Effective Date: January 1, 2014
This Policy is designed to comply with Canada’s Privacy Act and the principles of natural justice.
- Use of Personal Information:
We can only use your personal information for the purpose for which it was obtained or for a use consistent with that purpose, or for a purpose listed in Section 8 of Canada’s Privacy Act. We only collect personal information that is directly related to one of our programs or activities. Wherever possible, such information will be collected directly from the individual about whom it pertains. The amount and the type of the information collected will be limited to that which is needed to fulfil the identified purpose(s). We only collect what we need.
We may for example, collect your name, contact information, and the status of your — or your own client’s — company’s profile on the web to offer advice and pricing to solve your particular problems. Like most sites, Google Analytics code on each of our website pages uses “cookies” (tiny pieces of code) to track your path through our site and to convey other marketing information, such as your current city, the type of technology you are using, etc. While your personal identity remains unknown to us, comparing the browsing patterns from many anonymous visitors can reveal priorities and paths through our website that can inspire design changes to reduce visitor efforts to reach their desired information. For more information about Google’s policies, visit:
- Access Restrictions:
We will not disclose your personal information without your consent unless it is allowed under section 8(2) of the Privacy Act. In this case, we will aim to disclose only the specific information that is needed under the circumstances and, wherever possible, will inform you about the disclosure.
Access to personal information within AlterMedia will be restricted to those staff members who need the information in order to carry out their job duties. Those employees will maintain the information in the strictest of confidence and will not provide access to the information to anyone who is not authorized. The level of staff access to personal information will be granted on a need-to-know basis.
All individuals we hire under contract or other means to conduct business on our behalf will be required to respect the provisions of the Privacy Act as well as this Policy and related internal procedures. Violations of any part of the contractual agreement may result in termination of the contract.
- How We Protect Your Personal Information:
In any organization, failure to protect personal information can increase the risk of a privacy breach. These privacy breaches can lead to things such as reputational harm, fraud or identity theft.
We will protect personal information from loss or theft, unauthorized access, use or disclosure, modification or destruction through appropriate administrative, technical and physical security measures and safeguards.
The level of safeguards used to protect personal information will depend on the:
sensitivity of the personal information;
amount, distribution and format of the information;
method of storage.
- Your Consent:
Wherever possible, we seek a person’s consent before we collect their personal information. The form of consent may vary depending on the circumstances and the type of information being requested. Consent can be express or implied, and can be provided directly by the individual or by an authorized representative.
Express consent is preferred. Express consent can be given orally, electronically or in writing. Implied consent may be reasonably inferred from a person’s action or inaction. For example, providing a name and address to receive a report or providing a name and telephone number to receive a response to a question. When determining the appropriate form of consent, we take into account the sensitivity of the personal information, the reasons we are collecting it, and the reasonable expectations of the person. When using personal information for a new purpose, we will document that new purpose and ask for consent again.
We will not use your personal information without your consent unless it is either:
for the same purpose for which the information was originally collected or compiled,
consistent with that purpose,
for a purpose that may be disclosed under section 8(2) of the Privacy Act.
- Retention Of Information
Given that our clients typically subscribe for a long period of service, or re-commission our work within four years of ending relations, information may be retained for similarly long durations, providing records of problems and solutions that can greatly help future responses, should you or your estate contact us again.
- Review Or Corrections To Personal Information:
You have the right to formally request access or corrections to your personal information digitally retained by AlterMedia. Copies of this can be provided to you via electronic files transmitted to email accounts that are verified (to our satisfaction) as being accessed by you. Alternately, should you wish this data placed on electronic media, we can do this as long as you provide the media (freshly purchased, unopened, and of a type our office can reasonably utilize) and sufficient self-addressed pre-paid envelopes. In either case, the data will typically be saved as a password-protected archive (ZIP file) and/or password-protected PDFs, with the access password conveyed by phone or alone in a separate email.
Should you wish to correct any inaccurate or outdated personal information held by AlterMedia, we will respond favourably to any specific requests, subject to verification that your identity matches that of our records, and that the request does not conflict with historical facts known to us through other trusted documentation. A 30-day response time to gather and transmit the data is considered a reasonable maximum in most situations.
If you have any questions about this Policy, or how we manage personal information, or you experience conflicts in our staff’s handling of your personal information review or corrections, you are welcome to call us at 416-296-9290 or email us via the form on the Contact page.