We work to protect our clients’ privacy and safeguard their personal information, and are in full compliance with Canada’s Personal Information Protection and Electronic Documents Act, PIPEDA, which came into effect on January 1, 2001. This act sets the ground rules for how Canadian businesses and non-profit organizations may collect, use and disclose personal information.
We inform our clients why and how we collect, use and disclose personal information; obtain their consent where required.
Canada’s Personal Information Protection and Electronic Documents Act, PIPEDA outlines the principles and practices we follow to protecting clients’ personal information. Our commitment to privacy ensures accuracy, confidentiality, and the security of our clients’ personal information and allows our clients to request access to and correction of their personal information.
Scope of this Policy:
This Personal Information Protection Policy applies to Flex Point Security.
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Flex Point Security.
Cookies – cookies are a mechanism for storing information such as usage history and input content sent and received between the user’s browser and the server when a user accesses a web page, stored as a file on the user’s computer. Subsequent access to the same page, allows the browser to use the information in the cookie to change the display for the user.
Personal Information – means information about an identifiable individual E.g., including name, age, home address and phone number, social insurance number, marital status, religion, income, credit history, medical information, education, employment information. Personal information does not include contact information (described below).
Contact Information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPEDA.
Privacy Officer – means the individual designated responsibility for ensuring that Flex Point Security complies with this policy and PIPEDA.
Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the client and/or customer voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect client and/or customer information that is necessary to fulfill the following purposes:
– To complete a sale/transaction
– To deliver requested products and services
– To ensure a high standard of service to our clients and/or customers
– To understand the needs of our clients and/or customers
– To open and manage an account – customer relationship management
– To contact our clients and/or customers for upcoming events, contests, surveys or workshops
– To meet regulatory requirements
2.1 We will obtain client/customer consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided e.g., orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client/customer voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client/customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products and the client/customer does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients/customers can withhold or withdraw their consent for the Flex Point Security to use their personal information in certain ways. A client’s/customer’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client/customer in making the decision.
2.5 We may collect, use or disclose personal information without the client’s/customer’s knowledge or consent in the following limited circumstances:
A full listing of such circumstances can be found in section 7 of PIPEDA. Some examples include:
– When the collection, use or disclosure of personal information is permitted or required by law;
– In an emergency that threatens an individual’s life, health, or personal security;
– When we require legal advice from a lawyer;
– For the purposes of collecting a debt;
– To investigate an anticipated breach of an agreement or a contravention of law
Using and Disclosing Personal Information
3.1 We will only use or disclose client/customer personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
– To conduct client, customer, member surveys in order to enhance the provision of our services;
– To contact our clients/customers directly about products and services that may be of interest;
3.2 We will not use or disclose client/customer personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client/customer lists or personal information to other parties [unless we have consent to do so].
Retaining Personal Information
4.1 If we use client/customer personal information to make a decision that directly affects the client/customer we will retain that personal information for at least one year so that the client/customer has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client/customer personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that client/customer personal information is accurate and complete where it may be used to make a decision about the client/customer or disclosed to another organization.
5.2 Clients/customers may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
A request to correct personal information should be forwarded to the Privacy Officer at [email protected]
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’/customers’ correction request in the file.
Securing Personal Information
6.1 We are committed to ensuring the security of client/customer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that client/customer personal information is appropriately protected:
– Restricting employee access to personal information as appropriate (i.e., only those that need to know will have access.
– With regards to paper files, a locked filing cabinet will be utilized, in a restricted area with an alarm system activated.
With regards to electronic files the following security measures will be followed to ensure that client’/customer personal information is appropriately protected:
– Computer passwords will be utilized on each computer/workstation/device containing personal information
– Encrypted data files
– Encrypted personal information that is sent or received over the Internet (by email or through web forms)
– Electronic audit trails that identify who has access information
– Keeping backup files in a locked cabinet, in a restricted area with an active alarm system.
6.3 We will use appropriate security measures when destroying clients’/customers’ personal information such as:
– shredding paper documents
– deleting electronically stored information
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Providing Clients/Customers Access to Personal Information
7.1 Clients/customers have a right to access their personal information, subject to limited exceptions.
A full listing of the exceptions to access can be found in section 9 of PIPEDA. Some examples include:
– solicitor-client privilege
– disclosure would reveal personal information about another individual
– health and safety concerns.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer at [email protected]
7.3 Upon request, we will also tell clients/customers how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client/customer of the cost and request further direction from the client/customer on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the client/customer in writing, providing the reasons for refusal and the recourse available to the client/customer.
Questions and Complaints: The Role of the Privacy Officer or Designated Individual
8.1 The Privacy Officer is responsible for ensuring the Flex Point Security’s compliance with this policy and the Personal Information Protection and Electronic Documents Act.
8.2 Clients/customers should direct any complaints, concerns or questions regarding the Flex Point Security’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client/ customer may also write to the Office of the Information and Privacy Commissioner of Ontario.
Contact information for the Flex Point Security’s Privacy Officer: [email protected]