Anatech Inc. Personal Information Protection Policy
WHAT IS PERSONAL INFORMATION?
Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (possible examples: gender, age, income, home address or phone number, ethnic background, family status), their health (possible examples: health history, health conditions, health services received by them) or their activities and views (possible examples: religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is to be contrasted with business information (examples: an individual’s business address and telephone number), which is not protected by privacy legislation.
WHO WE ARE
Anatech Inc. includes, at the time of writing this, outside sales representatives and customer service personnel and supporting staff. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These can include computer consultants, temporary workers to cover leave or holidays, credit card companies, website managers, accountants and lawyers. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.
POLICY 1: COLLECTING PERSONAL INFORMATION
1.1 Unless the purposes for collecting personal information are obvious and the customer 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.
1.2 We will only collect customer information that is necessary to fulfill the following possible purposes:
• To verify identity;
• To verify creditworthiness;
• To identify customer preferences;
• To open and manage an account;
• To deliver requested products and services
• To ensure a high standard of service to our customers;
POLICY 2 - CONSENT
2.1 We will obtain customer consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided e.g., orally, in writing, electronically, or through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the customer voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new products and the customer does not opt-out.
2.4 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), customers can withhold or withdraw their consent for Anatech Inc. to use their personal information in certain ways. A customer’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 customer in making the decision.
2.5 We may collect, use or disclose personal information without the customer’s knowledge or consent in the following limited circumstances:
• When the collection, use or disclosure of personal information is permitted or required by law;
• When the personal information is available from a public source (e.g., a telephone directory);
• For the purposes of collecting a debt;
POLICY 3 - USING AND DISCLOSING PERSONAL
3.1 We will only use or disclose customer personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
• To conduct customer surveys in order to enhance the provision of our services;
• To contact our customers directly about products and services that may be of interest;
3.2 We will not use or disclose customer personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell customer lists or personal information to other parties.
POLICY 4 - RETAINING PERSONAL INFORMATION
4.1 If we use customer personal information to make a decision that directly affects the customer, we will retain that personal information for at least one year so that the customer has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain customer 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
5.1 We will make reasonable efforts to ensure that customer personal information is accurate and complete where it may be used to make a decision about the customer or disclosed to another organization.
5.2 Customers 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 Privacy Officer].
5.3 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 customers’ correction request in the file.
POLICY 6 - SECURING PERSONAL INFORMATION
6.1 We are committed to ensuring the security of customer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that customer personal information is appropriately protected:
- physically secured offices where personal information is held;
- the use of user IDs, passwords, encryption & firewalls;
- restricting employee access to personal information as appropriate (i.e., only those that need to know will have access);
- contractually requiring any service providers to provide comparable security measures.
6.3 We will use appropriate security measures when destroying customer’s personal information such as shredding documents and deleting electronically stored information.
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.