From January 1, 2004 all businesses engaged in commercial activity must comply with the “Personal Information Protection and Electronic Documents Act”, and the “Canadian Standards Association Model Code for the Protection of Personal Information”, which it incorporates. These obligations extend to our company and the act gives you, our affiliates, certain rights concerning the privacy of your personal information.
ClearNeed Information Systems Inc. is responsible for the personal information we collect and hold. To ensure this accountability, we have developed this policy and trained our staff about our policies and practices.
This policy covers our treatment of the personal information we collect from you.
Our company collects personal information for the following limited purposes:
to evaluate potential affiliates
to ensure the accurate performance of various services
We collect information only by lawful and fair means that are not reasonably intrusive. Wherever possible we collect your personal information from you, our affiliate, directly at the start of our business relationship. We also collect the personal information of your clients through the performance of various services on your behalf.
Our company does not sell, barter, trade or give away your personal information to third parties. For example, we do not provide our affiliate mailing list to other companies. Our company stores and maintains personal information in conformity with the requirements of the “Personal Information Protection and Electronic Document Act” and the “Model Code for the Protection of Personal Information” created and approved by the Canadian Standards Association.
ClearNeed Information Systems Inc. applies the ten principles of the code as follows:
Our company is responsible for the personal information collected and maintained by us and which is under our control. In order to fulfill this responsibility:
we have designated officials to be responsible for the day to day care and control of personal information
our staff oversee compliance with the terms of this policy
our company has taken the following measures to ensure compliance with this policy:
developing procedures to protect personal information
developing procedures to receive and respond to complaints and inquiries
training our staff about the policies and practices respecting personal information
developing and distributing information to our staff explaining our policies and procedures respecting personal information and having this information
available to our clients upon request
Our company is committed to openness regarding the collection and use of personal information. As discussed above we collect and use personal information for the following limited purposes:
to evaluate potential affiliates
to ensure the accurate performance of various services
To demonstrate this openness we require the consent of our affiliates prior to using their personal information for any purpose other than that for which it was originally collected.
If any individuals wish to be advised of the personal information we have in relation to them, they are advised to follow the procedure listed at the end of this document.
In most cases, we shall ask you to specifically consent, if we collect , use or disclose your personal information. Normally we ask you for your consent in writing but in some circumstances, we may accept your oral consent. Sometimes your consent may be implied throughout your conduct with us. The company will only further disclose your personal information, without notice, only in the situations described in Section 5 below.
Our company restricts the collection of personal information only to that information that is necessary for the limited purposes noted above. We are committed to collecting personal information in a fair, open and lawful manner.
For this reason, our company does not indiscriminately collect personal information. We collect personal information to fulfill the above noted purposes only, and for no other purpose.
Our company does not use personal information for purposes other than those for which it was originally collected, unless it has first obtained the consent of the person from whom such information was received.
Further, ClearNeed Information Systems Inc. will only disclose your personal information or your client’s personal information that we acquire through the performance of various services on your behalf, under the following circumstances:
when we are required or authorized by law to do so, for example if a court issues a subpoena
when you have consented to the disclosure
where it is necessary to establish or collect fees
if the information is already publicly known
We retain personal information only for as long as it is needed and only for the fulfillment of the purposes for which it was originally collected.
Since we use personal information to evaluate potential affiliates and may use it to maintain current affiliates, it is important that the information be accurate and up-to-date. If during the course of our business relationship any of your information changes, please inform us of such changes and we will update our records accordingly. If during the course of performing any of our services on your behalf, personal information is found to be inaccurate, we will contact you for any corrections deemed necessary.
You may confirm the accuracy of your personal information by contacting us in writing at the address set out at the end of this document.
Our company takes all reasonable precautions to ensure that personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect this information are:
premise security
restricted file access to personal information
secured databases
hard copies of affiliate information kept in a secure area with restricted access
confidential shredding
We also ensure that any of our employees who deal with personal information are properly trained and are aware of the necessary and appropriate measures required to protect personal information.
Our company makes information about its policies and practices respecting the collection and maintenance of personal information available to all interested parties.
We are pleased to answer any questions that you may have regarding the collection and maintenance of personal information. Please forward any questions in writing to the address set out at the end of this document.
You may ask for access to any personal information which we hold about you, however, we reserve the right to confirm the identity of the persons seeking access to personal information before complying with any requests.
Your rights to access of your personal information are not absolute. We may deny access when:
denial of access is required or authorized by law
information relates to existing or anticipated legal proceedings against you
when granting you access would have an unreasonable impact on other people’s privacy
when to do so would prejudice negotiation with you
to protect our company’s rights and property
when the request is frivolous or vexatious
If we deny your request to access information we shall provide you with a written explanation for such denial.
Our company has designated officials who are responsible for the day to day care and control of personal information. These officials will receive and respond to all information requests concerning our privacy policies or about your personal information under our care and control.
We investigate all complaints received by us and will respond in a timely manner. If any complaint is found to be justified, then we will take the appropriate measures to respond to the matter to the satisfaction of the complainant.
If you have any questions, or wish to access your personal information, please write to our privacy officer at:
Box 3128, Hamilton, Ontario, L8H 7K6
If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at:
112 Kent Street, Place de Ville, Tower B, 3rd Floor, Ottawa, Ontario, K1A 1H3 1-800-282-1376
