The Company is committed to protecting the privacy of personal information. Personal information is collected, used, maintained, and disclosed in compliance with applicable federal and provincial privacy legislation including, but not limited to, the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”).
The personal information that you are asked to provide, and the reasons why you are asked to provide it, will be made clear to you at the point we ask you to provide your personal information.
All employees and contractors of the Company are accountable for safeguarding and maintaining the privacy of all personal information under their control. Our accounting, compliance and client service personnel are all aware, and ensure, that personal information, when requested, is only supplied to people who are expressly authorized by the client employee or contractor, as the case may be, to receive it. Our systems identify whether there are any such authorized recipients other than the client or employee, as the case may be. To maintain awareness of our policies and practices in this regard, annually all of our employees and contractors sign an Annual Confirmation of Compliance affirming this undertaking.
Personal information can only be used for the purposes for which it is collected. Specific permission must be sought if personal information is to be used for any other purpose than that for which it was initially collected.
The Company has a centralized records and archives management process for the collection, management, retention, and disposition of personal information. Categories of individuals for which personal information is being collected and maintained include employees, contractors, and clients.
Personal employee information is contained in paper and/or electronic records at the Company’s permanent place of business and is the property of the Company. Personal employee information that is contained in electronic records may also be stored, collected, or manipulated outside of Canada and may be subject to the laws of that jurisdiction. All personal information stored, obtained, compiled, maintained, and disclosed to the Company by third party agents and contractors must comply with applicable federal/provincial privacy legislation. Contractual provisions requiring such compliance must be incorporated into all third-party agent and contractor agreements. All individuals have controlled access to their personal information.
The Company is responsible for personal information in its control, which means information, whether factual or subjective in nature,about an identifiable individual. It includes, but is not limited to, health and financial information, such as:
· name and age;
· address, telephone number and e-mail address;
· medical records;
· identification number (such as Social Insurance Numbers);
· income, assets, and transaction information;
· opinions, evaluations, and comments; and
· credit records and loan records.
The name, title, and business address or telephone number of an employee or contractor in any organization/business is not considered personal information requiring consent prior to sharing with others as this information is available for the general public.
SMS opt-in and Phone Numbers for the purpose of SMS will not be shared with third parties and affiliates for marketing purposes.
The Company will follow the ten principles for handling personal information as set out in Schedule 1 of PIPEDA. These principles are:
· accountability
· consent
· limiting use, disclosure, and retention
· safeguards
· individual access
· identifying purposes
· limiting collection
· accuracy
· openness
· provision of recourse.
The intent of the Privacy Policy is to provide the Company’s employees and contractors with requirements concerning compliance with the privacy legislation and guidance as to what is required in order to comply with its provisions as it relates to the Company. The goal is to raise awareness of the nature of the requirements and their effect on the day-to-day business and to educate individuals as to what the various obligations entail.
Protecting the confidentiality and security of our clients’ and employees’ personal information is an integral part of our corporate values. If you wish to know more about our privacy policies, please call 1-877-4CYCLIC.
