he Walter Fedy Partnership (TWFP) is committed to respecting the privacy rights of our customers by ensuring that their personal information is collected, used and disclosed according to the Personal Information Protection and Electronic Documents Act (PIPEDA).
The PIPEDA came fully into force on January 1, 2004. This legislation establishes rules and principles for the use and disclosure of personal information based on ten privacy principles developed by the Canadian Standards Association. Under the new legislation, an organization may collect, use or disclose personal information only for limited purposes that a person would consider to be appropriate depending on the circumstance. Personal information means any information about an individual that relates to their personal characteristics (i.e. gender, age, weight, height, income, property, home address or phone number, social insurance number, ethnic background, education, family status), their health (i.e. health history, health conditions, health services received by them) or their activities or views (i.e. opinions expressed by an individual, religion or political involvement). Personal information does not include the name, title, business address or telephone number of an employee of an organization.
The Ten Privacy Principles to which TWFP is Committed
1. Accountability
TWFP is responsible for maintaining and protecting your personal information while it is under our control. This includes any personal information that may need to be disclosed to third parties for processing or other administrative functions.
To help ensure the confidentiality of your personal information, we have established policies and procedures to ensure that we comply with the PIPEDA. We have designated Eva Steininger as TWFP's privacy officer who is responsible for our company's compliance with the PIPEDA. If you have any questions or inquiries about how your personal information is stored, or when it may need to be disclosed to others, our privacy officer will be happy to assist you.
2. Identifying Purposes
Before or when we collect information from you, we will explain how we intend to use it. Unless required by law, TWFP will not use or disclose any personal information that has been collected without documenting the new purpose and obtaining your consent. Common purposes for collection include:
- Information required for billing purposes
- Ensuring that the customer information is accurate and up-to-date
- Information required for insurance renewals
- Identifying project team members
- Identifying subconsultants.
3. Consent
TWFP will obtain your consent if we need to use or provide your information to third parties.
However, in certain circumstances, personal information may need to be collected, used or disclosed without the knowledge and consent of the individual. For example, legal, medical, or security reasons may make it impossible or impractical to seek consent.
The PIPEDA recognizes that when information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of an individual may defeat the purpose of collecting the information.
In obtaining your consent, we will always use reasonable efforts to ensure that you are advised of the identified purposes for which any personal information collected will be used or disclosed.
4. Limiting Our Collection of Personal Information
We will only collect personal information for specific, legitimate purposes. We will not collect personal information indiscriminately.
We will only collect information by fair and lawful means and not by misleading or deceiving individuals about the purpose for which information is being collected.
5. Limiting Use, Disclosure, and Retention
Personal information will not be used or disclosed for purposes other than for which it was collected, except with your consent or as permitted or required by law. Your personal information will be retained only as long as it is necessary to fulfill those purposes.
Under certain circumstances, TWFP may have a legal duty or right to disclose personal information without the individual's knowledge or consent. An example of this disclosure would include subpoenas and other court or government orders.
TWFP keeps personal information only as long as necessary for the identified purposes. Personal information that is not longer needed for its identified purposes or for legal requirements will be destroyed or erased.
6. Accuracy
TWFP makes every effort to keep personal information in its possession or control, which is used on an ongoing basis, accurate, complete, current and relevant, based on the most recent information available to TWFP.
7. Safeguarding Information
TWFP makes every effort to keep personal information in its possession or control from loss or theft, unauthorized access, disclosure, duplication, use or modification.
All our employees with access to personal information are required to respect the confidentiality of personal information. TWFP may transfer personal information to third parties for processing, such as payroll and benefits. TWFP requires these third parties to safeguard all personal information in a way that is regulated by law.
TWFP uses care when disposing of or destroying personal information in order to prevent unauthorized access to the information.
8. Openness
TWFP is open about its procedures used to manage personal information. Individuals have access to information about these procedures by contacting the privacy officer.
9. Access
When a request is made in writing to the privacy officer, we will advise the individual in a timely fashion, what TWFP has its possession or control about the individual, what it is being used for, and to whom it has been disclosed.
In certain exceptional situations, we may not be able to provide individuals with access to all the personal information we hold about them. Exceptions may include information that contains references to other individuals, information that cannot be disclosed for legal, security or medical reasons. If TWFP denies the individual's request for access to personal information, TWFP will advise the individual of the reason for the refusal.
10. Employee or Customer Complaints
Our privacy officer will investigate all complaints concerning compliance with the privacy policy. If a complaint is found to be justified, we will take appropriate measures to resolve the complaint including the amendment of our policies and procedures.
Need More Information?
For more information about our privacy policy and procedures, please contact our privacy officer, Eva Steininger, at (519) 576-2150. You can also visit the Privacy Commissioner of Canada's website at www.privcom.gc.ca.
