Revision Date: September 1, 2019
Revision Number: 1
2. The Company recognizes the confidential nature of the Personal Information in its care and is accountable for the compliance of itself and its directors, officers, management, s, representatives and agents including consultants and independent contractors (the “Staff”) in protecting this Personal Information.
4. Personal Information includes but is not limited to name, home address, home phone number, home email address, identity verification information, Social Security Number, physical description, age, gender, salary, education, professional designation, personal hobbies and activities, medical history, employment history, credit history, contents of resume, references, interview notes, performance review notes and emergency contact information.
5. Personal Information will not include the Individual’s business title, and business address and contact information when used or disclosed for the purposes of reasonable business communication.
7. The Company and the Staff will at all times respect the confidentiality of the Personal Information placed in its care. The Company will endeavor to ensure that the policies affecting the collection, storage and disclosure of Personal Information reflect the confidential nature of the information.
8. The Company will comply with all applicable privacy legislation and regulations in force now and in the future related to protecting the confidentiality of Personal Information.
Purposes for which Personal Information is Collected
9. Personal Information will be collected, used and disclosed for purposes pertaining to the Individual’s relationship with the Company, including but not limited to establishing contact regarding services provided by the Company.
10. The purposes for collecting Personal Information will be documented by the Company. Personal Information will only be used for the stated purpose or purposes for which it was originally collected.
11. The Company may use Personal Information for a purpose other than the originally stated purpose where the new purpose is required by law or where the Company has obtained consent orally or in writing from the affected Individual for each new purpose.
Knowledge and Consent
13. Consent will not be obtained through deception or misrepresentation.
14. Any use or disclosure of Personal Information will be within the reasonable expectations of the Individual.
15. Subject to legal and contractual obligations, an Individual may withdraw their consent on reasonable notice.
Legislation and Regulation
16. Where the Company has Individuals living and working in different jurisdictions the specific rights and obligations of Individuals may vary between jurisdictions.
Scope and Application
Collection of Personal Information
20. The type and amount of Personal Information collected by the Company will be limited to the minimum necessary to accomplish reasonable business purposes. Personal Information will not be collected maliciously, indiscriminately or without a reasonable business purpose.
21. Personal Information will be collected using fair and lawful means.
Access by Authorized Company Representatives
22. All Personal Information will be released internally only on a need-to-know basis. In the course of normal and reasonable business practices it is the policy of the Company to grant designated Company representatives access to Personal Information files. This access will not exceed that necessary to accomplish the specific business function of the Company representative nor the purpose for which the information was originally collected.
Accuracy of Personal Information
23. The Company will endeavor to ensure that all Personal Information collected is accurate and validated using reasonable business practices and procedures. The Company is also committed to ensuring that the Personal Information remains accurate for the purpose for which it was collected.
Rights of Access and Correction
24. The Company will make reasonable efforts to ensure that Personal Information is at all times complete and accurate for its stated purpose.
26. The Personal Information disclosed to an Individual must be in a form that is reasonable and understandable. Where the meaning of information is not clear then translations and explanations will be provided without additional cost.
27. Where an Individual suspects that an error exists in their Personal Information, the Individual may submit a request in writing for correction. This request should include any relevant information substantiating the error and should describe the correction to be made. The Company will make all reasonable efforts to address any request for correction.
28. Where the Individual successfully demonstrates an error in their Personal Information the Company will make appropriate corrections. Any modifications, additions or deletions to the Individual’s Personal Information will be made only by an authorized personnel officer.
29. Where a request for correction is not successful, the details and substantiating evidence of the request will be recorded and retained by the Company.
30. The Company will endeavor to respond promptly to any reasonable request for disclosure and correction made by an Individual to ensure the continued accuracy of Personal Information.
31. In some instances the Company may be required to limit access to Personal Information because of statutory or regulatory requirements. In all instances however the Company will make all reasonable efforts to comply with the Individual’s request for access and correction to the extent of what is allowed by statute or regulation.
32. The Company may refuse access to portions of the Personal Information of an Individual where it is found to contain Personal Information pertaining to another Individual.
Use and Disclosure of Personal Information
33. The Company and the Staff will keep confidential all Personal Information in its control except where one or more of the following conditions apply:
a. where the Individual who is the subject of disclosure has provided written consent;
b. where the disclosure is in accord with the purposes for which the Personal Information was originally collected;
Ownership of Personal Information
Retention and Disposal of Personal Information
35. Personal Information that is no longer needed for its stated purpose will be destroyed, erased or made anonymous.
36. The Company will ensure that all practices and procedures relating to the disposal of Personal Information will respect the fundamental policy of confidentiality. All Personal Information disposal procedures, including the disposal of computerized data storage devices, will ensure the complete destruction of Personal Information so that there will be no risk of subsequent unauthorized disclosure of Personal Information.
37. The rights and protections of the Company’s Privacy Policies will extend to deceased Individuals.
38. The Company will take and enforce all reasonable security measures appropriate for the sensitivity of the information to ensure that all Personal Information for every Individual is protected against any form of unauthorized use including but not limited to accidental or malicious disclosure, unauthorized access, unauthorized modification, unauthorized duplication or theft.
39. Methods of security may include but not be limited to the following:
a. physical security including locked filing cabinets and secure-access offices;
b. organizational security including security clearances and access limited on a “need-to- know” basis and
c. technological security including passwords and encryption.
Knowledge of Unauthorized Disclosure
41. Responsibility for the security of Personal Information is a responsibility that the Company holds in very serious regard. Any Staff having knowledge of an impending unauthorized disclosure, whether intentional or unintentional, and who fail to act to prevent the unauthorized breach will be subject to sanction as described in the Enforcement section of this document including the immediate dismissal of the offending Staff.
Mediation and Arbitration
46. If the dispute is not resolved within a reasonable period then any or all outstanding issues may be submitted to mediation in accordance with any statutory rules of mediation. If mediation is not successful in resolving the entire dispute or is unavailable, any outstanding issues will be submitted to final and binding arbitration in accordance with the laws of the state the Company is headquartered from. The arbitrator’s award will be final, and judgment may be entered upon it by any court having jurisdiction within the state of headquarters of the Company.