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Privacy Policy
The Employers’ Choice Inc. (“TEC”)
is a human resources management consulting firm that provides advice,
programs, human resources outsourcing, and training to employer
clients.
Our employees hold various human resources professionals’
designations by recognized authoritative bodies and their activities
may be governed by outside professional codes of conduct and standards
of practice. Consistent with our obligations as professionals, we
are dedicated to maintaining high standards of confidentiality with
respect to the information that has been provided to us.
In addition to existing professional obligations,
TEC is committed to ensuring that all handling of personal information
occurs in compliance with applicable privacy legislation including
the Personal Information Protection and Electronic Documents Act.
This Privacy Policy (the “Policy”) has been prepared
to communicate the principles, guidelines and practices that flow
from our commitment to protecting the privacy of the personal information
of our clients, their employees, service providers and other individuals.
In particular, the Policy addresses the following:
- The Professional
Relationship
- The Definition
of Personal Information
- Collection of
Personal Information
- The Types of Personal
Information we collect
- Disclosure of
Personal Information
- Consent
to Collection, Use and Disclosure
- Storage, Security
and Protection of Personal Information
- Retention of Personal Information
- Access and Accuracy
- Privacy and Electronic Communication
- Changes to the Privacy
Policy
- Questions and Further
Information
1. The Professional
Relationship
As a general rule, all information concerning
the business, the employee make-up of the business and/or affairs
of an employer acquired either for the purpose providing proposals
or fee estimates or in the course of providing services shall be
held in strict confidence and will not revealed to anyone unless
expressly or implicitly authorized by the person or organization
concerned.
A professional relationship develops when TEC
has determined that it is appropriate to offer services to a particular
client and the client has agreed to retain the services of TEC.
It is TEC’s practice to provide proposals and time estimates
for every project and to obtain a consent and acknowledgement before
beginning any work.
2.
The Definition of Personal Information
Canadian privacy legislation defines “Personal
Information” broadly as information about an identifiable
individual or as information that allows an individual to be identified.
For the purposes of this Policy, Personal Information means information
about an identifiable individual as defined from time to time in
applicable privacy legislation. Generally speaking, Personal Information
does not include what is considered business contact information;
i.e. an individual’s name, title or position, business address,
telephone number, facsimile number, and e-mail address.
3.
Collection of Personal Information
TEC collects, uses and discloses Personal Information
about our clients, employees of clients, and service providers in
order to provide clients with consulting services. Personal Information
is also collected, used and disclosed for client communication,
marketing and internal professional development purposes. More specifically,
we collect, use and disclose Personal Information for the following
purposes:
- to establish and manage client relationships,
provide services, and avoid conflicts of interest;
- to analyze in order to make specific recommendations for changes
to employer practices;
- to organize and prepare Personal Information for submission
to third parties designated and approved by clients. Such third
parties may include the client’s legal counsel, accountants,
group benefit providers, compensation surveyors, pension investment
managers, authoritative governing bodies, and payroll services;
- to establish and maintain commercial relationships with clients,
suppliers and other third parties, including to issue invoices,
administer accounts, collect and process payments, and to fulfil
contractual obligations;
- to understand and respond to client, supplier and other third
party needs and preferences, including to contact and communicate
with such parties and to conduct surveys, research and evaluations;
- to distribute our Employers’ Edge newsletters, seminar
information and other material to individuals on our mail and
e-mail lists;
- to develop and manage our knowledge-management precedent systems
and databases;
- to develop and manage TEC’s business and operations;
- to detect and protect TEC and other third parties against error,
negligence, breach of contract, fraud, theft and other illegal
activity, and to audit compliance with TEC’s policies and
contractual obligations;
- as permitted by, and to comply with, any legal or regulatory
requirements or provisions; and
- for any other purpose to which you consent.
4. The
types of Personal Information we collect
The types of Personal Information that TEC may
collect include an individual’s name, home address, telephone
number, personal e-mail address, and billing and account information.
In addition, in the course of providing services, we may collect
or be exposed to a wide variety of information about a client’s
employees and job applicants including social insurance numbers,
health insurance numbers, education and training courses taken,
group insurance policy application and claim numbers, chequing account
numbers, personal health information, health and safety records,
workers’ compensation claim information, results of a self-identification
study as may be reported under an employment equity program, credit
history, compensation information, individual performance data,
and shareholder status.
We do not sell, trade, barter or exchange any
information obtained, including and especially any information obtained
in the course of professional relationships.
5.
Disclosure of Personal Information
In the course of providing services, TEC may
disclose Personal Information to:
- service providers, including an organization
or individual retained by TEC to perform functions on its behalf,
such as marketing, data processing, document management and office
services;
- an organization or individual retained by TEC to evaluate your
creditworthiness or to collect debts outstanding on an account;
- a financial institution, on a confidential basis and solely
in connection with the assignment of a right to receive payment,
the provision of security or other financing arrangements;
- a person who, in the reasonable judgment of TEC, is providing
or seeking the information as your agent; or
- any third party or parties, where you consent to such disclosure
or where disclosure is required or permitted by law.
6.
Consent to Collection, Use and Disclosure
By submitting Personal Information to TEC or
its service providers and agents, you agree that we may collect,
use and disclose such Personal Information in accordance with this
Privacy Policy and as permitted or required by law. Subject to legal
and contractual requirements, you may refuse or withdraw your consent
to certain of the identified purposes at any time by contacting
TEC’s Chief Privacy Officer identified below. If you refuse
to consent or withdraw your consent, we may not be able to provide
you or continue to provide you with certain services or information
which may be of value to you. If you provide TEC or our service
providers and agents with Personal Information of another individual,
you represent that you have all necessary authority and/or have
obtained all necessary consents from such person to enable us to
collect, use and disclose such Personal Information for the purposes
set forth in this Privacy Policy and in accordance therewith.
There are circumstances where collection, use
or disclosure may be justified or permitted or where we are obliged
to disclose information without consent. These circumstances could
include:
- Where the information is publicly available;
- Where required by law or by order of a court or tribunal;
- Where we believe, upon reasonable grounds, that there is an
imminent risk of death or serious bodily harm to an identifiable
person or group;
- Where it is alleged that a partner, associate or employee of
TEC is guilty of a criminal offence or guilty of malpractice or
misconduct;
- Where it is necessary to establish or collect fees.
In such circumstances, we will not collect, use
or disclose more information than is required.
7.
Storage, Security and Protection of Personal Information
TEC endeavours to maintain adequate physical,
procedural and technical security with respect to our offices and
information storage facilities so as to prevent any unauthorized
access, disclosure, copying, use or modification. Your Personal
Information is stored in secured locations and on servers controlled
by the owners of The Employers’ Choice Inc., located either
at our office or at the offices of our services providers. To help
protect the confidentiality of your Personal Information, TEC employs
physical, administrative and technological safeguards appropriate
to the sensitivity of your Personal Information. For instance, we
operate secure data networks protected by industry standard firewall
and password protection systems. In addition, where Personal Information
is sent to a third party for processing, we make sure, through our
contracts with such third parties, that all Personal Information
is kept secure.
8. Retention
Because of the nature of the professional relationship and the services we provide it is our practise to retain paper versions of our files and the Personal Information contained therein for three (3) years, unless for legal purposes it is required to be retained for longer periods. Paper files are shredded by qualified outside vendors. Electronic data will be stored for a minimum of seven (7) years. This retention policy has developed for the convenience of our clients, many of whom have expressed their expectation that we retain our copies of their files many years after the services we have provided have been performed and completed in case they require access in the future.
9. Access and
Accuracy
Access requests should be sent to our Chief Privacy
Officer, using the contact information provided below. Upon receiving
a written request and subject to any applicable exemptions, TEC
will inform you of the existence, use, and disclosure of your Personal
Information and will give you access to that information and the
opportunity to correct any inaccurate Personal Information that
is in the possession of TEC. TEC endeavours to maintain the accuracy
of any information in its possession, with respect to active matters.
Information contained in closed files is not actively updated or
maintained.
We encourage our clients and other individuals
to make efforts to advise TEC of any changes in the information
that we have in our possession.
10.
Privacy and Electronic Communication
- Exchange of Information Via E-mail - TEC does
not guarantee the confidentiality of any communications made by
you via e-mail or otherwise through our website and cannot guarantee
that any such communications are confidential. If you wish to
provide information of a confidential or sensitive nature to TEC,
please contact your TEC representative directly by telephone to
arrange for delivery/transmission of such information by secure
means.
- Distribution Lists By virtue of the nature of our contacts
the human resources field, TEC has created an e-mail distribution
list in order to circulate employment opportunities in the HR
field, or information regarding upcoming training or events or
services available. The positions circulated may or may not be
opportunities within TEC or with one of TEC’s retained
clients. Anyone in the general public may elect to join this distribution
list at any time. Any individual consenting to be on this list
consents to receiving information about employment opportunities,
information regarding upcoming training or events or services
available. Any individual on the list may request removal at any
time.
- Web Site - In order to provide our website visitors with a
service or information, visitors may voluntarily submit Personal
Information to us via email for purposes such as asking a question,
obtaining information, reviewing or downloading a publication
or participating in a seminar or other event. Occasionally, we
may send marketing or promotional e-mail communications to you
with information that may be useful.
- Cookies - In browsing the Internet, you will encounter a technology
called "cookies" which can be used to provide you with
specific information from a Web site. A "cookie" is
an element of data that a Web site can send to your browser, which
may then store it on your system. TEC’s website does not
currently use cookies.
- Links - Our website may contain links to other websites which
are provided as a convenience only. Visitors are advised that
other third party websites may have different privacy policies
and practices than TEC, and TEC has no responsibility for such
third party websites.
11.
Changes to the Privacy Policy
TEC reserves the right to modify or supplement
this Policy at any time. If we make a change to this Policy, we
will post such changes on our website and make such revised policy
and changes available upon request to TEC’s Chief Privacy
Officer. However, TEC will obtain the necessary consents required
under applicable privacy laws if it seeks to collect, use or disclose
your Personal Information for purposes other than those to which
consent has been obtained, unless otherwise required or permitted
by law.
12.
Questions and Further Information
Any question concerning the management of their
Personal Information, should first be addressed by the client to
the lawyer responsible for the client’s legal affairs. In
addition, TEC has appointed a Chief Privacy Officer to oversee compliance
with this Policy and applicable privacy laws. Any questions related
to this Policy or the handling of Privacy Information by TEC can
be addressed with the Privacy Officer at the contact information
below:
CHIEF PRIVACY OFFICER
The Employers’ Choice Inc.
2 County Court Blvd.
Suite 430
Brampton, Ontario L6W 3W8
If you are not satisfied with TEC’s response
to a privacy related matter, you may contact the Office of the Privacy
Commissioner of Canada at 1-800-282-1376 or at www.privcom.gc.ca.
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