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HORN’s
Privacy Policy
Effective January 1, 2004, Ontario businesses
became subject to the requirements of the
Personal Information Protection & Electronics
Documents Act (PIPEDA). As defined by the
PIPEDA, personal information consists of any
factual or subjective information, recorded
or not, about an identifiable individual.
Personal information does not include your
job title, telephone number or address (anything
that might appear on your business card, or
can be found through publicly available information
such as the telephone book).
The privacy act does not cover an individual’s
name, title, business address or telephone
number; or the collection, use or disclosure
of personal information strictly for personal
purposes (e.g. personal greeting card list);
and, the collection, use or disclosure of
personal information solely for journalistic,
artistic or literary purposes.
In accordance with the ten principles of
privacy as set out in schedule 1 of the Act,
HORN has adopted its own privacy policy so
as to ensure an honest and lawful commitment
to respecting the personal privacy of the
individuals we conduct our business with.
The aforementioned principles, and HORN’s
policy regarding them, are as follows:
Accountability
Our organization is responsible for the personal
information under its control and has designated
a privacy officer to be accountable for the
organization’s compliance with the legislation’s
privacy principles.
Identifying Purposes
Personal information is collected by HORN
for the express purpose of helping to inform
our client development initiatives and to
help us formulate answers to the questions
that our clients ask us in various consulting
projects.
Consent
HORN does not obtain personal information
without the consent of the individual in question.
The knowledge and consent of the individual
are required for the collection, use or disclosure
of personal information, except where inappropriate.
Demonstrations of consent are part of all
relevant documents and contracts.
Limiting Collection
The collection of personal information shall
be limited to that which is necessary for
the purposes identified by the organization.
Information shall be collected by fair and
lawful means.
Limiting Use, Disclosure and Retention
Personal information shall not be used or
disclosed for purposes other than those for
which it was collected, except with the consent
of the individual or as required by law. Personal
information shall be retained only as long
as necessary for the fulfillment of those
purposes. Personal information is never released
to third parties.
Accuracy
Personal information shall be as accurate,
complete, and up-to-date as is necessary for
the purposes for which it is to be used. Concerns
over accuracy should be directed to HORN’s
privacy officer, who will ensure that any
inaccurate information is updated.
Safeguards
Personal information shall be protected by
security safeguards appropriate to the sensitivity
of the information. At the conclusion of each
project, HORN erases the personal information
of all individuals from the relevant documents.
Openness
We shall make readily available to individuals
specific information about our policies and
practices relating to the management of personal
information.
Individual Access
Upon request, an individual shall be informed
of the existence, use, and disclosure of his
or her personal information and shall be given
access to that information. An individual
shall be able to challenge the accuracy and
completeness of the information and have it
amended as appropriate. The location of personal
information shall be recorded so as to ensure
a timely retrieval. A request for access shall
be responded to within 30 days. All requests
for access should be directed to HORN’s
privacy officer. The grounds for denial of
access are laid out in section nine of the
act.
Challenging Compliance
An individual shall be able to address a challenge
concerning compliance with the above principles
to the designated individual or individuals
accountable for the organization’s compliance.
All questions and concerns regarding HORN’s
policy in this area should be directed to
Lisa Tomassetti, HORN’s privacy officer,
at 905-761-8000 ext 228.
Further information about the PIPED act, including
the rights and responsibilities of individuals
as well as organizations, can be viewed online
at www.privcom.gc.ca
or www.ipc.on.ca.
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