We will use our best efforts to ensure that personal information, including information that is disclosed to third parties, is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
We will protect personal information with safeguards appropriate to the sensitivity of the information.
Our safeguards will protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We will make our employees aware of the importance of maintaining the confidentiality of personal information, and will exercise care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.
Our methods of protection will include physical measures (for example, locked filing cabinets and restricted access to offices), organizational measures (for example limiting access on a “need-to-know” basis), and technological measures (for example, the use of passwords and encryption).
Openness Concerning Policies and Practices
We will make readily available to customers and employees specific information about our policies and practices relating to the management of personal information.
The information we will make available will include: how to gain access to personal information; the type of personal information held by us, including a general account of its use; general information concerning our policies; and how to contact our Privacy Officer.
Upon written request, we will inform an individual of the existence, use, and disclosure of his or her personal information and we will give the individual access to that personal information. An individual can challenge the accuracy and completeness of his or her personal information and have it amended as appropriate.
We will respond to an individual’s written request within a reasonable time (generally within 30 days). We will assist any individual who informs us that they need assistance in preparing a request. We may require an individual to provide sufficient information to permit us to provide an account of the existence, use, and disclosure of personal information.
While our response will typically be provided at no cost, depending on the nature of the request and the amount of information involved, we reserve the right to impose a cost. In these circumstances, we will inform the individual of the approximate cost to provide the response and request direction from the individual on whether or not to proceed with the request. Requested information will be provided or made available in a form that is generally understandable. Where possible, we will indicate the source of the information.
In providing an account of third parties to which we may have disclosed personal information about an individual, we will attempt to be as specific as possible.
If an individual successfully demonstrates the inaccuracy or incompleteness of personal information, we will amend the information as required. If a challenge is not resolved to the satisfaction of the individual, we will record the substance of the unresolved challenge. Where appropriate the amended information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the information in question.
In certain situations, we may refuse a request or not be able to provide access to all the personal information we hold about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law. Where permitted, the reasons for denying access will be provided to the individual upon request.
Any individual can address a challenge concerning our compliance with any of the Privacy Principles to our Privacy Officer.
We will investigate all written complaints. If we find a complaint to be justified, we will take all appropriate measures, including, if necessary, amending our policies and practices.