At ServiceControl, we are committed to providing our clients, customers and partners with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients and customers, protecting their personal information is one of our highest priorities.
While we have always respected our clients’, customers’ and partners’ privacy and safeguarded their personal information, we continue to strengthen our commitment to protecting personal information as a result of changes in legislation, best practices, and changes in client, customer and partner expectations. As an Alberta-based Canadian company, ServiceControl is governed by the Canadian Federal Government’s Personal Information Protection and Electronic Documents Act (PIPEDA) (http://www.priv.gc.ca/leg_c/leg_c_p_e.asp), the Canadian Federal Government’s Canada Anti-Spam Legislation (CASL) (http://www.crtc.gc.ca/eng/casl-lcap.htm) and the Province of Alberta Personal Information Protection Act (PIPA) (http://servicealberta.ca/pipa/). These laws lay out the ground rules for how Alberta and Canadian businesses may collect, use and disclose personal information and communicate with clients, customers and partners with commercial electronic messages (CEM).
We will inform our clients, customers and partners of why and how we collect, use and disclose their personal information, obtain their express consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with PIPEDA, CASL and PIPA, outlines the principles and practices we will follow in protecting clients’, customers’ and partners’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’, customers’ and partners’ personal information and allowing our clients, customers and partners to request access to, and correction of, their personal information.
Scope of this Policy
This Personal Information Protection and Email Policy applies to Omni Technology Solutions, Inc., ServiceControl and related companies. This policy also applies to any service providers collecting, using or disclosing personal information on behalf of ServiceControl.
Age of the Policy
This was last updated on July 26 2014.
Personal Information –means information about an identifiable individual (e.g., including name, personal email address, personal mailing address, personal phone number and other related personal information). Personal information does not include contact information (described below).
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email, business fax number and related business and employer information. Contact information is not covered by this policy.
Privacy Officer – means the individual designated responsibility for ensuring that Riva complies with this policy and related legislation.
Policy 1 – Collecting Personal Information
- Unless the purposes for collecting personal information are obvious and the client, customer or partner voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
- We will only collect client, customer, member information that is necessary to fulfill the following purposes:
- To verify identity;
- To identify client, customer and partner preferences;
- To understand the needs of our clients, customers and partners;
- To deliver requested products and services;
- To open and manage an account;
- To enrol the client, customer or partner in a program/subscription;
- To send out client, customer and partner information;
- To ensure a high standard of service to our clients, customers and partners;
- To meet regulatory requirements;
- To collect and process electronic or physical payments.
- When you visit our Site(s), additional information may be collected by using “passive information collection” technologies. The information gathered may include, among others, your IP address, information about the type of operating system, the browser you use, your computer’s location, what pages you visit on the Site, what links you click, what other websites you’ve visited recently and other similar information. These technologies used to gather this passive information may include the use of “cookies”. Cookies are small text files that store information about your interactions with a particular web site, either temporarily (known as a “temporary” or “session” cookie, and deleted once you close your browser window) or more permanently on the hard drive of your computer (known as a “permanent” or “persistent cookie”). Cookies can make it easier to use a website by allowing servers to access certain information quickly. Cookies can be deleted at any time and browser options control whether cookies are allowed and how they are managed.
Policy 2 – Consent
- We will obtain client, customer, member consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
- Consent can be provided by client, customer or partner by expressed selection of the consent form (checkbox or other) or it can be implied where the purpose for collecting, using or disclosing personal information would be considered obvious and the client, customer, or partner voluntarily provides personal information for that purpose. The types of information included in this process include payment card information, payment card expiration date, banking information, product service preferences, customer satisfaction information, opinions about products and services and other.
- Consent may also be implied where a client, customer, member is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs of commercial electronic messages, the marketing of new services or products, fundraising and the client, customer, member does not opt-out. This policy respects the July 1, 2014 CASL requirement which provides a 36-month period during which previously received implied consent can be converted to express consent. Implied consent will continue to apply for interactions and contacts created after July 1, 2014, but this consent will be limited to a 24-month period during which expressed consent can be solicited.
- Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients, customers and partners can withhold or withdraw their consent for Riva to use their personal information in certain ways. A client’s, customer’s, partner’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client, customer, member in making the decision.
- We may collect, use or disclose personal information without the client’s, customer’s, member’s knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- In an emergency that threatens an individual’s life, health, or personal security;
- When the personal information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law.
Policy 3 – Using and Disclosing Personal Information
- We will only use or disclose client, customer or partner personal information where necessary to fulfill the purposes identified at the time of collection and:
- To conduct client, customer, member surveys in order to enhance the provision of our services;
- To contact our clients, customers and partners directly about products and services that may be of interest.
- We will not use or disclose client, customer or partner personal information for any additional purpose unless we obtain consent to do so.
- We will not sell client, customer, member lists or personal information to other parties unless we have consent to do so.
Policy 4 – Retaining Personal Information
- If we use client, customer or partner personal information to make a decision that directly affects the client, customer or partner, we will retain that personal information for at least one year so that the client, customer or partner has a reasonable opportunity to request access to it.
- Subject to policy 4.1, we will retain client, customer, member personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
- We will make reasonable efforts to ensure that client, customer or partner personal information is accurate and complete where it may be used to make a decision about the client, customer, member or disclosed to another organization.
- Clients, customers and partners may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. A request to correct personal information should be forwarded to the designated Privacy Officer.
- If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the client’s, customer’s or partner’s correction request in the file.
Policy 6 – Securing Personal Information
- We are committed to ensuring the security of client, customer and partner personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
- The following security measures will be followed to ensure that client, customer, member personal information is appropriately protected. In the case of physical security, these measures include ensuring that all physical files that include personal information are kept in locked filing cabinets in locked rooms with access restricted to people who require this information. In the case of electronic files, these measures include ensuring the required use of user IDs, secure passwords, data encryption, firewalls to prevent external access, restricting employee access to electronic personal information as appropriate (only those employees who need to know this information will have access) and by requiring any contractors or service providers to provide comparable security measures.
- We will use appropriate security measures when destroying clients’, customers’ and partners’ personal information such by shredding physical documents and deleting electronically stored information.
- We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Clients, customers and partners Access to Personal Information
- Clients, customers and partners have a right to access their personal information, subject to limited exceptions such as solicitor-client privilege or if disclosure would reveal personal information about another individual, health and safety concerns.
- A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer.
- Upon request, we will also tell clients, customers and partners how we use their personal information and to whom it has been disclosed if applicable.
- We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
- A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client, customer or partner of the cost and request further direction from the client, customer or partner on whether or not we should proceed with the request.
- If a request is refused in full or in part, we will notify the client, customer, member in writing, providing the reasons for refusal and the recourse available to the client, customer, member.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
- The Privacy Officer, as identified below, is responsible for ensuring Riva’s compliance with this policy and the related legislation.
- Clients, customers and partners should direct any complaints, concerns or questions regarding Riva’s compliance in writing or by email to the Riva Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client, customer or partner may also write to the Information and Privacy Commissioner of Alberta and/or the Office of the Privacy Commissioner of Canada.
Contact information for Riva’s Privacy Officer:
Michèle Dagneault, President and Privacy Officer
103, 10301-109 Street, Edmonton
Alberta T5J 1N4
Email: michele @ omni-ts.com
Web site: www.rivacrmintegration.com
Information about the related legislation which applies to this Personal Information Protection and Email Policy:
Office of the Information and Privacy Commissioner of Alberta
410, 9925 – 109 Street
Edmonton, Alberta T5K 2J8
Phone: (780) 422-6860
Toll Free: 1-888-878-4044
Email: generalinfo @ oipc.ab.ca
Web Site: http://www.oipc.ab.ca
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Québec K1A 1H3
Toll Free: 1-800-282-1376
Web site: http://www.priv.gc.ca/index_e.asp
Canadian Radio-television and Telecommunications’ Commission
Canada’s Anti-Spam Legislation
Ottawa, Ontario K1A 0N2
Phone: (819) 997-0313
Toll Free: 1-877-249-2782
Web site: http://fightspam.gc.ca/eic/site/030.nsf/eng/h_00211.html