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Furniture Designer Resume Example …
blason resume A qui est ce blason ? Cliquez sur le blason pour le savoir. Resume For Furniture. L'héraldique est la science ou l'art qui étudie les blasons et les armoiries. Essays Michel Montaigne. L'héraldique permettait d'identifier le porteur du blason et de connaître son histoire (les faits d'armes et les victoires qu'il avait remporté). For Furniture. L'héraldique s'est développée au Moyen Âge dans toute l'Europe . List. Au départ, les blasons étaient utilisés par les chevaliers pour être reconnus, puis rapidement, son usage s'est étendu à toute la société : femmes, clercs, paysans, bourgeois, villes, régions, pays et même corporations de métiers. Il existe donc une quantité considérable de blasons, qui se sont compliqués au fil des siècles. Resume For Furniture. Pour arriver à identifier un blason - et l'homme qui se cache derrière - il faut d'abord connaître le vocabulaire très particulier de l'héraldique.
Un blason est un ensemble de couleurs et de dessins peints sur un écu. Kundera Essays. Les armoiries (ou armes) sont l'ensemble formé par l'écu, les figures, les devises et tous les ornements extérieurs du blason. Resume For Furniture. Un écu est un bouclier. Il servait aux guerriers à se protéger bien sûr, mais aussi à effrayer l'ennemi (dans l'Antiquité on milan essays, dessinait des figures monstrueuses sur le bouclier) et puis à identifier le porteur , sa famille ou son clan sur les champs de bataille. Resume For Furniture. Il existe toute sorte de formes d'écu, parce qu'il existait toute sorte de formes de bouclier ! La plus classique est l'écu ordinaire : Mais il existe nombre d'autres formes, par exemple : Chaque pays a sa forme particulière, par exemple : Cliquez ici pour télécharger une page (format .doc) avec toutes ces formes d'écu. Transitions. (51 ko) En héraldique, les couleurs ont un nom particulier, on resume, les appelle les émaux . Life Essay. - d'associer un métal sur un métal. For Furniture. - d'associer une couleur sur une couleur. Life. - d'associer une fourrure sur une fourrure. For Furniture. Attention , les fourrures ne sont pas obligatoirement de ces couleurs là ! On peut voir par exemple : le vair d'or et gueules , de gueules herminé d'or , d'azur herminé d'or , le péan (hermine sable moucheté d'or) ou encore l'erminois (hermine d'or moucheté de sable) etc. Essay Locke Sparknotes. Et les motifs peuvent être plus ou moins grands. Resume. Par exemple : le Menu-vair ou le Gros-vair (appelé aussi Beffroi). Transitions Essay Writing. Cliquez ici pour télécharger une page (format .doc) avec les émaux, les métaux et les fourrures. Resume For Furniture. (73 ko) 4) Les partitions : les découpages à l'intérieur des blasons.
Un écu reste rarement intact, il peut être divisé en deux, en quatre, en diagonale ou découpé en bandes horizontales ou verticales, orné de motifs géométriques, permettant d'alterner les couleurs. Les découpages des écus sont appelé partitions . List Transitions. Lorsque l'écu est uni, sans partition, il est dit plain . For Furniture. Voici les principales partitions : L'écu peut être orné de formes géométriques , lignes horizontales, verticales, diagonales, carré, triangle etc. Paper. Chaque forme porte un nom, voici les plus communes que l'on appelle pièces honorables en héraldique : Il existe aussi les rabattements , ce sont, pour parler simplement, des rayures de deux couleurs, verticales, horizontales ou diagonales. Resume For Furniture. En fait, on life essay, répète les formes géométriques précédentes. Resume. C'est déjà plus compliqué, mais les voici : Cliquez ici pour télécharger une page (format .doc) avec les partitions, les pièces honorables et les rabattements. List Writing. (123ko) 5) Les meubles et les figures : les décors sur les blasons.
En plus des couleurs et des formes, les blasons peuvent porter des objets, on for furniture, les appelle des meubles ou les figures quand il s'agit d'animaux ou d'humains. Life. Ce sont des formes géométriques ou des animaux . For Furniture. Ce sont des carrés, losanges, triangles, ronds, rectangles, anneaux etc. Chaque forme prend un nom particulier en héraldique, voici les plus courantes : Ce sont très souvent, le lion et l'aigle , mais on summary essays montaigne, trouve aussi l'abeille, le cerf, le coq, la cigogne, le loup, le sanglier, l'ours etc. Resume For Furniture. Les animaux peuvent être dans des positions différentes , aussi leur nom change. Transitions Essay Writing. Par exemple, pour le lion : On peut associer les positions : contourné et passant, regardant et couché etc. For Furniture. On trouve aussi des monstres fabuleux, des animaux fantastiques , tels que : Le plus célèbre est incontestablement la fleur de lys , mais on letter agent, trouve aussi des roses, des arbres, des chardons, des épis de blés, des palmes, des pins etc. For Furniture. Les objets inanimés (constructions, outils, etc.) Ce sont par exemple, une couronne , une épée, des outils, des clés, une tour , un soleil, une lune, une étoile, une coquille, un fer à cheval, un navire, un chateau et toutes sortes de croix. Kundera. Cliquez ici pour télécharger une page (format .doc) avec encore plus de meubles et de figures. Resume. (218ko) Autour de l'écu, on summary michel, peut rajouter d'autres éléments : le cimier, le cri et la devise et d'autres choses encore. Resume. En langage héraldique, lire un blason se dit blasonner .Cela consiste à décrire le blason avec précision . Desk Agent. Le vocabulaire spécifique à l'héraldique est donc essentiel pour être précis. On commence par le partitionnement s'il y en a un. For Furniture. Puis l'émail (les couleurs) du champ principal.
S'il y a plusieurs charges (c'est-à-dire plusieurs pièces ou meubles), il faut commencer par les plus importants : les pièces avant les meubles, le centre avant les côtés, les grandes avant les petites, les nombreuses avant celles qui sont uniques. Essays Montaigne. Pour voir des exemples de lecture , voir ci-dessous, des blasons célèbres. Resume. D'azur aux trois fleurs de lys. Front Desk Agent. Au trouve au-dessus, une couronne, le cri des rois de France Montjoie Saint Denis, deux anges et d'autres ornements. Resume For Furniture. Ecartelé 1 et 4 : de gueules, à trois léopards d'or (Angleterre) ; au 2, d'or, au lion de gueules, enfermé dans un double trescheur, fleurdelisé et contre-fleurdelisé du même (Ecosse) ; au 3, d'azur, à la harpe d'or, cordée d'argent (Irlande). Sa devise : Dieu et mon droit De gueules au château d'or. Analysis College Essays. Castel de Saverdun en lettres d'argent. Resume For Furniture. D'azur aux treize couronnes d'or.
Sa devise : Pendragon Teste de Dragon. Cover Letter Front Desk Agent. D'argent aux trois bandes de gueules. Resume For Furniture. Sa devise: Du lac ma Dame Tout le monde peut dessiner son propre blason, il faut seulement s'assurer que personne d'autre ne le possède déjà ! Votre blason doit être simple , facile à dessiner et facile à lire. Cover Letter Front. Mais attention, si vous choisissez d'azur plain (c'est-à-dire tout bleu) il existe certainement déjà depuis des siècles ! Pour vous aider, pensez à : la forme d'écu que vous voulez. Par exemple, si vous être une jeune-fille ce sera forcément un losange ! votre couleur préférée pour la mettre en fond. Resume For Furniture. vos autres couleurs préférées pour les éléments tels que partitions, meubles etc. Summary Essays Michel. un animal que vous aimez, peut-être auquel vous ressemblez (pas physiquement j'espère !!) un objet que vous aimez, qui vous représente. For Furniture. la partition que vous souhaitez mettre. Milan. (lignes ? croix ? bande ?) Maintenant, il ne reste plus qu'à prendre son crayon et à faire des essais ! 1) Décrivez ces blasons en utilisant le vocabulaire héraldique : 2) Cherchez l'erreur dans ce très ancien blason du royaume de Jérusalem . Resume For Furniture. 3) En utilisant vos connaissances, réaliser votre blason en respectant la règle des émaux et en plaçant obligatoirement une partition et un meuble (géométrique, animal, végétal ou autre), au minimum.
Décrivez votre blason dans le langage héraldique. Challenge. Cliquez ici télécharger (format .doc) le sujet de devoir. For Furniture. (62ko). Challenge Essay. L'héraldique est vraiment très compliqué, il ne s'agit ici que d'une initiation ! Pour plus de détails (beaucoup de détails) voir :
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Furniture Sales Associate Resume …
Teaching Speech Sounds: The Process of Articulation Therapy. Teaching kids how to resume say speech sounds they can’t produce is called “Articulation Therapy.” As a speech-language pathologist I assess what sounds need to be learned and then systematically train a child how to essays produce them. It is for furniture, one of the most rewarding things I do. I love when it begins to click and I can see my clients producing their sounds correctly and summary essays michel montaigne, confidently. I have created several worksheets for you to use with your child or your students, but I thought that it would be helpful for me to explain the process of how to teach these sounds.
There are many reasons a child might not be able to say a certain sound(s). Some of those may be related to resume apraxia of cover front desk, speech, phonological disorders, cranio-facial anomalies (i.e. cleft lip/palate), etc. Those special cases will not be discussed right now in this post. I will be explaining a traditional articulation therapy hierarchy. It is a brief and basic outline you can use when teaching your child or student to produce certain sounds he/she is struggling to for furniture say. It is always a good idea to check with your local speech-language pathologist so they can fully assess your child’s speech and essay understanding sparknotes, language needs. A speech therapist will usually give an Articulation Test to see which sounds are in error and in which part of the resume for furniture, word (beginning, middle, or end). Once this is determined, they will see if those errors are typical for kids of that age or not. They will then recommend therapy if necessary. Just to let you know – there are a few different ways of kundera, teaching speech sounds to kids.
I’m going to walk you through what is known as the “Traditional Articulation Therapy” approach. Depending on the age, number of resume for furniture, sounds in errors, and other underlying factors an SLP may choose to use a different approach – again, just another good reason to summary consult with your local SLP! They will be happy to help you and your child! Okay, let’s go through each step of the resume for furniture, traditional process of articulation therapy! The first thing you want to do is see if your child can make the essay concerning john sparknotes, sound by itself. We call this first level ‘isolation’. See if they can copy you as you model how to say the individual sound. Have them really listen and watch you say the sound first and then copy you. If they can correctly imitate you – this is great! We would then say that they are stimulable for that sound, meaning they can physically produce it! (i.e. lift their tongue into the right spot in their mouth, etc.) Now you would begin to help incorporate that good speech sound into all levels of speech!
At the resume, isolation level, you can begin to analysis paper essays model the correct sound production in your everyday speech with your child. Try to resume highlight and concerning john sparknotes, emphasize it whenever you say it. Print out some of the worksheets that have their sound in them and talk about the words and resume for furniture, the pictures with your child. Using the conversational re-cast is another great tool! It is essays, so simple and effective. If you hear your child use an incorrect sound (gag for for furniture, dad) you would say something like this: Child: “I want to life challenge essay play with my dod” (dog)! Parent: “Yes, you can play with your DoG after lunch!” You just re-say or re-cast the sentence your child just said, BUT you emphasize the correct sounds.
This is for furniture, much better than asking your child to continually repeat their words or sentences – which can be so frustrating for kids. By hearing you say the kundera, correct sound immediately after they have made the resume, error, they are getting the feedback they need! If your child cannot imitate you at essay human understanding all, then you would want to begin teaching them where to resume for furniture put their tongue in their mouth in order to cover agent say the certain sound (i.e. behind upper teeth (for /t/ or /d/ sounds) or (in the resume, back of the throat for /k/ or /g/ sounds). The second level in the process of articulation therapy is called the ‘syllable level’. This is when we pair the individual sound (which they should be able to produce now) with a vowel. At this level, you would use the long and short vowel sounds along with the target sound. Let’s say you are working on the /t/ sound. Here is how you introduce that sound in syllables in all positions (beginning, middle, and end). List Transitions Essay Writing? Have your child practice saying the sound at the beginning of the syllable: tay, tea, tie, toe, to. Resume? Then at the end of the syllable: at, et, it, ot, ut. Life Challenge? Then finally in the middle of the syllable: atta, etta, itta, otto, uttu.
Once your child can say the sound at the syllable level, you can move on to words! Click here to use my syllable wheels for this stage! Now it’s time to put that sound into real words! Start with the beginning of the word using the resume, worksheet pages to make cards. Then move to the end and then the middle of the word.
You can also go on a treasure hunt in john your home and resume for furniture, hunt for things that have the target sound in human locke sparknotes them! For example, you and your child (or client if you are an SLP) can search for things containing their sound. See how many you can find! You could even hunt for things with their target sound at the grocery store, at the park, in books, etc! Now that your child has their sound down in single words, you are ready to increase the for furniture, level of difficulty again by adding a few more words to the mix!
A phrase is list transitions, simply using their target sound in for furniture combination with a couple words. Let’s use the /t/ sound again as an example. Here are some phrases with the comparative analysis essays, /t/ sound: “Too much fun”, “Take the car” “time to eat” “count to three” etc. Resume? Use words that have the target sound in essay concerning locke the beginning, middle, and end. The sentence level just adds more words to the phrase to make a complete sentence. This level is resume, more difficult because it requires the list transitions essay writing, child to maintain correct speech sound production while adding other words to express a complete thought! Whew! That can be a lot for some kids to remember! Just keep practicing! It may take lots of for furniture, tries, but they will get it. Use words that contain their sound in all positions of the word (beginning, middle, and end).
Have them practice saying their the target sound in the beginning of words in sentences: “A big _________” (insert the words: tree, toad, tiger, etc.). Then have your child practice using their target sound at the end of words in life challenge essay sentences: “The funny ______ is under the table” (insert final /t/ words: cat, rat, boat, etc.). Do the same for medial /t/. It is fun when the sentences are silly! You can talk about why the sentences are silly. Ask your child why it’s silly for a boat to be under the table or what a funny boat looks like?
Have them use their imaginations! They could draw a picture of a “funny boat” and tell you about for furniture, it using their good /t/ sound. 6. READING (Or Oral Story-Telling for non-readers) If your child can read, you will then be able to introduce books and have them read to you while continuing to produce their target sound correctly. If your child is milan kundera, not yet a reader, have them tell you stories they make up. They can also retell a story you have told them. Resume? I love this level because my students are professionals at milan essays telling me stories! This is the last level! Once your child has progressed through reading/story-telling, they should be ready to use their target sounds during their everyday speech.
You can continue to re-cast their sentences if they forget to use their correct sound. You can also remind them to use their “good __ sound!” if you hear an for furniture error. By this time, there should only be occasional errors. Producing their target sound should be almost effortless and very automatic. Remember to have fun and to be patient! This can take a lot of time, but your child will get it! Please let me know how you are doing with this approach.
I love hearing stories about how therapy is going! A child comes to me for speech therapy, he girst used to talk in “D” language. Means all words in D. After I took b, p,m, t, n. Now he has started talking in “P” language. He is very stubborn child. He doesn’t listen to anybody. I want your help. Life? Pl let me know what to resume for furniture do. The process is working fine for my child. But, she is cover desk, mispronouncing letters as she keeps on adding new.
For ex, she learnt p first. Now when we try to teach her b, she is loosing p. hi,,my daughter is 5 years old and has problems pronouncing the sss and thh. she has a frontal lisp. She can imitate me perfectly but she never remembers to resume for furniture say the words correctly unless she is asked too. Its been a year now and summary montaigne, the situation is starting to get frustrating for all concerned. I am using this treatment as a student clinician in NY at Adelphi University. Do you happen to know of any studies that used this articulation treatment and came out with good results from the resume, past ten years? I am having trouble finding one.
Thanks. I know that clinicians have been using this vertical, hierarchal approach extensively since it was first made known by milan Van Riper and I’ve seen it referenced in journals. I’m not aware of any exact studies specifically on Van Riper in the last 10 years; however, if you are interested in resume what current research is milan essays, showing about the remediation of phonological and articulation disorders you should check out http://www.slpath.com. Jennifer Taps is doing great things for for furniture, artic/phono therapy. Thank you for writing to me! #128578; Thank you so much for the awesome advice.
The Speech therapist at john my son’s school has recommended therapy for an incorrect ‘th’ sound. Financially, at for furniture the moment, we are unable to send him as he attends weekly occupational therapy sessions. I am SO excited to try your ideas and worksheet cards to help him. Hi Kerry! Im so happy you will use these materials and tips for comparative paper, your son! Please let me know how I can help you along the way! Hi, How can I assess a student’s (Kdg.) letter sound knowledge when his articulation is poor? It’s difficult to distinguish if he is saying bee, cee, tee, gee, pee, dee, zee, or vee. Yeah, that can be tricky.
I would have to determine if when I said the sound to him, he could point to or choose the correct letter symbol from a choice of resume, two letters to the one that matches that sound. Does that make sense? I hope that helps but you will need to essays michel montaigne use a more receptive task since his expressive is distorted. You can use picture cards too in the same format. Let me know how it goes! pl sugggest measures for an adult for pronounciation of letter “R” how i can use Speech Sounds in for furniture Syllable Wheel method. How do you help a child produce the /s/ sound and the /z/ sound in isolation?
There are different ways of going about training the correct tongue position. I like to start by transitions writing showing them with a flavored tongue depressor where the tip of the tongue should go. Resume? If they can produce a good /t/ sound, you can definitely use that for placement and then have them make a long t…which ends up sounding like this: tttttttttsssssssssss. Front Desk Agent? If you tell them to hold it as long as they can it just sort of naturally turns into an /s/. Once they get it, have them do lots of drill and repetitions. Resume? Then teach them how to turn on their voice while making an /s/ which then results in a /z/ sound! Let me know how it goes.
I’ll be excited to essay concerning understanding locke sparknotes hear if this works for you child! Hi I am working as a literacy tutor with an adult who has issues with mixing up syllables in longer words, eg she will say explosive instead of exposure. It seems to mostly the final syllable that comes out wrong, it happens in resume conversations and concerning human understanding john sparknotes, the word she say has completely the wrong meaning, but you know what she means from context. It really affects her confidence, and she has negative stories about childhood issues with teachers at school due to resume for furniture this problem. She also struggles to essay spell longer words after the for furniture, first syllable. Essay Understanding John Locke? I am thinking about working with her to recognise and say syllables separately and then put them together, as I would with English language learners trying to get their mouths around more complex words. Do you have any suggestions for helping her? She has a reasonable level of literacy overall, no other real problems, I am thinking of this as a form of dyslexia or dyspraxia. What do you think? Thanks.
Yes, sounds similar to resume my students with dyslexia. I LOVE the challenge essay, Lindamoodbell LiPS program. Resume For Furniture? It addresses this very thing. The ability to hear various syllables in comparative analysis multisyllabic words can be very challenging for resume, people with dyslexia. Even adults that have literacy issues can make progress and retrain their brains how to process sounds in words and syllables. Challenge Essay? I would DEFINITELY recommend getting your hands on the LiPS program. The LiPS program uses colored felt squares to resume for furniture represent syllables in words. Say a word for her. Concerning Understanding Locke? It can be a nonsense word. Resume For Furniture? By that I mean, not a real word but a word that uses real English sounds. For example, “hap-tion.” Say the word to her and place two different colored felts on the table.
Touch each felt as you say the word. This is life challenge, helpful because she can’t rely on resume for furniture prior knowledge of the word and essay, the colored felt squares serve as a visual representation of the resume, two syllables. Then you would say, if this says “hap-tion” show me “dac-tion” and she would then show this syllable change by college essays changing the first colored felt and replacing it with a different color because the syllable changed from “hap” to “dac”. You do this same thing for longer words and resume for furniture, eventually they learn to hear the differences between syllables in much longer words. The next level of difficulty is hearing a single sound change (beginning, middle or ending sound) within a syllable, within a multisyllabic word. Essay Concerning Understanding Locke Sparknotes? For example, let’s take the word, “dis-trac-tion”. You would say, “dis-trac-tion” and place the colored felts for the number of syllables, so 3 different colored felts are placed on the table. Then you would choose which syllable to target this time.
Either the first, second, or third syllable. (You will need to print out the actual letters and place them on the felt of the syllable you are targeting). Then say, if this word says “dis-trac-tion” then show me “dis-fac-tion.” She should then remove the “tr” letter tiles and replace the first sound (in the second syllable of the word) with a new letter tile, now an “f”. Does this make sense?? I sure hope so! You can do the same thing for any of the syllables.
Let me know if you have more questions and I’d love to hear how she is resume for furniture, progressing! I have found your site incredibly helpful! I teach 5 and 6 year olds and have a large group of children that cannot pronounce ( or spell) works with f/th/v. It doesn’t seem to matter if it is at the beginning, middle or end of a word? Any suggestions please? I would do some very basic phonemic awareness type activities with them. I love the Lindamood Bell LiPS program.
They teach sounds by helping the kids think about what their mouth is doing and then FEELING the parts of summary essays michel montaigne, their mouth working for different sounds. So for resume, example, the /f/ sound is labeled a “lip cooler” because the top teeth are touching the milan essays, bottom lip and then air is being blown over the bottom lip essentially cooling it off! You could also talk about how /f/ is a quiet sound and for furniture, /v/ is a noisy sound. But they are brothers because they are produced in the same way except that one is comparative analysis college essays, quiet /f/ and one is for furniture, noisy /v/. Essay Understanding Locke? Use the lower case letter symbol as you talk about the resume for furniture, sound.
To help them grasp the life, /th/ sound, talk about how their mouth works. Describe the for furniture, parts of the mouth that work for human understanding sparknotes, that sound. Have them watch you produce it. The /th/ sound is resume for furniture, called a “tongue cooler”. The top teeth touch the transitions writing, tongue while air comes out over the top of the tongue essentially cooling it off. Be sure to for furniture have the letters there for milan kundera, them to resume see while to summary essays discuss how the mouth looks and feels for this sound too. It also is resume for furniture, a quiet sound as opposed to the noisy brother /th/ as in milan kundera the work “mother.” Let me know if this approach helps! Thanks for your question. Your information is very helpful.
Could you recommend a method/worksheets of assessing students? I will be working with children at a small private school. Should I play the copycat game? I am from resume for furniture India.my son is 3.5 years.he has speech delay.he can speak few bisyllables now.sometimes he knows small words but won’t say them spontaneously.after asking him for 20 times he would reply with that word.how can I make him say small words spontaneously? Please help. Hi heather, thanks for a great blog. Do you ever use a phonology based approach with your speech clients? Or generally articulation approach? Absolutely. If a child has multiple sounds in error, after analyzing their speech extensively (standardized tests, language sample, etc.) I may choose to concerning understanding locke treat later developing sounds, non-stimulable sounds, or 3-element, complex clusters or two element clusters, more frequently occurring sounds, etc.
I love Jennifer Taps and her research-based approach to treating articulation and phonological disorders. To read more, go to http://www.slpath.com. Thanks for resume for furniture, the additional info Heather, I’ll look into that website #128578; Thank you for the information above. It is very informative and gives you a clear picture of what to expect in articulation therapy. I had a question however regarding a student. Understanding Locke Sparknotes? I have a student who adds “t” to open single syllable words such as “sea” (seat) ,even though he is resume for furniture, required via imitation to imitate the letter desk, word “sea” or even imitate labeling the letter “C”. Is he demonstrating a particular phonological process ? Can you please given some insight in his behavior and why he is doing this ? Thank you so much for your expertise on this issue. So interesting. I have not personally encountered a child who did this.
My first question would be how old is he/she? Second, are they confusing the word you are saying with another word? Third, Try using a minimal pairs contrast when presenting the word. Use a visual picture paired with the spoken word. Resume? For example, a picture of the “sea” and a picture of a “seat”. Present the two picture to him/her. Cover Letter Front? Say this is the “sea” (point to it) and then say “this is resume, a seat” (point to it).
Then say, point to the “sea” (hopefully he/she will point to list essay the right picture card) then say, “point to resume for furniture the SEA-T” and hopefully he/she will point to the correct word. If he/she can identify them correctly, have them do this task expressively, i.e. you point to the card and say, “what is this?” or “this is a _____?” and have him/her say the list transitions writing, word correctly. I would emphasize that by adding a sound, his little one is changing the meaning! See if that approach helps. If he is very young, use real toys or objects in resume for furniture a similar way I described above. Let me know how that is going! Thankyou so much for all your information. I’m in India and my daughter has speech delay. Cover Letter Front Desk? She’s 2.5 years old. Thankyou again.
Wow! I am so excited that you found my website and that it is helpful to you as you work with your daughter. Please email me with any questions you may have. Resume For Furniture? I’m always very happy to milan kundera help you as you help your little girl!
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Furniture Sales Associate Resume …
15 Pilates Moves That Get Results. What sets Pilates apart is its focus on toning the resume for furniture, muscles with springs, bands, or your own body weight. Alycea Ungaro, author of 15 Minute Everyday Pilates, shares her routine for beginners. Some moves are shown using Pilates studio equipment, but you can do most moves at home. List Transitions! Check with a doctor first if you're a man over 45 or a woman over resume 55, or if you have a medical condition. This classic move helps flatten the tummy by using your abs efficiently.
Hold on behind the knees, scoop the belly in, and curl down to challenge the floor to get into for furniture position. Now curl the kundera, head and shoulders up slightly, lower back still pressed to resume for furniture the floor. Pump the milan kundera essays, arms up and down in small motions at your sides. Breathe in for five and out for five until you hit 50 pumps. Sit up and repeat for a total of 100 pumps. In a studio, you can try the Pilates hundred on a reformer, a spring-based resistance machine. For Furniture! Lie on your back with your legs in life table-top position or extended at a 45-degree angle. Pull the straps down next to your abdomen. For Furniture! Curl the head and shoulders up and letter front desk agent, pulse your arms up and down. Breathe in for five and out for five until you reach 100 pulses. If any move doesn't feel right, check with a fitness professional.
Begin this starter sit-up with your legs straight in front of you. Resume! Extend your arms over your legs and lower your head between your arms. Curl backward, bending your knees, and stop halfway down. Raise your arms straight up and pull your abs in tightly. Exhale and lower your arms as you curl back up.
Do 6-8 reps at a moderate pace. As you become more advanced, try lowering all the way to the floor. If sit-ups give you a sore neck, try this alternative. Lie flat with the end of a resistance band or towel tucked under the center of your back. Bend your knees and grab the other end of the band above your head.
Inhale and use your ab muscles to slowly peel your body up, letting your head rest against paper college essays, the band. Exhale and return to the starting position. Do five reps, making sure your abs do all the work. Keep that resistance band handy for resume, this waist-toning move. Sit with your legs a little more than hip-distance apart. Hold the band between your hands and raise your arms overhead. Exhale as you turn to one side, using the cover letter agent, muscles in your waist. Inhale as you reach the arms out and for furniture, back, keeping the hips in place. Summary Michel Montaigne! Exhale and return to starting position.
Alternate for a total of four sets on each side. Lower Back: Shoulder Bridge, Part 1. As you strengthen your abs, it's vital to tone the back of the body as well. Lie on your back with your knees bent and your feet hip-width apart. Keep your arms at your sides and raise your hips without arching your back. For Furniture! Tighten the muscles of your buttocks and hamstrings, and hold for five breaths. Lower down one vertebra at a time to the floor if you're stopping here, or go on to the advanced posture.
Lower Back: Shoulder Bridge, Part 2. Keeping your hips raised, extend one leg straight up and point the foot. Kick the leg down and out, flexing the foot. Repeat, exhaling as you extend the leg up and inhaling as you kick it down. Keep your torso strong and your other foot firmly on the mat. Milan Kundera Essays! Do five reps with each leg. Toning the upper back is the for furniture, fast track to better posture. This move uses the reformer with an accessory called a long box.
Lie on montaigne your stomach with your chest just past the edge of the long box. Resume For Furniture! Grab the analysis college, straps in for furniture front of front desk agent you with straight arms. Lift the resume, head and chest as you pull the straps down toward your hips. The long box will slide forward, with you on top. Release the arms back to the starting position. Essay John Locke! Do five reps. Want to target the upper back without a reformer?
Lie face down on a mat with your feet together. Raise your head and chest slightly, and extend your arms perpendicular to your body, palms down. Exhale and sweep the arms back as you lift your chin and chest higher. Keep your waist on the mat and use your upper back muscles to bring your arms closer to for furniture your body. Return to starting position. Do five reps. This powerful upper-body toner can be done on a mat, reformer, or Wunda chair. If using a mat, sit with your legs straight in front of you, feet together and flexed. Press your hands flat on the mat, look down, and use your upper body strength to lift your backside and upper legs. Swing yourself forward and backward before lowering slowly to the mat. Do five reps.
A pair of small hand-weights adds punch to a Pilates workout at home. For this move, imagine you are twirling the challenge essay, weights like sparklers on the Fourth of July. Stand with the weights held at your thighs. Turn them slightly in to face each other and make eight small circles. Each circle should be a little higher until the hands are overhead.
Make eight circles in the opposite resume direction as you lower the arms. Repeat 2-3 times. Lower Body: Kneeling Knee Stretches. This reformer exercise is an efficient way to work the entire lower body. Kneel on the reformer and round the essays michel montaigne, back, keeping the for furniture, arms straight. Use the concerning understanding locke sparknotes, butt muscles and thighs to push and pull your lower body back and forth.
The platform will slide a few inches with each movement. Do five reps. As you get more advanced, do another five reps with the back arched. Here's a way to tone the thighs and butt without a reformer. Begin by kneeling. Lean to the left, placing your left hand on the mat under the shoulder and resume for furniture, your right hand behind the head with the elbow pointing up. Raise your right leg until it is parallel to the floor. Holding the torso steady, kick the leg to the front and life challenge, then to resume the back, knee straight.
Do five reps on each side. This move sculpts the legs while getting your heart rate up. List Transitions Writing! Stand with your arms crossed in front of you at shoulder height. For Furniture! Keeping your abs tight, exhale and lift your right knee up toward the right elbow. Lower the leg quickly and repeat on summary montaigne the other side. Keep switching sides for a total of 10 swings with each leg. Besides toning the muscles, Pilates is known for boosting endurance.
A wall and small hand-weights are the only necessities for this highly effective exercise. Stand with your back against resume for furniture, the wall and feet hip-width apart. Walk the feet out a little, bend the knees, and analysis paper college essays, slide down as if sitting in a chair. The upper legs should be parallel to the floor. Raise the arms to shoulder height and hold for 30 seconds.
Do two reps. Resume! While the focus of Pilates is essay strength training, you'll get some cardio in with moves like this. Stand with your belly pulled in and your arms overhead. Exhale and for furniture, lower your head, bending the knees and swinging the arms back. Inhale and jump up with straight legs, reaching the arms overhead.
Land with the knees slightly bent and list essay, return quickly to starting position. Do 8-10 reps at a rapid pace. You should be out of breath when you finish. Resume! IMAGES PROVIDED BY: 1) Steve Pomberg/WebMD. 2) Steve Pomberg/WebMD.
3) Steve Pomberg/WebMD. 4) Steve Pomberg/WebMD. 5) Steve Pomberg/WebMD. 6) Steve Pomberg/WebMD. 7) Steve Pomberg/WebMD. 8) Steve Pomberg/WebMD. 9) Steve Pomberg/WebMD. 10) Steve Pomberg/WebMD. 11) Steve Pomberg/WebMD. 12) Steve Pomberg/WebMD.
13) Steve Pomberg/WebMD. 14) Steve Pomberg/WebMD. 15) Steve Pomberg/WebMD. 16) Steve Pomberg/WebMD. 17) Steve Pomberg/WebMD. Alycea Ungaro, physical therapist; owner, Real Pilates, New York; author, 15 Minute Everyday Pilates and comparative, Pilates Practice Companion ; Pilates Practice Companion , DK Publishing, 2010. American Council on Exercise: Pilates Primer, Can Pilates Do It All?
Dina Blair, Pilates instructor; athletic director, Concourse Athletic Club, Atlanta. For Furniture! Dori Ricci, NASM, CPT. Idea Health and Fitness Association: Pilates Moves Recruit Deep Abs Better Than Crunches. Pilates Method Alliance: An Exercise in Balance: The Pilates Phenomenon. Reviewed by Ross Brakeville, DPT on February 24, 2016. This tool does not provide medical advice. See additional information.
THIS TOOL DOES NOT PROVIDE MEDICAL ADVICE. It is intended for general informational purposes only and does not address individual circumstances. It is not a substitute for professional medical advice, diagnosis or treatment and milan essays, should not be relied on to make decisions about your health. Never ignore professional medical advice in seeking treatment because of something you have read on the WebMD Site. Resume! If you think you may have a medical emergency, immediately call your doctor or dial 911. Concerning John Sparknotes! View our slideshows to learn more about your health. 2005 - 2017 WebMD, LLC. All rights reserved.
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EMail Privacy Rights In Business Essay Research. Papparizzi Rights Essay Research Paper Does the 4 . Rights Of Privacy In The Private Sector 16 . Computer Privacy Essay Research Paper Computer Privacy 8 . Technology Vs Privacy Essay Research Paper 5 . For Furniture? Privacy Essay Essay Research Paper Privacy 4 . Privacy Essay Research Paper Privacy is something 12 . The Right To Privacy Essay Research Paper 2 . E-Mail Privacy Rights In Business Essay, Research Paper. E-Mail Privacy Rights In Business. E-Mail Privacy Rights in Business. How far we have come in analysis paper such a small time. Resume For Furniture? When you think that the personal computer was invented in life challenge the early 1980’s and by the end of the millennium, several households have two PC’s, it is an resume for furniture astonishing growth rate. Summary Essays Michel? And, when you consider business, I can look around the office and see that a lot of the resume, cubicles contain more than one PC. It is astonishing to me that such an item has taken control over life challenge essay the information technology arena like personal computers. Consider, however, the items that go along with personal computers: printers; modems; telephone lines for your modem; scanners; the software; online access; and lets not forget, e-mail addresses. E-mail, or electronic messaging, has taken over for furniture the communications world as the preferred method of human understanding john, exchanging information. From the simple, “let’s do lunch” messages, to the ability to send a business associate anywhere in for furniture the world an e-mail with an attached document that contains 150 megabytes of information, e-mail is quickly replacing the telephone, the U.S. post-office, and comparative college even overnight delivery services as primary method of exchanging important data.
With the ability to create and send this instant information, the technology has far outpaced the resume, education of how to use this phenomena, the affects of this technology on society, and how to prevent this method of communication from growing itself out of essays michel, existence. For Furniture? Consider the following numbers: ? There were about 23 million e-mail users in 1994. ? There will be approximately 74 millions e-mail users in the year 2000. ? Employees sent approximately 263 billion e-mail messages in 1994. ? Employees will send approximately 4 trillion e-mail message in the year 2000. ? A 1993 study by MacWorld magazine found that 22% of transitions essay, employers have engaged in searches of employer computer files, voice mail, electronic mail, or other network communications. ? The number of people subject to resume for furniture, electronic surveillance at work has increased from list transitions essay approximately 8 million in 1990 to more than 20 million in 1996. ? Nearly 60% of companies that monitor e-mail or other employee communications conceal doing so. ? Less than 20% of companies have a written policy on electronic monitoring. One of the resume, major areas affected by this new technology is corporate America.
Not only is it struggling with how to keep pace with the growing need for fast and efficient e-mail, but also the dangers associated with it. Among these dangers is privacy, in particular, what legal rights corporations and employees have in keeping their communications private. This paper will introduce the current legislation in this area, the expectation of privacy an employee should have, any court decisions that provide additional ruling, and what a corporation can do to prevent litigation in summary michel montaigne these matters. II. Employees Expectation of Privacy in e-mail. As an resume e-mail systems manager, I was under the analysis, impression that since the resume for furniture, company owns the electronic messaging system, the company could view the contents of any employees e-mail account at any time.
I was only partially right. The explanation of the current law will describe this in detail, but, the cover, employee does have a certain right to privacy where e-mail is concerned. Arguably, a company’s most valuable asset is it’s data. For Furniture? In the age of technological marvels, it is easier to essay, create more valuable data and, on the other hand, that data is more easily retrievable, especially by persons not authorized to obtain the data. Employees of companies can expect a certain right of privacy granted by three main sources: (1) The United States Constitution; (2) Federal Statutes (The Electronic Communications Privacy Act of 1986); and (3) State Statutes (many of which have not addressed the issue). The United States Constitution provides a limited group of resume for furniture, employees with privacy safeguards. The safeguards are based on guarantees in the United States Constitution’s Fourth amendment and similar state constitutions. Courts have upheld that the Fourth Amendment’s protection against “unreasonable search and seizures” applies to workplace invasions of privacy. However, this Constitutional protection is limited to governmental intrusions.
Hence, it does not apply to private employers, unless an life essay employee successfully shows “state action.” In Schowengerdt v. Resume? General Dynamics Corporation [823 F.2d 1328, 1332 n.3 (9th Cir. Kundera Essays? 1987).] Schowengerdt held that the employee had a reasonable expectation to privacy in work areas of exclusive use to the employee, such as the employee’s office, unless the employer had previously notified the employee that the employee’s office was subject to a work-related search on a regular basis. The court concluded that despite the employee’s reasonable expectation to privacy in his office that a warrantless search of the office was permissible when it was work-related and reasonable under the circumstances. For Furniture? As the wording of the 4th amendment suggests. it does not protect against all searches, only life, unreasonable searches. Courts have defined unreasonable searches as those against a person who has an expectation of for furniture, privacy which must be protected. This can be shown in United States v. Perkins. [383 F. Supp. 922, 927 (N.D. Ohio 1974)] Employees who lack this reasonable expectation of privacy such as through awareness of publicized monitoring policies, will generally be denied any constitutional protection.
The policy, to be effective, should warn employees that e-mail messages may be audited despite certain system features that give the appearance of transitions, privacy, such as personal passwords and the employee’s ability to delete messages. III. Current Law Pertaining to E-mail Communication. The technology revolution of the e-mail address enabled businesses and private individuals to communicate in resume for furniture ways never before imagined. As with anything, the easier it is, the easier it becomes to do something wrong. With e-mail, this is very evident. In order to prevent wrongdoing and to protect the e-mail user, Congress enacted the Electronic Communications Privacy Act of 1986 (EPCA). [Pub. Concerning John Sparknotes? L. No. 99-508, 100 Stat. 1848 (1986)(codified at 18 U.S.C. ?? 2510-2521, 2701-2710, 3117, 3121-3126 (1988)).] The ECPA amended Title III of the Omnibus Crime Control and resume for furniture Safe Streets Act of 1968, [18 U.S.C. Essay Human Understanding Sparknotes? ?? 2510-2520 (1994).]. The ECPA was passed in response to Congress’ perception that the privacy protection of the 1968 Act was limited to narrowly defined “wire” and resume “oral” communications.
This bill indicated the realization that advancing technology posed potential threats to citizen’s civil liberties and that changes were needed to update the older wiretapping laws. The amendment expanded the scope of Title III to challenge essay, include the interception of “electronic communication” and unauthorized access of stored electronic communications. [18 U.S.C. ? 2510(1), (4), (12), (17) (1994).] E-mail was not specifically mentioned in the ECPA’s definition of “electronic communication”, but, was originally intended to be included. Resume For Furniture? “Electronic communication” is defined as in the ECPA as the “transfer of signs, signals, writing, images, sounds, data, or intelligence of any nature transmitted in whole or in part by a wire, radio, electromagnetic, photoelectronic or photooptical system that affects interstate or foreign commerce. [18 U.S.C. ? 2510(12)(1994). College Essays? While this does not directly mention e-mail, the history of legislative statutes indicates the for furniture, term includes electronic mail, digitized transmissions, and video conferences. [S. Analysis? Rep. No. 99-541, at 14 (1986)]. The ECPA also outlaws the interception of electronic communications. Resume For Furniture? [18 U.S.C. Paper College? ?? 2511(1)(a), 2520 (1994).] The ECPA amended the Federal Wiretap Act’s definition of “intercept” as “the aural or other aquisition of the contents of any wire, electronic, or oral communication.” [18 U.S.C. ? 2510(4) (1994).] The key to resume, this is including “or other” in the definition, since electronic communications cannot be acquired aurally.
Even though electronic communications are now included within the ECPA’s interception clause, the range of protection afforded by the prohibition against interception has been narrowly interpreted by one of the few courts to address the issue. An example of this lies in the decision of the 5th Circuit Court in the case of Steve Jackson Games, Inc. v. United States Secret Service, [36 F.3d 457 (5th Cir. 1994).] In this case, the court decided whether or not the Secret Service’s seizure of a computer that was used to operate an electronic bulletin board system, constituted an essay concerning sparknotes “intercept” of the resume for furniture, stored but unread e-mail contained on the system. Even though the court decided that e-mail can be intercepted, the court decided that the Secret Service’s seizure of the unread e-mail did not constitute an interception. The main reason for this was a distinction between e-mail in “transfer” and challenge essay e-mail in resume electronic storage. The use of the word “transfer” in life essay the definition of “electronic communication,” and resume its omission in that definition of the phrase “any electronic storage of such communication” says that Congress did not intend for “intercept” to apply to “electronic communications” when those communications are in “electronic storage.” This means that there is only a very narrow window of milan essays, time during which an for furniture e-mail interception may occur. This would be the locke, time between the time an e-mail message is sent and the time it is saved to any location designated as storage. So, for for furniture, all intents-and-purposes, interception of e-mail within the prohibition of the ECPA is virtually impossible. The next condition of the ECPA which concerns most employers is its protection against the unauthorized access of electronic communications is electronic storage. [18 U.S.C. ? 2701 (1994).] E-mail in electronic storage includes e-mail which has been temporarily stored following transmission, as well as e-mail which has been stored for backup protection. [18 U.S.C. ? 2510(17) (1994).] This definition would include most e-mail as existing in electronic storage.
So, any protection of employee privacy found in the ECPA will be based upon the unauthorized access provision. The ECPA has built-in exemptions that will protect most employers and protect them against suit. These exemptions are: prior consent, business use, and system provider. 1. Prior Consent. The best protection against liability under the agent, ECPA is when prior consent has been given for any interception or access of e-mail in for furniture electronic storage. Interception of sparknotes, electronic communication is expressly allowed by the ECPA when “one of the parties to the communication has given prior consent.” [18 U.S.C. ? 2511(2)(d) (1994).] Also, access to stored electronic communication is allowed without liability when authorization has been given “by a user of that service with respect to a communication of or intended for that user.” [18 U.S.C. ? 2701(c)(2) (1994).] An easy case to understand here is American Computer Trust Leasing v. Jack Farrell Implement Co. [763 F. Supp. Resume? 1473, 1495 (D. Minn.
1991)]. Summary judgement was granted in this case stating that when the party consented to the access of its computer system, it “cannot now claim that such access was unauthorized.” The key to prior consent is setting policies for corporate e-mail use and notifying employees that they will be monitored. This policy should be corporate-wide and employees that use the system will be judged as giving implied consent upon comparative analysis paper, reviewing the policies and agreeing to the fact that they have read and reviewed the policies. Employers should also be aware that a provision in an e-mail policy which only suggests that monitoring will be done, such as one which reads, “ABC, Inc. reserves the right to for furniture, monitor all e-mail communication,” may not operate to create implied consent. 2. Kundera? Business Use Exemption. Employers may use the business use exemption for interceptions made within the ordinary course of business. The business use exemption is more commonly applied in telephone monitoring cases where improper use of resume for furniture, a business telephone is in question.
Therefore, the provision upon which it is based is unlikely to apply in the e-mail arena. The definition of “intercept” in the ECPA excludes interceptions captured by paper college, “telephone or telegraph instrument, equipment, or facility, or any component thereof, (i) furnished to the subscriber or user by a provider of wire or electronic communication services…being used by the subscriber or user in the ordinary course of resume, business.” [18 U.S.C. ? 2510(5)(a)(i) (1994).] Based on essay this definition, it indicates that telephone or telegraph equipment is necessary for the exclusion to apply. For Furniture? It is even doubtful that the courts will consider a modem to be telephone equipment. There is another clause within the ECPA that allows employers to apply the business use exemption. Section 2511(2)(a)(i) states: It shall not be unlawful under this chapter for an operator of a switchboard, or an officer, employee, or agent of a provider of wire of electronic communication service, whose facilities are used in the transmission of a wire of life challenge, electronic communication, to for furniture, intercept, disclose, or use that communication in the normal course of employment while engaged in any activity which is a necessary incident to the rendition of his service or to the protection of the essay concerning human understanding john, rights or property of the provider of that service. [18 U.S.C. ? 2511(2)(a)(i) (1994).]
For this exemption to resume, apply, the employer would have to essay concerning locke, be classified as a system provider or an for furniture agent of a system provider. Several commentators on the subject have speculated that employers do qualify as system providers. The term provider would likely include public email networks, such as Prodigy and Compuserve, and the term agent may or may not be defined to agent, include employers who subscribe to or use their e-mail service. Companies with their own e-mail systems on their own networks could also fall under this exception as electronic communication service providers. Assuming that an employer does qualify as a system provider, any interception would still need to be made within the ordinary course of business. [18 U.S.C. ? 2511(2)(a)(i) (1994).] Previous case law in telephone call monitoring provides some “stare decisis” for monitoring of employee e-mail in resume for furniture the ordinary course of summary montaigne, business. In both Watkins v. L.M. Berry #038; Co. [704 F.2d 577 (11th Cir. Resume For Furniture? 1983).] and Briggs v. American Filter Co. [630 F.2d 414 (5th Cir.
1980).], the courts decided that if the employer had difficulty controlling personal use of business equipment, then a personal call could be intercepted in the ordinary course of cover desk, business to determine its nature, but not its contents. The employer should be cautious with the business use exception, as the resume, definition of “within the ordinary course of business” is still undefined. 3. System Providers. Where employers provide their own company e-mail system there are two additional thoughts to concerning human john sparknotes, support the non-relevance of the ECPA to them. The first theory is only available for employers with a system whose messages remain entirely intrastate, and is based on the ECPA’s applicability being limited to interstate communications. Under this theory, an intracompany e-mail system, whose messages do not cross state lines and which is resume for furniture not connected to an interstate network, fails to essay john locke, fall under the definition of “electronic communications service,” [18 U.S.C. ? 2510(15) (1994).] and falls outside the protection of the ECPA.
The definition of electronic communications under the resume for furniture, law only pertains to such communication that affects interstate or foreign commerce. However, the action could fall under the Interstate Commerce Clause if it is determined that the essays, activity affects interstate commerce. In Perez v. United States [402 U.S. 146, 152 (1971)] the court stated “that a class of activities can be properly regulated by Congress without proof that the for furniture, particular intrastate activity against which a sanction was laid had an list effect on commerce.” Also, in Wickard v. Filburn [317 U.S. Resume? 111, 125 (1942)], the observation was made that “local activity may be reached by paper, Congress if it exerts a “substantial economic effect on for furniture interstate commerce, irrespective of whether such effect is indirect.” Because the essays michel, Interstate Commerce Clause could pre-empt this theory, the theory appears to have no basis and would be a shaky defense in a court of law. The second theory for exclusion rests upon the ECPA’s clear exemption of for furniture, system providers from its prohibition against access and disclosure of stored electronic communications. [18 U.S.C. ? 2701(c)(1) (1994)] The exception states “Subsection (a) of this section does not apply with respect to conduct authorized (1) by the person or entity providing a wire or electronic communications service.” Although speculation provides that employers should qualify as system providers, there is little legislative history that provides clarity on whether or not Congress intended to exempt private companies who provided their own e-mail system as system providers from the desk, ECPA. Senate Reports on the ECPA acknowledged the existence of internal e-mail, but did not address the law’s affect on those systems. Resume For Furniture? In addition, testimony during the Senate hearings reflected an overriding concern for a company’s rather than an individual’s privacy. Some testimony during the Senate hearings even argued that the proposed legislation should cover all electronic communications. Challenge Essay? Philip Walker, Vice-Chair of the Electronic Mail Association (EMA), stated that, “electronic mail users deserve privacy regardless of resume, what type of kundera, entity runs their system.” [S.
Rep. Resume? No. 99-541 (1986) Hearing on S. 1667 Before the Subcommittee on life challenge essay Patents, Copyrights and Trademarks of the Senate Committee on the Judiciary, 99th Congress 42 (1986)(statement of Senator Patrick Leahy (D-Vermont)).] This uncertainty of Congress has left the door open has left the door open for courts to resume, create a narrow definition of system providers, which could only include public, commercial providers such as America On-line, Prodigy, and Compuserve. Employers should again not depend on cover front the system provider exception, but rather use the business-use or consent exceptions. IV. Case Discussion. In examining case law concerning e-mail privacy, there are a few standard benchmark cases. Most of these cases come from resume California and it is cover no coincidence that this law should develop in for furniture what is considered a technological center of the United States. In California, which has some of the strongest laws protecting individual privacy rights, the courts have been unwilling to enforce promises made by employers to employees that their e-mail messages would be kept confidential. Analysis Paper College? In fact, the California Supreme Court refused to review the case of resume, Alana Shoars v. Epson America Incorporated. In that case Ms.
Shoars, who was the e-mail administrator, told Epson’s employees that their e-mail was confidential. A supervisor subsequently set up a gateway that allowed him to monitor all the employees’ e-mail. When Ms. Shoars learned of this practice she immediately complained to her supervisors, and essays michel montaigne then was fired for “gross insubordination”. For Furniture? The judges in Ms. Shoars case concluded that California privacy laws did not encompass the workplace or e-mail and basically left it in the hands of the legislature. The same result was found in summary montaigne Flanagan v. Epson. [Sup. Resume? Ct.
Cal., Jan. 4, 1991] In this case, an employee brought a class action lawsuit alleging that Epson invaded the employee’s privacy by circumventing their passwords and reading their e-mail messages while advertising a feeling which led the employees to believe their messages were private. The final case interpreting California’s Constitutional right to privacy was Bourke v. Nissan Motor Company. [California Superior Court, Los Angeles County (1991)] In determining whether the right to privacy has been violated, the transitions, court said you must first determine whether the individual had a personal and objectively reasonable expectation of resume, privacy. Nissan argued that there was no reasonable expectation because the employees had signed a Computer User Registration Form, which stated, “it is company policy that employees and contractors restrict their use of transitions essay, company-owned computer hardware and software to for furniture, company business. Essay Understanding? Bourke and Hall countered that they had a privacy expectation because they were given passwords to resume for furniture, access the computer system and were told to safeguard these passwords. The court realized that a subjective expectation of privacy existed, however this was not objectively reasonable. As a result, since there was no reasonable expectation of privacy, there was no violation of the right to privacy. The federal courts seem to kundera essays, have taken the same position. In Smyth v. Pillsbury Corporation, [914 F. Supp. 97 (E.D. Resume For Furniture? Pa.
1996).] a federal court in Pennsylvania ruled this year that Pillsbury Corporation was entitled to essays, fire a manager who had sent e-mail critical of a supervisor, even though the company had explicitly promised it would not monitor e-mail messages. The court reasoned that an employer may not be prevented from firing an employee based upon a promise, even when reliance is demonstrated. The court also quickly dismissed plaintiff’s claims of a tortious invasion of resume for furniture, privacy under common and statutory law. On the writing, other hand, cases involving intrusion are found to not be an invasion of privacy when a legitimate business reason exists for an intrusion. In Vernars v. Young [539 F.2d 966 (3d Cir.
1976).] an employee’s e-mail was opened and read by a fellow employee. A cause of action for resume, invasion of privacy was found in this case. This was because there was no legitimate business reason for the intrusion. V. Preventive Policy Measures. The ECPA signals that the most favorable method for employers to protect against liability is to gain prior consent from employees before monitoring or accessing their business e-mail accounts. Concerning John Locke? What this does is provides a reasonable expectation of privacy (or lack thereof) for employees regarding e-mail. The following issues should be considered when creating policies concerning e-mail practices: ? Consult a lawyer or other employment specialist with expertise in employment and resume for furniture privacy issues in your state. ? Prepare a written policy.
? Include a clear description of the letter front, permissible uses of e-mail. ? Receive verification that the employees have reviewed and agree to the policies. ? Update the policies to change with technology. ? Emphasize and impermissible content for e-mails. ? Clearly state that the e-mail administrators may unintentionally view e-mail during troubleshooting practices. ? Inform employees and independent contractors of resume for furniture, any intent to monitor e-mails. ? State the consequences of misuse of the e-mail system. ? Show flexibility by allowing limited personal use of the milan, e-mail system but clearly define acceptable personal uses. ? Be clear if different standards apply to different classifications of employees/managers.
? Remind employees of any confidential nature of your projects that should not be disclosed in e-mails. ? Clearly describe the times that the monitoring of e-mail will take place. ? Create policies regarding the retention time of resume for furniture, e-mails and life challenge backups of e-mail systems. ? Do not bury the policy in pages and resume for furniture pages of list transitions, policies in for furniture a company handbook. ? Distribute and re-distribute the policy from time-to-time so employees remember it. ? Be consistent and non-discriminatory in your enforcement of the policies. Most companies are flexible and challenge allow for for furniture, employee’s limited personal use of the e-mail system. They simply trust their employees to use good judgement and get their jobs done.
Others either have written policies in place or are planning them. Whether or not you decide to desk agent, have a policy for your company, let the employees and for furniture independent contractors know if you do or do not have a policy. Clear communication is the best way to avoid disputes. It also provides for a more positive working environment. VI. Analysis Paper Essays? Future Privacy Legislation. Several attempts have been made to make the current laws regarding privacy in e-mail more clear and more in line with the resume, technological advances of the late 20th century. In 1993, a bill was introduced by life essay, Senator Paul Simon (D-Ill.) to restrict employer monitoring of e-mail. The bill never came up for resume for furniture, a vote.
The Privacy for Consumers and Workers Act has not been voted on either. This legislation was introduced by Representative Pat Williams (D-Mont.). The PCWA addresses from two perspectives the issue of employer monitoring of employees: electronic monitoring and telephone call accounting. In addressing the issue of electronic monitoring, PCWA can be analyzed in five parts: permitted monitoring, notice of monitoring, prohibited monitoring, data obtained from monitoring, and penalties. Thought has been given to allow technological organizations, such as the essay, Electronic Messaging Association, to govern the resume for furniture, use of kundera essays, e-mail and the privacy that users can expect. Resume? The organization has already adopted rules for the use of e-mail as well as assisted in creating the “ten commandments for e-mail.” Those commandments (there are actually only 7) are: ? Don’t use anonymous remailers. ? Don’t look at other’s messages. ? Don’t misrepresent or lie. ? Follow EMA guidelines.
? Consider presentation of a message. In today’s technologically advanced world, new ideas and inventions are around us on comparative paper a daily basis. A lot of these advances create opportunities for play or even danger. To prevent this action in the workplace, employers are using technology to monitor and keep track of employees and their actions. The level of surveillance being practiced by employers is unprecedented. On both sides, employer and for furniture employee, their must be efforts made to prevent over-abuse by either side. There are both ethical and social responsibilities that need to be shared to keep the technology from overwhelming us. I hope that I have shown that the current law in this area is inadequate and needs to be reviewed.
The current law in this area, the Electronic Communications Privacy Act of 1986, does not satisfactorily address the many problems in list essay writing connection with abuse of e-mail systems by employees or abuse of privacy issues by employers. The Federal Court of Appeals for the Fifth Circuit has commented that the ECPA is simply not clear and is too broad to be effective. One of the main reasons for this is that the ECPA is simply an amended version of the 1968 federal wiretap law which was originally adopted to deal with telephone eavesdropping. Those laws do not significantly address the changes in technology that provide the wonder of e-mail. With the current legislation being ambiguous, and no new legislation yet passed, the for furniture, next best solution is encouraging employers to implement a clear e-mail policy. All employees should receive a copy and analysis paper college be required to sign a form which acknowledges the fact they have read the details of the company’s policy. This should not be considered a permanent solution to resume for furniture, the problem of e-mail privacy. It is only a temporary solution that will keep employees and employers on the same page regarding the expectation of corporate behavior as far as e-mail is involved.
ACLU. (September, 1996). SURVEILLANCE INCORPORATED: American Workers Forfeit Privacy for a Paycheck. [On-Line]. Available: http://aclu.org/library/wrrpt96.html. AFTAB. Monitoring Employees’ Electronic Communications: Big Brother or Responsible Business? [On-Line].
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