pool at the McLaren Leisure Centre and golf course. Other attractions include the Loch Venachar Harbour Café and Fishing facilities, Go Ape and the David Marshall Centre at Aberfoyle, Blairdrummond Safari Park, Briarlands Farm, and Stirling Castle. Also worth visiting is the wonderful restaurant at Monachyle Mhor Hotel (award-winning chef Tom Lewis) and closer by, the Mhor 84 Motel at Kingshouse.


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14 NEW CASES OF SWINE FLU, BALEARIC GOVERNMENT SAYS IT IS WELL PREPARED
By Humphrey Carter
THE Balearic government last night confirmed 14 new cases of swine flu in the region as the National Police, in cooperation with the Balearic health service, continued gathering information about the Nigerian woman who died from swine flu on Thursday and is rumoured to have been working in Calvia but lived in Palma.
The 33-year-old Nigerian, who claimed she was on holiday on the island, died at Palma's Son Llatzer Hospital after having been taken ill four days earlier while staying with friends in Majorca.
Tests analysed by Palma's Son Dureta Hospital have shown that she was carrying the AH1N1 flu virus but a second round of tests are being taken in Madrid to discover if the young woman had been suffering from any other illnesses.
However, the initial results of the autopsy carried out yesterday morning indicated that she did die from swine flu.
According to the Spanish Minister for Health, Trinidad Jimenez, because neither doctors here nor in Madrid have the Nigerian's medical history, until the results of the second tests are received, the exact cause of death can not be confirmed 100 percent. The total number of people to have died from swine flu in Spain now stands at four.
A 71-year-old man also died on Thursday in Madrid.
Yesterday, Balearic government spokeswoman, Joana Barcelo, said that the Balearics is "totally prepared" to handle any kind of health scare and stressed that the region is one of the "safest" holiday destinations in the world. "We have a very good health service, we're a safe place and completely ready to confront this virus," she underlined.
She said that all of the region's medical centres are on "full alert" and that all of the region's medical personnel know what the procedure is in the event of a case of swine flu. Barcelo admitted that it is going to be hard to convince the public to remain calm but she said that the local government and health service are going to keep the general public fully informed of all developments related to the spread of the swine flu virus.

redpajama_set_name: RedPajamaCommonCrawl


Wouldn't it be nicer if switches adopted to the theme color?
In all these other elements, only the switches are using a permanent green color instead of the theme (forum color).
ardacebi Not sure whether this was intended by Toby or not, but from personal experience I can only say that dynamic color values can become very tricky when it comes to things like (automatically) finding a hover color etc.
This might become problematic if the primary color was white, or close enough to it, and the position of the switch could not be detected.
Green means it's On/Enabled. Sounds about right to me.
Digital It's like the switches on the iPhone; green means on and red means off. Just like the characters O and I. I agree with the above.
Green is ok and accesible.
Never actually thought about that, but I can see why they haven't considered or implemented it. Most users know what green means and how to react to it. Might get a little confusing if the primary color is red, as it is commonly associated with something being turned off.
Its all about the Custom CSS.
Possibly allow it to be controlled by the Highlight color?


text:
Joint effort in Southern region described prerequisite to reduce non-communicable diseases
Mr. Gebreselasie Gebremariam, head of non-communicable diseases at the Health Ministry's branch in the Southern region, said that exerting joint effort by health institutions in the region are a prerequisite to the reduction of non-communicable diseases.
Mendefera, 13 March 2015 – Mr. Gebreselasie Gebremariam, head of non-communicable diseases at the Health Ministry's branch in the Southern region, said that exerting joint effort by health institutions in the region are a prerequisite to the reduction of non-communicable diseases. He made the remarks at an assessment meeting in Mendefera city with health personnel, during which he explained that mortality rate resulting from the diseases has shown decline. Still, new infections are on the rise there, a task that requires due attention.
He went on to indicate that health institutions are working on priority basis in the case of Diabetes, blood pressure, Asthma, cardiac and respiratory diseases, in addition to ophthalmic diseases.
Also speaking at the meeting, Mr. Alem Zekarias, head of National Blindness Prevention and Control, disclosed that successful eye surgery has been carried out twice on inhabitants of the region last year, and that studies have been made to prevent eye diseases.
Mr. Yemane Haile, head of the Health Ministry's branch in the region, emphasized on his part the need for enhanced public awareness pertaining to combating the aforementioned diseases.
Eritrean nationals residing in London donate sports equipments
Call made for exerting joint endeavors to raise all-round female participation


text:
Matthew Leonard
Next Level Catholic Academy
I've been speaking about the Catholic faith for more than a decade…and I love it! There's nothing like seeing someone's jaw drop when they finally understand the mind-blowing opportunities God lays before us, or watching tears running down the cheeks of a person overwhelmed by His love. The same things still happen to me, even when I'm the speaker!
I'm honored to be considered for any event. But while I've given hundreds of talks to thousands of people, I've been on the other side of the equation, too.
I know arranging speakers for an event is no easy task. So to make things easier, allow me to fill in a little of my background so you or your committee can make a good decision. But please don't just take my word for any of the following. Read the endorsements to the right from people who've hired me, or just listened to me as an audience member.
I've been speaking and writing about the Catholic faith for more than a decade and am the Founder of Next Level Catholic Academy, an online membership community designed to instruct, inspire, and ignite a fire of love for God.
I've published several books and have more in the works. For more than a decade I served as the executive director and executive producer at the St. Paul Center for Biblical Theology and was a vice president at Ave Maria College before that. A former radio host, I now blog and host a popular podcast show titled, "The Art of Catholic".
In addition to my own show, I've been on CBS, Relevant Radio, Redeemer Radio, Immaculate Heart Radio, Guadalupe Radio, EWTN, and Shalom Media, to name a few. Additionally, I've published a number of articles, two books, and am a featured by Lighthouse Catholic Media and have appeared in the Magnificat.
I'm a professional. Every time I step up to a microphone I'm fully aware of the responsibility God has put in front of me. I know my material and deliver it to the very best of my ability. I believe that content plus presentation equals transformation. So I strive to create dynamic talks that inspire people to seek God above anything else.
Professionalism doesn't only happen on stage, of course. I'm also very prompt with regard to any necessary communications or materials leading up the event. I'm not a high maintenance guy, and want to make it as easy possible for all involved. I'll be where I'm supposed to be on time, will gladly sign every book put in front of me, and really enjoy mingling with the crowd.
Are My Talks Highfalutin?
I speak for regular Catholics. While I'm often seen sporting a bow tie (which I think are cool), I'm not an academic. Yes, I have a master's degree in theology (with Highest Honors) from Franciscan University, but all of my talks are geared for Joe and Judy Catholic – those people sitting in the pew next to you at Mass. Over the years I've become very adept at taking "deeper" topics and making them accessible and inspiring for all Catholics.
"I'm not exaggerating. Not since Fulton Sheen have I heard a speaker so effective at motivating ordinary Catholics to step up their prayer lives and take their faith more seriously." Mike Aquilina – EWTN Personality & author of more than 40 books
I'm also a fun-loving guy and tend to use a lot of humor. The Catholic life is a joy, so even when discussing serious topics I like to keep people chuckling (or flat out slapping their knees).
At What Types of Events Do I Speak?
I get around a fair bit, speaking all over North America, and sometimes places where an ocean must be crossed. While I often speak for retreats or parish missions, I regularly address conference audiences of more than 1,000 people.
Over the years, I've done a lot of men's conferences, women's conferences, family events, young adult gatherings, and everything in-between. (Not sure what else is in-between, but I've done it.) As long as your event is for humans, I can do it.
I'm often asked to give more than one talk at an event, which is fine by me. In fact, it's not unusual for me to give three talks for a one-day event when I'm the only speaker.
My wheelhouse is prayer, the interior life, and all other aspects of Catholic spirituality. My heroes include Teresa of Avila, John of the Cross, Fr. Garrigou-Lagrange, and Fr. Jean Pierre de Cassaude…along with a host of other spiritual greats. (I named my first son after St. John Paul II, though we call him Jack so as to not confuse anyone.)
My driving passion is to ignite a fire within people's hearts for holiness. And I don't just talk about prayer and spirituality, I teach how to do them – how to go deeper. I'm very practical.
I also have a deep background in Sacred Scripture. In fact, I'm the host of the Journey Through Scripture video Bible study series, a program from the St. Paul Center. I'm a firm believer, along with Pope Benedict XVI, that Scripture is the "soul of theology." I mix a lot of the Bible into my talks.
My Most Requested Talks
Below are a list of some of my most requested keynote presentations, which can be combined when multiple talks are requested. I've written my talks so that they easily build off of one another when I'm giving multiple talks at one event. I have other talks in addition to what you see below.
My Conversion Story – How does a Protestant pastor's kid and former missionary to Latin America preaching to Catholics end up Catholic himself? Matthew describes his road into the arms of Mother Church, including many of the issues he had to deal with. It's a journey filled with study, a few tears, and some big laughs.
Pray Like a Saint: Wisdom For Growing Closer to God – According to Scripture, every one of us is called to "be perfect" and to "pray without ceasing." Prayer is the path to God and we've been doing it all our lives. But are we really praying? Are we really progressing toward holiness, perfection, and a deep relationship with God? In this talk we'll define and discuss the three traditional stages of prayer as taught by spiritual greats like St. John of the Cross, St. Teresa of Avila, and St. Francis de Sales. We won't just talk theory, but lay out the practical steps to achieve union with God through deep prayer even in the midst of this busy, distracting world. Because if you're not praying, you're not living.
Spiritual GPS: The 3 Stages of the Spiritual Life – Many spiritual writers refer to the "science of sainthood." It's the defined process by which we achieve union with God, our ultimate destiny – a mode of life beyond what anyone can imagine.
This talk explains the three traditional stages of Catholic spiritual life
as taught by spiritual greats like St. Teresa of Avila, St. John of the Cross, St. Thomas Aquinas, and so many others. I also explain how to achieve a life of true peace and happiness in the craziness of this world as you move through the stages of the spiritual journey. This is what life is all about – now and forever!
Love Hurts: The Truth Behind Redemptive Suffering – Unfortunately, no one can escape suffering. But don't be discouraged! Christ proclaims a new idea of love that gives meaning to human suffering, penance, and ultimately, death. In fact, there's a powerful secret that unlocks how we can "rejoice in the Lord always" just like St. Paul, no matter what happens! After all, there is absolutely no reason Catholics shouldn't be the most joyful people on earth regardless of earthly circumstances.
Our Beautiful End: Exploring the Timeless Mystery of Heaven – It doesn't do any good to tell people they must die to themselves to be good Catholics if we don't also tell them what they're dying for, namely, a heaven that is beyond our wildest imaginations. True, Scripture tells us straight up that we can't know, or even imagine the depth of the joy and pleasure of eternity spent with God. That being said, divine revelation and human experience do provide us with some clues that can help motivate us to achieve the Beatific Vision. We'll discuss the nature and role of beauty in this life, particularly how it sheds light on the nature of God and assists us in achieving our glorious, beautiful end.
No Regrets: The Art of Living as a Catholic – "If only I'd done this!" "If only I'd done that!" These are not statements we want to make at the end of our lives, especially when we face our Maker. But in a world that presents us with an almost infinite number of options, what are the things that make up a "Catholic" life? What makes us different? How are we supposed to live? This talk provides the answers. While our paths can certainly go in any number of directions, God provides foundations upon which we can build and enjoy a full, purposeful, adventurous life that is both satisfying now and prepares us for eternity. There's no reason to settle for less and every reason to perfect our "art of living."
It is embarrassing to say that an old dog needs to learn new tricks. After 40 years in the priesthood, I finally understand such concepts as the "purgative, illuminative and unitive ways" and the concept of abandonment to the will of God. I heard Matt Leonard explain them in a way that even I can understand. Matt is possibly the finest speaker on the spiritual life out there these days. His clarity and depth are a blessing." Fr. Rich Simon, pastor St.Lambert's Skokie and Host of Relevant Radio's "Fr. Simon Says"
"If I have to choose between laughing or crying my way to holiness, I'll choose laughter, and I'll listen hard when Matt speaks. So will your friends, parishioners, and family members, no matter how alienated they might feel from the Church. Bring them home when Matt's speaking." Michael
Bridgeville, PA
"Run, don't walk, to listen to Matt Leonard speak. His message is a storehouse of treasure from the Catholic Faith. A message you can live, now!" Mark Lasseigne
"Matthew Leonard's style and content electrify his audiences and leaves them with a passion for the truth." Dr. Taylor Marshall
President - New St. Thomas Institute, Dallas, TX
"Matt Leonard is dynamic, entertaining, and able to articulate Christian truth in a way that keeps you interested and builds up your faith. The fact that he held our attention for 8 hours is the proof!" Deacon Mike Martin - RCIA Director
St. Mary Catholic Church, Chelsea, MI
"I have only one word: AWESOME!" Pin Pin
"Because of you I've got the fire of the Holy Spirit!" Bo Mi Jang
"Mathew is a joy to work with! He gave an excellent talk that was filled with wisdom and humor. Well done!""Mathew is a joy to work with! He gave an excellent talk that was filled with wisdom and humor. Well done!" Christine Dinovo
Director - Rochester Women's Conference, New York
"Matt has the keen ability to present deep theological truths in a convincing, profound, and engaging way. While most presenters sacrifice depth at the altar of entertainment or humor at the altar of orthodoxy, Matt manages to preserve both – he made me laugh and contemplate in the same presentation." Joan Watson - Director of Adult Formation
Diocese of Nashville, TN
"Really funny and very well-rounded, I highly recommend Matt to speak to any kind of group!" Danny Abramowicz
Former All-Pro NFL great & host of EWTN's "Crossing the Goal"
"I'm not exaggerating. Not since Fulton Sheen have I heard a speaker so effective at motivating ordinary Catholics to step up their prayer lives and take their faith more seriously." Mike Aquilina
EWTN Personality and author of more than 40 books
"When Matt Leonard talks, I'm all ears because he's all heart. If there's one thing I know it's rock 'n' roll, and this guy knows how to rock a bunch of Catholics. His words change hearts." Dion Dimucci - Rock-n-Roll Hall of Famer
I am an author, speaker, podcaster, Vice President and Executive Producer at the St. Paul Center for Biblical Theology. I'm married to a beautiful woman named Veronica with whom I have six children (so far…she's 10 years younger so you never know).
©2020 Matthew Leonard. Powered by the Get Noticed! Theme.


Sold October 24, 2018. See homes currently on the market in Beverly, MA.
When you are here, at home, it will be hard to tell you are in the center of all the activity of North Beverly. Fantastic neighborhood on a restful side street near Beverly Golf and Tennis Club, the Cummings Center and Route 128 nearby.
Sold November 27, 2018 for $1,055,000. See homes currently on the market in Boxford, MA.
Well designed single level home connects perfectly with the 1.6 acre lot.
Common rooms line the back of the house, enjoy morning sun, and wrap around the striking, generously sized brick patio with stone walls. The patio has plenty of room for both dining and seating areas. The landscaping is beautiful, neat and restful, anchored by two fabulous Metasequoia's.
Single level home on a private and fenced .29 acre lot in a great Hamilton neighborhood.
The living room with wood burning fireplace has glass doors that look out to the beautiful yard. There are three bedrooms and the master bedroom has a private half bath.
"Park Street" – Fully renovated in 2002 and 2007, this craftsman colonial offers present day amenities with a perfect blend of old and new, on a corner lot in highly desirable in-town location. Capacious and nicely finished 3,000 square feet, with nine rooms, four bedrooms, and three and a half baths.
Before the Beach" circa 1947 cape style home located on a narrow sleepy side street, before Good Harbor Beach and between Bass Rocks and East Gloucester.
See the video for 20 High Rock Terrace Gloucester, MA.
Sold October 23, 2018. See homes currently on the market in Hamilton & Wenham, MA.
Tranquil setting near Beck Pond in Hamilton, Massachusetts.
Cool…very cool, best describes this Shed style home, an innovation from the postmodern architecture period popular in the 1960's and 70's.
This home with multiple "shed" roofs and it's line of clerestory windows was built in 1976 with attention to the visual as well as lifestyle. There's a great balance of open and private space that's often favored today.
Bounded by old stone walls, "The Lee House" traces its history back nearly 400 years when Essex was known as Chebacco Parish. First built in early 18th century, completely rebuilt in 1960, and more recently remodeled and updated in 2010 this home enjoys the esthetic of an older home.


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Olivia Barnardsubscriber
Summer recipes: Jambalaya or Ceebujen? Gumbo or Gombo?
May 22, 2017 • Food
As the temperatures rise, the humidity takes over, and adolescents are no longer in class, things get cookin' in New Orleans. We want to help you add to that heat with a little history, a little spice, and some recipes for the summer season. Some dishes will singe the taste buds while others will freshen up your life. First up, let's go back to some root dishes. Jambalaya or Ceebujen? Gumbo or Gombo? We may know one more than the other, but these dishes are linked even though their geography and language have waters between them.
It's not just the physical rice that New Orleans received from Senegal. The actual rice dishes created in Senegalese society are very similar to modern New Orleans rice dishes. Modern day Senegal's national dish, ceebujën (also spelt thieboudienne) consists of rice and fish. Chiep, the Wolof (the predominant language spoken in Senegal) word for rice and jën, the Wolof word for fish, are combined in the name of this meal. The fish is usually stuffed with a mixture of spices and herbs including parsley, peppers, and garlic. In addition to rice and fish, the meal always includes vegetables, ranging from carrots and potatoes to eggplant.
This meal is usually served at lunchtime and it is not uncommon to have a varying form of this national dish at lunch every day of the week in Senegal. This meal has also evolved into different forms of Senegalese jambalaya, consisting of rice and seafood and vegetables, very similar to jambalaya found in New Orleans. In New Orleans, rice is used most notably in meals such as red beans and rice, jambalaya, and even added on a side or in addition to seafood gumbo.
The word gumbo, although not entirely rice-related, actually originates from the Wolof word gombo, meaning okra. The Senegambian gombo was already integrated into a Senegalese dish also called gombo, and although it tastes different from the gumbo found in New Orleans due to the presence of different oils and spices, both rely on a key ingredient– the okra vegetable.
As we look to the approaching 300th year anniversary of France's founding of New Orleans in May 2018, we should also look to the founders of this city that are not always included in history books, like the Senegambian slaves that made growing rice possible in New Orleans and helped spread this knowledge all over the South.
Perhaps the next time we eat jambalaya or gumbo, though, we can think about this great contribution to New Orleans culture and spread the word to whoever is sharing a meal with us.
Want to see it for yourself?
To hear from a renowned Senegalese chef currently living in New York City about the connections between Senegal and New Orleans cuisine, visit his website here.
For a Senegalese thieboudienne recipe, click here.
For a Senegalese-inspired gumbo recipe, click here.
To hear a historian and New Orleans chefs discuss this topic, watch this video.
Have an Instagram? Check out this account that features African dishes, including so many from Senegal. The account's handle, LekkRek, means "eat only" in the Senegalese language Wolof, lekk meaning "eat" and rek meaning "only."
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Footprints: An interactive public art map Kelley Crawford, Steven Melendez, and Emma Fick worked together to create a custom interactive public art map for New Orleans. This project was made possible through a grant provided by EPNO (Emerging Philanthropists of New Orleans)! Take a walk and click away! Artists in their own words: Christine Bunuan "We are a family while we're on the road. We eat together, we have outings together, and we support each other. And then, we get to be on stage together to perform this incredible play." Kelley Crawford talks with actress Christine Bunuan about her role as Gigi in Miss Saigon. Profile: Sandra O'Neal "The last decade marked the fiftieth anniversary of countless moments in the New Orleans civil rights movement. In 2010, we remembered the four African-American students who integrated the New Orleans public schools. That same year, non-violent activists were arrested at a sit-in at the Woolworth's lunch counter on Canal Street. Ten years later, New Orleanians of color were still fighting for basic forms of equality, many in unseen ways. Dr. Sandra O'Neal was one of those people." Reporter Sarah Holtz talks with Dr. O'Neal.
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Q: Define route without ending slash when importing route in Symfony 2.5? In file: HardCoreMore/HRAPIBundle/Resources/config/routing.yml
I have imported route like this:
hr_api_company:
resource: "@HRAPIBundle/Resources/config/routing/company.yml"
prefix: /company

And in file: HardCoreMore/HRAPIBundle/Resources/config/routing/company.yml
I have defined route for creating company like this:
hardcoremore_hr_api_company_create:
pattern: /
defaults: { _controller: HRAPIBundle:Company:create }
methods:  [POST]

Now the route is matched with following url:
POST company/
but it is not matched when I called it with:
POST company
How can I define route without ending slash when importing route and prefixing it?

A: this is not possible, see : https://github.com/symfony/symfony/issues/4322
I hope this has helped

redpajama_set_name: RedPajamaStackExchange


This annotation must be specified for persistent fields or properties of type java.util.Date and java.util.Calendar. It may only be specified for fields or properties of these types.
The Temporal annotation may be used in conjunction with the Basic annotation, the Id annotation, or the ElementCollection annotation (when the element collection value is of such a temporal type.
Learn how to define and use date and time fields in Chapter 2 of the ObjectDB/JPA manual.
The type used in mapping java.util.Date or java.util.Calendar.


Ideally located on the Costa del Sol, offers eighteen fully furnished, self-catering private apartments at unbeatable prices.
Perfect for families and golfers this delightful apartments comes complete with sunbathing area all set in attractive tropical gardens. And with over 300 hundred days of sunshine a year, you can be sure of great weather.


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If you're looking for a handsome U.S. series with lower coin values and relatively easy availability, then Franklin half dollars may be for you. This series, which was designed by John R. Sinnock and ran from 1948 through 1963, is an affordable set of coins to pursue and includes just 35 regular-issue pieces (that doesn't count the proof coins or any special varieties). Franklin half dollars feature a bust of the namesake inventor and Founding Father on the obverse and the cracked Liberty Bell on the reverse.
Coin values for the Franklin half dollar series are roughly tied to bullion values, at least in the case of the heavily circulated specimens. Uncirculated specimens of most issues are largely common, save for a few issues, including the 1949-S and 1952-S. Franklin half dollars grading MS 65 and all uncirculated specimens showing fully distinguished bell lines (the horizontal bands on the upper portion of the bell) are especially prized and valuable.
Coin values are significantly spread out for some Franklin half dollars. Perhaps this is most notable in the case of the 1953-S; this is a relatively common piece worth about $10 in XF-40, but soars in value to more than $16,000 for an MS-65 specimen with full bell lines (FBL). For the most part though, even high-end Franklin half dollars are very affordable. The lowest-mintage Franklin half – the 1955 – costs less than $20 for an XF-40 specimen; values for this coin range from about $25 to $100 for a nice uncirculated example. Coin values for well-worn Franklin halves are very low, and often are listed just $2 to $3 above the spot price of silver. So, assembling a circulated set of Franklin half dollars is within the reach of most coin collectors and investors.
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1948 Franklin Half Dollar
Streber
To My Young Brothers & Sisters at Reddit & Elsewhere
Are you concerned the precious metals train has left the station without you?
Bullion Shark LLC
How To Collect Pre-1933 Gold Coins


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redpajama_set_name: RedPajamaGithub


Browse for Kaitlyn Maher O Onlymaher song lyrics by entered search phrase. Choose one of the browsed Kaitlyn Maher O Onlymaher lyrics, get the lyrics and watch the video. There are lyrics related to Kaitlyn Maher O Onlymaher.


The LycaHealth tendinopathy clinic in Canary Wharf, East London and Orpington, Kent treats tendon injuries including tendonitis (inflammation of the tendon) and tendinosis (microtears in and around tendon).
Tendinopathy is more common in those who do sports and who do other repetitive physical movements or activities.
Our physiotherapy-led tendinopathy clinic means you'll be in expert hands – we have some of the UK's very best physiotherapists on site at LycaHealth who will assess your injury. With tendinopathy it is often necessary to use MRI, X-ray or Ultrasound to accurately diagnose the injury. Luckily, we have state of the art diagnostic imaging equipment; our 3.0T MRI scanner is twice as powerful as most MRI scanners, which is more likely to spot issues. Once you've been diagnosed, you'll be referred to the appropriate specialist for treatment and a carefully tailored recovery and aftercare plan.
Treatment for tendinopathy can include physiotherapy, joint injections, orthotics and also Extracorporeal Shock Wave Therapy (ESWT) and effective treatment for pain relief and helps to restore mobility.
Why go private for tendinopathy treatment?


Despite best intentions to take last year off exclusively for writing books, I found that the small amount of private tutoring work I took on to help 'make ends meet' while I wasn't earning commercially blossomed considerably. I should have known better, it's not the first time this has happened to me. Anyway, among my many students, I gained quite a few taking English Literature at GCSE and A level stages.
While this is no problem for me, I felt I should perhaps brush up on a few things and purchased Jonathan Culler's guide to remind me of subject areas I'd not necessarily studied since university days (which are, alas, dim and distant memories for me).
The first thing I did was head to the appendix and read up on all the theoretical schools and movements. It turned out to be the best chapter of the book and two of my three stars are awarded for that section alone. I even learned a few new things such as ecological readings and what it means to be 'post-human' which were somewhat alien concepts back in the 90s! The appendix is genuinely useful – unlike much of the rest of the book.
The opening chapters are reasonably useful and interesting too and Culler has things to say which are helpful to the student and teacher. The whole argument for 'why theory' and the basis for judging 'what is literature' were interesting areas and good for giving focus to the task of figuring out what to say about a novel or poem and so on.
But after that both Culler's wit (which was light and intelligent) and his wisdom begin to wane. The latter chapters are heavy and over-labour the theories discussed. Some chapters – such as that on Performative language – would have been clearer and more useful summarised as a single section rather than given an entire chapter. It felt, at times, as though Culler wasn't really clear about these theories himself and, as academics are prone to do when trying to hide uncertainty, waffled philosophically, endlessly.
Perhaps I was just missing what he was trying to say? It's not impossible, for sure. But his opening statements were usually clear and comprehensible and I usually felt like I got the idea and was ready to move on; alas, the author wasn't so ready.
I feel that Culler forgot that he was writing a guide to Literary Theory, rather than an in-depth treatise, partway through the book and that's a shame. As I say, the opening chapters and the appendix are excellent. The book will sit on my shelf along with other resources I call on from time to time but I suspect I'll rarely refer to it. The student or teacher would be better off either purchasing a shorter guide for reference purposes or buying an actual text book for more meat. Culler's doesn't quite manage to be either, which is a shame – the book had great potential.
Writer and journalist D K Powell is the author of the bestselling collection of literary short stories "The Old Man on the Beach". His first book, 'Sonali' is a photo-memoir journal of life in Bangladesh and has been highly praised by the Bangladeshi diaspora worldwide. Students learning the Bengali language have also valued the English/Bengali translations on every page. Ken has two new books coming out soon – don't miss them!


LAS CRUCES, N.M. - The police chief, mayor and a trustee of the village of Columbus, N.M., were among 10 people arrested March 10 for their roles in a firearms-trafficking ring, which was the focus of an investigation by special agents from U.S. Immigration and Customs Enforcement's (ICE) Homeland Security Investigations (HSI).
A federal grand jury in New Mexico indicted 11 members of the trafficking ring on firearms and smuggling charges. The criminal enterprise was based in Columbus, a small border village across from Puerto Palomas, Chihuahua, Mexico.
The defendants charged in the 84-count indictment include Columbus Police Chief Angelo Vega, Mayor Eddie Espinoza, and Blas Gutierrez, village trustee in Columbus. Defendant Ignacio Villalobos has not been apprehended and is considered a fugitive.
The Bureau of Alcohol, Tobacco, Firearms and Explosives (ATF); the Drug Enforcement Administration (DEA); and the U.S. Attorney's Las Cruces Branch Office participated in the yearlong investigation.
Ten of the 11 defendants were arrested without incident Thursday morning by teams of federal, state and local law enforcement officers. Vega, Espinoza, Gutierrez and seven other defendants are scheduled to make their initial appearances March 11 in the federal courthouse in Las Cruces.
Defendant Ignacio Villalobos has not been apprehended and is considered a fugitive. Federal agents also executed 10 search warrants at eight residences, a business, and at the Columbus Police Department.
"Identifying and arresting individuals involved in criminal activities, especially weapons and drug trafficking, in our Homeland is a national security priority for ICE," said Manuel Oyola-Torres, special agent in charge of ICE HSI in El Paso. "ICE HSI special agents will continue working shoulder-to-shoulder with our federal, state and local law enforcement partners to stop the flow of drugs, weapons and other contraband across the U.S.-Mexico border."
This investigation has been designated as part of the Organized Crime Drug Enforcement Task Force (OCDETF) program. The principal mission of OCDETF is to identify, disrupt and dismantle the most serious drug trafficking, weapons trafficking and money laundering organizations, and those responsible for the nation's illegal drug supply.
The indictment alleges that, between January 2010 and March 2011, the defendants engaged in a conspiracy to purchase firearms for illegal export to Mexico. During this 14-month period, the defendants allegedly purchased about 200 firearms from "Chaparral Guns," a store owned and operated by defendant Ian Garland.
According to the indictment, the defendants purchased firearms favored by the Mexican Cartels, including AK-47-type pistols, weapons resembling AK-47 rifles but with shorter barrels and without rear stocks, and American Tactical 9mm pistols. The defendants allegedly obtained firearms from Chaparral Guns by falsely claiming they were the actual purchasers of the firearms, when in fact they were acting as "straw purchasers" who were buying the firearms on behalf of others.
During the investigation, law enforcement officers seized 40 AK-47-type pistols, 1,580 rounds of 7.62mm ammunition, and 30 high-capacity magazines from the defendants before they crossed into Mexico. The indictment alleges that 12 firearms previously purchased by the defendants later were found in Mexico and were traced back to these defendants. As part of the investigation, efforts were made to seize firearms from defendants to prevent them from entering into Mexico, and no weapons were knowingly permitted to cross the border.
U.S. Attorney Kenneth J. Gonzales of the District of New Mexico, said, "Gutierrez, Espinoza and Vega were duty sworn to protect and safeguard the people of Columbus, N.M. Instead, they increased the risk of harm that the people of Columbus face every day by allegedly using their official positions to facilitate and safeguard the operations of a smuggling ring that was exporting firearms to Mexico. Today's indictment reflects our unwavering resolve to ensure safety along our Southwest border, and to expose and prosecute corrupt officials who seek to profit at the expense of the citizenry they are sworn to protect."
* Eva Lucie Gutierrez, 21, of Las Cruces: conspiracy and making false statements in connection with acquisition of firearms.
John E. Murphy, U.S. Attorney for the Western District of Texas, and his El Paso Branch Office staff also assisted with the investigation. The Chihuahua State Police in Palomas, Mexico, and the Secretariat of Public Security in Ciudad Juarez, Chihuahua, Mexico, also supported the case.


Unique design cardboard wine gift boxes are custom made with glossy lamintatioin and silver staming for one bottle packaging.
Finish: silver hot foil stamping, glossy lamination.
Accessories: paper inserts, yellow satin covering, cardpaper band.
Box material: 350 gsm card stock, 157 gsm coated paper, cardboard, satin.


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The INDY has previously reported that state Representative Jimmy Dixon—who has received $115,000 in campaign contributions from the pork industry—is the chief sponsor of a controversial hog-farm-protection bill that passed its second reading in the House Thursday under strange circumstances. And if you've been following this story, you know that HB 467 would protect hog farmers from myriad legal claims, including twenty-six active lawsuits filed against Murphy-Brown LLC, the hog division of China-owned Smithfield Foods.
But of the sixty-four people who voted in favor of the measure Thursday (the vast majority of whom are Republican), Dixon is far from the only person who has been a beneficiary of Big Pork's generosity.
Bill cosponsors John Bell and David Lewis have also received money tied to people who would be helped out should HB 467 become law. Bell, the House majority leader, has received $5,000 from the N.C. Pork Council, $1,000 from Smithfield Foods, $5,000 from Dixon, and $1,850 from people with ties to Goldsboro Milling, the tenth-largest hog producer in the nation. And Lewis got $15,500 from the Pork Council, $4,750 from Murphy-Brown stakeholders, $9,500 from Prestage Farms, and $7,000 from Smithfield.
In total, Big Pork has contributed more than $272,000 to the campaigns of those who voted Thursday to protect the industry. The Pork Council, which donated at least $500 to each of these people, doesn't think the bill is such a big deal.
Should this bill make it through the House and then the Senate and heads to Roy Cooper's desk, things could get interesting. Why? Because the governor has received $21,500 from Smithfield stakeholders, too.


After last night's cold, driving rain, and a touch of the flu, I need a little reminder of summer. This was taken just after dawn on August 29th in a Wisconsin ditch near Mount Horeb a little east of Taliesin.
tilth: The physical condition of soil as related to its ease of tillage, fitness as a seedbed, and impedance to seedling emergence and root penetration.
You can tell good soil. A shovel goes into it like butter.
This is not good soil. It's on the west side of the garage, bordering the alley, and it's a problem area full of weeds. I want to plant it, but if you try to put a shovel into it, chances are you will hit a brick. Or a rock. Or a piece of broken glass. Or a rusty nail. I don't think it's impossible soil though, because it's full of earthworms and nightcrawlers, which aerate and fertilize the soil, and give it tilth.
Before anything else happens, the rocks have to come out. Last week I mowed the weeds, so now I start removing the top layer of turf and weeds.
There are too many rocks to just pick them up and put them in a pile, so I devise a system of shaking the soil through the holes of a plastic crate. The rocks are caught in the crate and I dump them in a small garbage can. When the can is full, I carry it to the newly created rock pile.
The sun gets lower and lower in the sky. The shadows creep up to where I am working. Then, it's dusk and the street lights come on.
This isn't rocket science, so I keep working in the dark.
The next day, it's ready to plant. Except for the small problem of the new rock pile.
Can you garden and blog with the same pair of hands? I don't think so. Even though I had leather gloves, my hands are scratched and infected. I'm not anywhere near done either.
Why was it again, that I left Wobegon and came to the Big City? Time for a little Sandburg.
Poem: from "The Red Son" by Carl Sandburg, in Chicago Poems.
Supposedly, in Illinois you can add one day to the growing season for every 7 miles south traveled. So if you travel south 100 miles, you should see plants that are 2 weeks ahead of your own area. Of course we have had cold rainy weather, but still, my hostas are only an inch or two out of the ground. Will they look like these in another 2 weeks? And what about the flowers?
A while back I was planning a garden in the back of the house.
Today it's finished, even if a little worse for the frost. The square thing over the sewer lid cover was an addition by the landlord. It's an old concrete post support that we dug out of the side yard a few weeks ago. He says it's to keep the kids from messing with the lid, but I think he just likes it.
UPDATE: an experiment in proportions. Of course it always look different when you actually put the shovel in the ground.
I'm sort of leaning towards the last one, a sort of trapezoid, since a tiny strip of grass by itself is hard to maintain.
One of my childhood heroes was the criminal defense attorney Clarence Darrow. Beside being a notorious agnostic (and writing an autobiography that was the first book I read in the sixth grade when I was admitted into the adult library by special dispensation, having read all the books in the children's library) he also defended Leopold and Loeb (wiki) who were convicted of murdering a child and stuffing the body in a culvert. Some time ago, when googling the Nike missile site at nearby Wolf Lake (map), where I often walk, I became aware that Wolf Lake was also where Leopold and Loeb disposed of the body in a culvert.
Yesterday I went for a long walk after transferring the new Leonard Cohen London concert album to my new mp3 player, and just for kicks decided to see if I could find this notorious culvert. Here are the clues. The location is described as being in Illinois, near 118th street, near the Pennsylvania Railroad tracks, and on the north side of Wolf Lake. Also they moved the body with a car. Looking at a map, we see only two railroad tracks on the north side of Wolf Lake, one accessible by 118th street and one by the access road that goes around the west side of the lake (not on the map). I have marked the two possible routes in red.
So now, to the park.
I have never seen this before. Why does it make me nervous?
There is still some fall color, even though most of the leaves have fallen. The sumacs are the most spectacular. I wonder if this is the same sumac the Arabs eat as a seasoning.
but when I get to the crossroads, hoping to investigate the railroad tracks nearest the Indiana border, I am met with a road closure.
I have no desire to meet up with hunters carrying guns of any kind so I climb the hill to the bike path to the west.
The book exchange is still there, but no books today, not after two weeks of rain.
Finally I reach the turnoff for 118th street.
And not wishing to run into duck hunters on the north side of the lake, I head towards the western exit.
This leads out to a supermarket and a few shops.
Here the frost has not touched anything. Roses are still blooming as I reset my mp3 player for the return trip.
Geraniums and hosta are still green here, but at my house they're yellow from the frost.
The map showed railroad tracks between the lake and 118th street, but I didn't see any. On my return trip I see what has happened. The old railroad right-of-way has been used to make the bike trail, and our infamous culvert is no where to be found.
But there's no reason I can't do a little moss gathering. I having been keeping a lookout for moss, and here I finally find it on the west facing edge of the bike trail. Alas, it's public land, so I will have to leave it undisturbed and enjoy it right where it is.
Here is what is in my windowsill at the moment: mint cuttings with roots.
UPDATE: a stop at my mint patch across the street, and the cut mint for my morning tea is now replenished.
As you can see, I have also been to the local thrift shop and found a small piece of Oaxaca pottery, the kind that looks like it was made from pencil lead, and also a blue glass bowl, probably depression glass, that looks vaguely deco.
Further research tells me Oaxaca pottery is purely decorative, and since a low temperature firing method is used to get the black color of the clay, it's too porous to hold water. It's so whimsical though, I love it.
Walking along the railroad tracks at twilight, I found a few of the plants that ordinarily have drab fall colors take on a striking appearance in that light. Unfortunately, they don't quite fit any of the vases I brought home.
I love seeing bits of the outdoors inside, but that project will have to wait for later. The sun has finally come out and the garden is dry enough to work. Time to finish transplanting, before the frost they are promising for later in the week.
There are those who say Americans don't know how to garden. Not true, although the climate here is not as temperate or favorable to some plants as countries that enjoy the warming influence of the other side of the Gulf Stream, and the typical American neighborhood doesn't look as landscaped as European ones. Someone once remarked that Europe looked "finished". American is far from being finished and someone with the itch to play with landscaping materials will find plenty to do.
Here is this week's gardening activity. It started with a problem area, the north side of an entrance.
Turning the soil proved harder than it looked. It was one huge mass of intertwined roots, with a couple of eight or ten inch concrete blocks buried a few inches down, maybe part of an old porch support.
The next problem was where to obtain free plants. Hostas start at seven bucks for the ordinary kind and go up from there. It's not my property and I don't have a budget to work with, so I'll have to be creative. Time to start another project.
Here is the back yard of where I used to live, that I still take care of in exchange for storage. Looks a bit overgrown. Maybe time to trim things and divide a few plants. Before I started in on this area, maybe three years ago, it was a poorly growing lawn. I added a border with plants that I either bought or were gifts from my mother's yard, and rejuvenated the lawn.
After it's been cleaned, I have an entire trash bag full of hosta, iris, daylily, and ornamental basil left over.
I water it thoroughly, edge the bricks with a spade, and throw some Miracle-Gro foliar feeder on it for good measure.
Then it's back across the street to install the plant divisions in the problem area, with a little peat moss mixed into the soil under each plant.
In the front, a row of shade-loving hosta, the ordinary kind with white on the outer leaves. These grow rapidly and there are always enough to divide–in a year one plant will yield two more plants. In the middle, a blue leaved hosta and a yellow leaved hosta, interspersed with impatients. The yellow ones looks identical to green hostas until you put them in the sun, then they turn yellow. Impatients grow well here, in either sun or shade, although they do a little better in the sun. In the back are irises and a jade plant, both survive in shade. The soil here is sandy–this was once the bottom of a prehistoric Lake Michigan that was much larger–and the soil drains quickly. Ideally the soil should have four inches of peat moss dug into it, or even compost, but again, I don't have a budget for this project. Instead I had a little Miracle-Gro infused peat moss left over from some other project and mixed it with the soil under each plant. Hopefully that will help it retain moisture around the root.
The real purpose of a garden like this is to get perennials established so you don't have to plant annuals every year. Realistically, gardeners die or move away, but a good established perennial bed will look good even without care. Even though it's the skeleton of perennials that make the garden, it's the flowers that people notice and comment on. I find if I include some showy flowers, nobody has much comment about the rest of what I do and I am allowed to proceed without impedance.


Re: Grades in the French Revolutionary armies.
An 'adjoint' was a captain on staff duty. 'Adjutant general' was a staff rank, equivalent to colonel, used from 1793-1800. It was then changed to 'adjutant commandant.' It also denoted that these officers were staff officers and not commanding troops. Generally speaking, they served as chiefs of staff or the head of staff sections.
If one was promoted, then he would be a general of brigade.
Grades in the French Revolutionary armies.


In 1957, Val and Zena Weiler operated the Campus Fruit Market in Lincoln, Nebraska. It was clear to them that their business would soon be eclipsed by the large supermarkets springing up across Lincoln. The landmark which had stood for a dozen years, had to go. In its place, armed with three dozen pizza pans, a recipe that had been in Mrs. Weiler's family for years, and a generous amount of trepidation, they decided to open a pizza business.They took in $60 their first day, and as the restaurant's reputation grew, patrons began to gather and watch through the window as the pizzas were made. They would stand in line for an hour or more to sample the pizza and pasta specialties created in the original restaurant.
There was just one location then and no trip to the city was complete with out stopping to eat at Valentino's!
About three years after the 1971 purchase of Valentino's, members of the Messineo and Alesio families carefully formulated plans to expand into additional locations. Through controlled expansion, and an elaborate system of quality controls, Valentino's steadily grew. In 1990, Valentino's opened its first Valentino's To-Go location, offering take out service only. These stores were an immediate success. Today there are more than 18 successful To-Go locations operating.
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GDPR Webinar Q&A
Countdown to EU Compliance: Tips to Navigate GDPR & Privacy Shield
This Question & Answer resource page is based on common questions received during our webinar Countdown to EU Compliance: Tips to Navigate GDPR & Privacy Shield.
The following answers were provided by:
Isabelle Roccia - Senior Policy Adviser at the U.S. Foreign Commercial Service
Andrew Steele - International Trade Specialist at the U.S. Department of Commerce
To the best of our knowledge, the information contained herein is accurate. However, the U.S. Department of Commerce does not take responsibility for actions companies may take based on the information provided here. You should always conduct your own due diligence and seek legal counsel before making decisions or taking actions in the regulatory, standards and commercial fields.
Q: We tokenize and encrypt data for our clients. Most of them are storing credit card numbers. We do not know what else they are storing. Would we need an EU Representative?
A: An organization under GDPR needs to appoint a representative if it has no physical presence in Europe. Article 27 (2) a. provides for an exemption for organization whose processing of personal data is (a.o.) occasional, does not include on a large-scale processing of sensitive data. This determination will have to be made separately for the organization and for its client (e.g. one may need a representative and not the other; one may actually need a DPO). See GDPR for complete language. Large-scale is not defined but examples of large-scale processing include processing of travel data of individuals using a city's public transport system, processing of customer data in the regular course of business by an insurance company or a bank.
Q: The statement was made that HR Data means an organization's own data. However I have had my initial Privacy Shield application item challenged when I did not select HR data (we process HR data on behalf of other companies). There has been inconsistency among how HR data has been viewed. Some companies in my industry have been certified via PS without selecting HR data as required; others have been required. Please discuss how HR data is applied when it is being processed on behalf of another company.
A: The Privacy Shield consideration of HR data is as follows: "Where an organization in the EU transfers personal information about its employees (past or present) collected in the context of the employment relationship, to a parent, affiliate, or unaffiliated service provider in the United States participating in the Privacy Shield, the transfer enjoys the benefits of the Privacy Shield." For more information, see, https://www.privacyshield.gov/article?id=9-Human-Resources-Data.
Q: We are a small business, < 250 employees, that provides "live chat". We do not focus on capturing personal data. For companies that do, we require a BAA as required by HIPAA. It appears our only risk area for GDPR is this type of data: "Web data such as location, IP address, cookie data and RFID tags", and the only concern is that is "not occasional". What will we be required to do?
A: The size of the company is irrelevant as GDPR does not create an exemption for SMEs <250 employees (aside from the processing record exemption) and potentially applies to companies of all sizes and sectors. For a company in scope, even if its core business is not the collection/processing of data, GDPR requirements still apply. In addition, the EU is currently reviewing its e-privacy legislation. This legislation (draft called e-privacy regulation) could apply to live chat services deemed to be electronic communication services. This legislation is not expected to be finalized until end 2018 but it is worth monitoring given the business of this company.
Q: Do you have specific examples of how to create a GDPR-compliant privacy policy that is also Privacy shield compliant?
A: There is no silver bullet, privacy policies need to be tailored to each individual organization's needs and we cannot provide legal advice. We can, however, refer you to our Resources page, which has some further information on the topic.
Q: If my organization is already an active participant listed on the Privacy Shield web site, are we considered compliant with all GDPR regulations?
A: No, Privacy Shield is a compliance program with regards to international personal data transfers. The GDPR contains numerous other requirements (regarding individuals rights, transparency, accountability, security, etc.) that are separate and for which the Privacy Shield is not a solution.
Q: I have communicated with many companies on GDPR. A large number of companies (suppliers/vendors/customers/partners) and I have been told many refuse to sign agreements associated with GDPR; especially those that might outline roles (controller/processor) that might increase their liability. How can a company who attempts this in good faith be held accountable in compliance?
A: Article 28 requires controllers to update all contractual agreements that fall under the remit of the GDPR to match this article's requirements for contractual language. This article sets a baseline of terms that should be in a contract but indeed does not exclude negotiation between business partners. Any controller or processor should refer to the language of the GDPR to ensure that the proposed language matches their requirements under GDPR.
Q: The statute does allow for the establishment of orgs that can perform "GDPR Certification" services, establish frameworks for GDPR compliance certification, etc. Are you aware of any developments there?
A: At the moment, ITA is aware of a few initiatives, in particular in the cloud computing space. These codes of conducts pre-date the GDPR but were drafted with a view to its implementation. Stakeholders anticipate more codes of conduct to be developed once the GDPR becomes applicable.
Does a US Company need to identify a DPO in every EU state/country or could one DPO be used for all of the EU states? And does the DPO need to reside in the EU?
First, a company needs to run an assessment of whether or not it actually must appoint a DPO. See DPA guidance here: http://ec.europa.eu/newsroom/document.cfm?doc_id=44100
The GDPR creates a one-stop-shop that will make it easier for companies to interact with their DPA and for DPAs to interact among themselves. Organizations will identify their lead DPA in a specific country and this DPA will be the liaison with all the other relevant DPAs. As such the company only needs one DPO (which can be one person or a team). There is no requirement for the DPO to be physically based in Europe; this a is business decision.
Q: Should a US based company retain a EU based law firm that is proficient in GDPR to guide the conext of the companies policy?
A: ITA recommends to seek legal counsel with EU privacy legislation expertise, whether based in Europe or elsewhere. Local bar associations can help identify law firms with suitable privacy practice in the U.S. For companies that wish to retain Europe-based law firms, the Commercial Service teams in embassies can assist.
Q: Is a representative in EU mandatory irrespective of size of business in EU?
A: Yes but article 27 (2) a. provides for an exemption if the processing is occasional, does not include, on a large-scale, processing of special categories of data (i.e. sensitive data). See GDPR for complete language. Large-scale is not defined but examples of large-scale processing include processing of travel data of individuals using a city's public transport system, processing of customer data in the regular course of business by an insurance company or a bank.
Q: Is DPIA required to be done by a Data Processor?
A: The DPIA is the primary responsibility of the controller, per article 35 of the GDPR. Link to the DPA guidance document on DPIA: http://ec.europa.eu/newsroom/document.cfm?doc_id=47711
Q: Is a EU representative mandatory for a Data processor who is only processing data from EU data subjects?
A: An organization under GDPR needs to appoint a representative if it has no physical presence in Europe. Article 27 (2) a. provides for an exemption for organization whose processing of personal data is (a.o.) occasional, does not include on a large-scale processing of sensitive data. This determination will have to be made separately for the organization and for it client (e.g. one may a representative and not the other; one may actually need a DPO). See GDPR for complete language. Large-scale is not defined but examples of large-scale processing include processing of travel data of individuals using a city's public transport system, processing of customer data in the regular course of business by an insurance company or a bank.
Q: Does a Data processor need to have a EU representative and a DPO?
A: The representative and the DPO are two distinct requirements. The former is largely determined by whether or not the company has a physical presence in the EU. The latter is determined by the core activities of the company.
An organization needs to appoint a representative if it has no physical presence in Europe. However Article 27 (2) a. provides for an exemption for organization whose processing of personal data is (a.o.) occasional, does not include on a large-scale processing of sensitive data. See GDPR for exact language.
The conditions of the mandatory appointment of the DPO are explained in article 37 and include large-scale processing of sensitive data. See also DPA guidance on DPO: http://ec.europa.eu/newsroom/document.cfm?doc_id=44100
(Large-scale is not defined but examples of large-scale processing include processing of travel data of individuals using a city's public transport system, processing of customer data in the regular course of business by an insurance company or a bank.)
Q: A breach involves huge penalties. So Ability to detect a breach by use of technology or via a manual process is crucial. Any tips?
A: First, the threshold for a breach is very low. Referring to the DPAs guidance is essential to know what to notify and what not. See guidance on data breach here: http://ec.europa.eu/newsroom/article29/document.cfm?doc_id=49827
An example of loss of personal data can include where a device containing a copy of a controller's customer database has been lost or stolen. A further example of loss may be where the only copy of a set of personal data has been encrypted by ransomware, or has been encrypted by the controller using a key that is no longer in its possession.
Regarding technology to be used, the GDPR mentions state-of-the-art technology but remains technology neutral. Companies can look at existing widely-accepted standards for additional guidance such as the NIST Framework or ISO 27001 but this is illustrative only as there is no official recognition by the GDPR.
Q: Most of what I see converged under GDPR seems to cover electronics communications. I'm at a B2B call center. Our lists, spreadsheets stored in a database, are either purchased or come from our clients (the norm being prospects, not business people with existing relationships). Can we call into European businesses and be compliant?
On a side note, I'M a DBA. When I first was asked to look into this, my first reply was 'ask the corporate lawyers'. In your professional option, how important is getting people involved from our company who has actual legal expertise?
A: Electronic communications are also covered by the eprivacy directive (currently being revised under the name eprivacy regulation). It will be very important to monitor this piece of legislation in addition to implementing GDPR requirements as applicable.
Regarding the second aspect of the question: the GDPR compliance process indeed requires contributions from many teams in any organization: legal, finance, IT/IT security, HR, operations. Other teams such as products teams, marketing teams must also be involved.
Q: To what extent does a Company comply with GDPR if is is already ISO 27001 certified? I have heard there is about 90% to 95% overlap.
A: The Department of Commerce is not in a position to provide a definitive comparative analysis between GDPR and ISO 27001 at this stage. Regarding technology to be used, the GDPR mentions state-of-the-art technology but does not specify any further. Companies can look at existing widely-accepted standards for additional guidance such as the NIST Framework or ISO 27001 but this is illustrative only as there is no official recognition by the GDPR.
Q: Can you summarize the key differences in obligations of small companies (<250 employees) versus larger companies that process a lot of personal data?
A: The GDPR essentially applies the same way to companies regardless of their size. There is one exemption for SMEs regarding data processing recording of activities.
Q: Can you speak briefly on the use of "legitimate interest" with respect to managing sales contacts.. for example contact information entered in web form to obtain sales material.
A: Legitimate interest is one of six legal basis that the GDPR proposes for personal data processing. Companies should run an analysis to determine what legal basis they can use and, if several, which one is more suitable for their needs (commercially, structurally etc.). If using the legitimate interest, companies must run an impact assessment to show that they have given proper considerations to reasonable expectations of the data subject, and they must keep a record of that assessment. Recitals 47 onwards offer some guidance on what can be defined as legitimate interest. Examples included direct marketing purposes - provided an opt-out.
Q: Does Privacy Shield take place of Standard Contractual Contracts?
A: Privacy Shield and Standard Contractual Clauses are two of the valid transfer mechanisms. Binding corporate rules are another option. There are differences, which may require legal consultation. For more information, see https://www.privacyshield.gov/article?id=Contract-Requirements-for-Data-Transfers-to-a-Processor and, without prejudice, https://www.bna.com/euus-privacy-shield-n57982076824/
Q: While many discussions surround the GDPR compliance process specifically, once compliant, can you please discuss the process of subject requests, and specifically how to verify an individual is in fact the individual they state to be, to ensure the PII you are providing is owned by the requesting subject.
A: At this stage, there is no official guidance on this matter. One element of this process will be to properly train the staff that will be processing these requests. One practice that has been observed consists of asking the data subject to provide personal data already held by the company to proceed to the identity verification - this is to avoid collecting more personal data about a given data subject, possibly without legal basis. This is one example and does not constitute official recommendation by the Department of Commerce.
Q: Specifically for online ecommerce businesses: for data such as a customer's transaction history (past purchase history etc), does the data need to be deleted immediately upon a customer's request for their data to be deleted? Or does it need to be retained for a required time period as the specific EU country's data retention laws and requirements?
A: Recitals 65 and 66 of the GDPR address the issue. Recital 65 states: "a data subject should have the right to have his or her personal data erased and no longer processed where the personal data are no longer necessary in relation to the purposes for which they are collected or otherwise processed[...]". Companies should carefully consider the way they will draft their information notice, which under GDPR now include retention perdio for the data collected. If companies cannot set a retention perdio, they should at least specify the criteria that will be used to determine the retention.
Q: Our company is receiving a number of Model Clause contract addendums from our Clients. These addendums assign the data importer role to our company. The Model Clauses are stipulating that, if our company receives a privacy request directly from a data subject, we must notify the client company and allow them to participate in or approve any response to the data subject. This would seem to be a violation of the data subjects privacy rights. Is that an incorrect interpretation based on our role as the data importer?
A: First, model clauses cannot be amended in a way that would alter and lower their essence but their langage can be supplemented. Second, the controller is ultimately the party responsible for making determinations pertaining to data subjects' request (for erasure, rectification...). Per article 28 (3) e, the processor should assist the controller to fulfill its obligations in that respect, and their contract should stipulate this element.
Q: This slide states that an organization is eligible for GDPR if they provide goods or services to EU individuals. Does that mean B2B companies are exempt?
A: No, B2B are not exempted as such from the scope of the GDPR. See article 2 (2) for exceptions to the application of the GDPR, which include i.a. activity that is purely personal/household-related, activity that falls outside the scope of EU law.
Q: Is it allowed for a company to be compliant with GDPR without certifying to the Privacy Shield?
A: Yes, Privacy Shield is one existing tool for compliance regarding international personal data transfers. Chapter 5 of the GDPR recognizes other transfer mechanisms (such as model clauses and binding corporate rules).
Q: Has there been any additional clarity or guidance on whether businesses must appoint a DPO?
A: The official DPA guidance document can be found here: http://ec.europa.eu/newsroom/document.cfm?doc_id=44100
In addition some DPAs are producing guidance on qualifications for DPOs. See for instance Ireland DPA's additional guidance: https://dataprotection.ie/viewdoc.asp?DocID=1643&ad=1
Q: How are small US companies dealing with the requirement to have a representative located in the EU?
A: The DPAs have not yet produced any official guidance on the representative requirement. At the moment there is no concerted view on how to meet this requirement.
Q: We are a US firm, with some clients in the EU. We are compliant with US HIPAA requirements. Does that help us be compliant with GDPR? Are there significant differences?
A: The mandate of the Foreign Commercial Service is to counsel on foreign markets' regulatory environment. It is not in a position to provide a comparative analysis between EU and U.S. law. Foreign Commercial Service is not in a position to counsel on HIPAA or draw parallels between HIPAA and the GDPR.
Q: As a small US research business that occasionally conducts surveys of individuals in EU, would simply completing the Privacy Shield application be the first step in gaining compliance?
A: An organization that does international personal data transfers from the EU to a Third Country will need to comply with the GDPR chapter 5 requirements to have a valid transfer mechanisms in place. Privacy Shield is one available tool which that can contribute to building a full compliance program. Certifying to Privacy Shield does not offer full compliance with the GDPR requirements in other chapters.
Successful participation in Privacy Shield indicates to EU regulators an attention to EU data protection regulations. Full compliance in Privacy Shield and GDPR are continual efforts, hence Privacy Shield's renewal process. In particular instances, U.S. officials cannot provide exhaustive legal counsel.
Q: Can you give some specific examples on how Privacy Shield can be leveraged against the requirements of GDPR?
A: Privacy Shield enables participating companies to meet the EU requirements for transferring personal data to third countries, discussed in Chapter V of the GDPR.
Q: What are the top 3 compliance elements that US companies should be focusing on as they kick-off their GDPR compliance?
A: The GDPR applies as a whole to companies that fall in its scope, unless they do not meet specific criteria and fall under some of the exemptions. Companies that were already subject to the previous data protection directive 1995/46 can build on their existing compliance status (e.g. privacy policy, information notices etc.) to achieve GDPR compliance.
Q: What are you hearing from EU data protection authorities about their enforcement priorities in the early months of GDPR implementation? Is there any area that US companies should be particularly concerned about?
A: The GDPR becomes enforceable on May 25, 2018. Some individual DPAs have made statements regarding their intended approach to enforcement of the GDPR. See for example statement from the French DPA which will offer a grace period for new requirements but not for principles that are not new: https://www.cnil.fr/fr/rgpd-comment-la-cnil-vous-accompagne-dans-cette-periode-transitoire
Some have also recognized publicly their challenges to getting ready to meet that deadline. See for instance: https://www.reuters.com/article/us-europe-privacy-analysis/european-regulators-were-not-ready-for-new-privacy-law-idUSKBN1I915X
Q: If my company is meeting Privacy Shield requirements for third party contracts with both controllers and agents, are there any additional GDPR contract requirements they should be aware of?
A: Privacy Shield is a compliance program with regards to international personal data transfers. The GDPR contains numerous other requirements (regarding individuals rights, transparency, accountability, security, etc.) that are separate and for which the Privacy Shield is not a solution.
Q: When the Commerce Department reviews my privacy notice for Privacy Shield compliance, will they also confirm it is GDPR-compliant?
A: No, the Privacy Shield team does not confirm U.S. organization's compliance with GDPR. Our analysis of a privacy policy does not exceed the scope of the Privacy Shield Framework.
Q: Is there a program like Privacy Shield for certifying GDPR compliance?
A: As of right now, there is no approved certification program. Article 42 of the GDPR outlines the establishment of data protection certification mechanisms and data protection seals and marks, but none are approved today.
Q: When applying companies are asked by Commerce to revise their privacy policies, should they post the revised policy for Commerce review online, or do they have to re-upload the revised policy into the system.
A: Unless explicitly advised to upload the policy to their public-facing website, please continue to provide policy updates in a private format. This reduces the possibility of false claims complaints.
Q: If a company is found (by a DPA) to be out of GDPR compliance, could that adversely affect their status on Privacy Shield?
A: A finding by the DPA that a company is not in compliance with the GDPR does not in itself indicate that the company is not in compliance with the Privacy Shield principles.
The EU-U.S. Privacy Shield is a mechanism to transfer personal data from the European Union to the United States. It is not a GDPR compliance mechanism but rather is a mechanism that enables participating companies to meet the EU requirements for transferring personal data to third countries, discussed in Chapter V of the GDPR.
While the Privacy Shield was designed with an eye to the GDPR, addressing both substantive and procedural elements, the requirements in the Privacy Shield and the GDPR are not identical.
However, depending on the violation, a company that is found to be not in compliance with the GDPR could also be found to be not in compliance with the Privacy Shield principles. If an organization persistently fails to comply with the Privacy Shield principles, it will no longer be entitled to benefit from the Privacy Shield. The Department of Commerce will remove the organization from the Privacy Shield list and the organization must return or delete information it received under the Privacy Shield.


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Ahmad Lawan, President of the Senate
Coronavirus: No functional isolation centre in Abuja, North-central – Lawan
byQueenEsther Iroanusi
The Senate President, Ahmad Lawan, on Wednesday expressed disappointment over the sorry state of the temporary isolation centre for victims of coronavirus (COVID-19) in Abuja.
While he described the centre as a sorry sight, he wondered why not a singe room can be called an isolation centre in Abuja and the whole North-central. This, he said, is "despite allocating over N600 million for isolation centres to help contain the virus."
Mr Lawan, said this when he visited the facility located at the University of Abuja Teaching Hospital, Gwagwalada, Abuja.
The centre, he said "is not in good shape and does not look ready to receive any patient – which is something that should be fixed by Thursday", he said.
"We are in an emergency even if we don't have people who are affected, we shouldn't just rest on our oars. We have to do everything and anything possible to fix that temporary isolation centre to be prepared and ready to receive any one who falls sick in this respect."
But officials of the Nigeria Centre for Disease Control (NCDC) lamented that the federal government is yet to release funds to it from the N620 million earmarked to fight the disease.
The Senate President, however, urged the Ministry of Finance and the Federal Ministry of Health to immediately release the money to enable the NCDC put in place what is required to combat the pandemic.
He also promised that the Senate would ensure the release of the money.
He also called on the NCDC to replicate the building of its permanent isolation which is said to be 88 per cent complete in the other five geo-political zones of the country.
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Speaking to reporters after the tour, Mr Lawan said officials are in high spirits looking determined to discharge their mandate and obligation.
"We are indeed sad that the N620 million that was supposed to be released to the NCDC for fixing of everything here, not a kobo has been released. We are going to get across to the Minister of Finance and all the other authorities who have anything to do with this to release this money between today and tomorrow latest.
"There's no way that Nigeria, the largest economy in Africa, with a population of 200 million, and yet the Federal Capital and six surrounding states of the North-central, you don't have one room that you can call an isolation centre, where anyone who unfortunately falls into this crisis will be taken to. This is not acceptable.
"Let's spend money on our people, we waste money on some things that are less important. This is about the health and lives of the people of this country, and therefore, no investment is too much."
He said relevant committees of the Senate will follow-up on Thursday to ensure that work on the isolation centre begins and is completed.
The lawmaker's comments comes a day after the health minister, Osagie Ehanire, visited the leadership of the Senate and discussed the country's level of preparedness as well as progress made so far.
The news of the first recorded case of the virus was made known early last Friday, following confirmation from the Lagos State Government.
Many have, however, commended the NCDC for their efforts in tackling the disease.
The virus, which originated from China in December, has spread to about 60 countries. The respiratory disease, which has killed over 3,000 people, is capable of spreading through human-to-human contact, droplets carried through sneezing and coughing, and germs left on inanimate objects.
Symptoms of the disease can include a sore throat, runny nose, fever or pneumonia and can progress to multiple organ failure or death in some severe cases.
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QueenEsther Iroanusi
QueenEsther Iroanusi covers the National Assembly for PREMIUM TIMES. She is a 2018 Female Reporters Leadership Programme fellow of the Wole Soyinka Centre for Investigative Journalism. She has a degree in French. She can be reached on Twitter @QueenExtha
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text:
SORC 2012 Lineup
Where are our manners?
Once again, Team Pantera Racing members from the midwest are heading to the Sandhills Open Road Challenge. This year we have three members committed to go and we wish them all the luck in the world.
The Sandhills Open Road Challenge is one of the best Open Road Races there is. It's a two-stage, there and back again race with an intermission between the two legs of the course. Plenty of twists and straight open road... and unforgiving ditches on either side. Many drivers claim this race to have some of the most beautiful scenery of any open road race in America today.
The town of Arnold Nebraska has benefit from this race so much in years past, they are very happy and very helpful in hosting the race each year. Most townsfolk come out to help with tech, put decals on cars, put on a parade and barbecues. Since there are no hotels in Arnold, they even open up their homes to host the drivers for the event. It's all around a great time.
Wish our drivers luck.
2012 Return to SSCC
In what is shaping up to be a spectacular return to the Silver State Classic Challenge, Team Pantera Racing has an unconfirmed field of six drivers -and- "Cafe' Finito" for the finish line. Not wishing to disappoint their adoring fans, the 25th running of SSCC will feature the likes of TPR not seen in 10 years. Veterans and fans alike do not want to miss this year's running.
Team Pantera Racing is the first, and still the only vintage race team to field 10 examples of production cars from the era. TPR President Dennis (Mad Dawg) Antenucci is working hard to repeat that success this year. So much so in fact he has offered a $10,000 award to -any- other race team that can field 10 cars from the period prior to 1974. No team has done it since Team Pantera Racing, and Mad Dawg feels confident no team ever will. During that record breaking attendance of Panteras, TPR also sponsored "Cafe' Finito," an Italian diner on wheels.
The 2012 running of the SSCC will see the return of Cafe' Finito with a newer and larger rig. All TPR members will have access to complimentary beverages and food at the finish line. All others must pay for entry, and then submit to Mad Dawg's will before being allowed entry. We're being told this season may also see the return of the Brazilian Girls who have been absent on occasion at these events.
This is the year you don't want to miss. If you are a Veteran of TPR or a groupie, you had better make plans now to attend this 25th running of the Silver State Classic Challenge. Go all the way, or go home.
Last Updated on Monday, 09 July 2012 10:38
March 2012 Willow Springs Reports
Written by Mad Dawg Antenucci
Jim & Shari Saxton's West Coast Racing Event (previously known as the Ferrari/Pantera Clubs joint event) was a blast yesterday.
A real bargain for $145 for one day or $215 for two days. I could hardly believe there is a photo of 20 Pantera's and their owners on the wall in the cafeteria....in the photo the Pantera's are all lined up on the track from 20 years ago....I don't know who the drivers were because all of them were young skinny guys with hair....someone told me the guy standing next to the black Pantera was me and that the black Pantera next to me was mine but that could not of been me because that guy in the photo had hair....lots of hair! ;-]>
Okay, Willow, if you haven't been there before has a great 2.5 mile 9-turn course with elevation changes and two long front and rear straights...a great track for a Pantera. Yea, for that little money Jim & Sheri'strack event is a allota bang for the buck.
It was the first track event that I ran in Socal in 1992 after I moved to Huntington Beach from SF. Sheri always puts on a big lunch at no additional cost and she spent allot of time just wondering around checking with drivers all day if they needed anything or had any problems....They offered me their garage....they asked me several times if I needed anything.....Yea I know I look like I need help.....and do.....but seriously Sheri is the Track Mom of all track moms.....and it was her chocolate chip cookies that helped. ;-]>
Last Updated on Sunday, 04 March 2012 19:58
March Racing 2012
For those wishing to stretch the legs on their favorite cat,
here is an event you might not have been aware of:
Jim Saxton Open Track Event at Willow Springs March 3-4, 2012...(West Coast Racing)
Contact Jim 626-285-2515....email This e-mail address is being protected from spambots. You need JavaScript enabled to view it
Asa Jay
Last Updated on Friday, 03 February 2012 19:44
Supporting and Encouraging Legal Racing of Your De Tomaso Pantera in
Sanctioned Open Road Racing (ORR) and Track Events.
Welcome To:
Do you have a Need for Speed? Do you want to see how fast your Pantera will go, legally?
Want to know what the big dogs are running in their Pantera? Need advice, need direction, need more than just car shows?
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