Indwisco Privacy Policy

Introduction

Indwisco Limited (Indwisco) has a practice of protecting the privacy and security of customer and employee records. We are committed to meeting our obligations under Canadian data privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and applicable provincial laws. We adhere to the privacy principles set out below which govern the way we collect, use, store and disclose personal information which is obtained in the course of sales or in the course of employment. 

Personal Information as used in this policy means any information about an identifiable person including employee records and customer information, but does not include the name, title, business address, business telephone number, mobile number if published, business fax number or a business email address of an employee of an organization.

 

Policy for the Protection of Personal Information

We will collect, use, store and disclose Personal Information in accordance with the following privacy principles: 

• Accountability
  The overall responsibility for ensuring our compliance with data privacy laws and this privacy policy rests with the Sec/Treas, Finance & Administration, who is our Privacy Officer, although other individuals within Indwisco have responsibility for the day-to-day collection and processing of Personal Information and may be delegated to act on behalf of the Privacy Officer.
  We are responsible for Personal Information in our possession or custody, including Personal Information that we may transfer to third parties for processing. We will require our service providers to agree to contractual requirements that are consistent with our privacy and security policies. We will require that our service providers are prohibited from using Personal Information except for the specific purpose for which we supply it to them.

• Identifying Purposes
  Either before or at the time of collection, we will identify the purposes for which we plan to use the Personal Information. Depending upon the way in which the Personal Information is collected, this can be done orally or in writing. Indwisco may use the information we collect for the following purposes.
  
  1. To conduct credit checks on customers or prospective customers, (who are not incorporated).
  
  2. To meet legal requirements.
  
  Unless required by law, we will not use Personal Information for a new purpose without the knowledge and consent of the individual to whom the information relates.

• Consent
  Personal Information will only be collected, used or disclosed with the consent of the individual, except in certain circumstances permitted or required by law. The way in which we seek consent may vary depending upon the sensitivity of the information. We will obtain consent in all cases where the Personal Information involved is considered sensitive, such as income or health information.
  Typically, we will seek consent for the use or disclosure of Personal Information at the time of collection. However additional consent will be sought after the Personal Information has been collected if it is required for a new purpose.
  In certain circumstances, obtaining consent would be inappropriate. The federal Personal Information Protection and Electronic Documents Act and provincial privacy laws provide for exceptions where it is impossible or impractical to obtain consent.

• Limited Collection
  We will collect Personal Information by fair and lawful means and will limit the amount and type of Personal Information we collect to that which is necessary for our identified purposes.

• Limiting Use, Disclosure and Retention
  We will not use or disclose Personal Information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Subject to any applicable business, legal or regulatory requirements, we will ensure that the data is destroyed in a secure manner, erased or made anonymous.

• Accuracy
  We will use our best efforts to ensure that Personal Information that is used on an on-going basis and information that is used to make a decision about an individual is accurate, complete and up-to-date as necessary for the purpose for which it is to be used.

• Safeguards, protection of information
  We will protect Personal Information with safeguards appropriate to the level of sensitivity of the information. Our safeguards 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 exercise care in the disposal or destruction of Personal Information to prevent unauthorized parties from gaining access to the information. Our methods of protection include physical methods (locked file cabinets and restricted access to offices), organizational measures (security clearances and limiting access on a need-to-know basis), and technological measures (the use of passwords and encryption). We also require our outside service providers to provide a comparable level of protection to Personal Information that we may supply to them.

• Openness
  Privacy policies and practices are posted on our Web site, www.Indwisco.com

• Individual Access
  Upon written request, we will inform an individual of the existence, use and disclosure of his or her Personal Information and give him or her reasonable access to that information no later than 30 days after receipt of request. The normal 30-day response time limit may be extended for a maximum of 30 additional days, according to specific criteria set out at Subsection 8(4) of the Act:
  - If responding to the request within the original 30 days would unreasonably interfere with activities of Indwisco.
  - If additional time is necessary to conduct consultations.
  - If additional time is necessary to convert personal information to an alternate format.
  If the time limit is to be extended, the individual will be notified, within 30 days of receiving the request, along with his or her right to complain to the Privacy Commissioner of Canada .
  We may deny access for legally permissible reasons such as situations where the information is prohibitively costly to provide, if it contains references to other individuals, or where it cannot be disclosed for legal, security or commercial proprietary reasons. We will advise the individual of any reason for denying an access request.
  When an individual successfully demonstrates the inaccuracy or incompleteness of Personal Information held by us, we will correct or update the information as required.

• Recourse
  Filing Inquiries and Complaints
  We will investigate all written complaints and respond to all written inquiries. If we find a complaint to be justified, we will take appropriate measures to resolve it.
  To file an opt-out request, request access to your information, report incorrect information or file a complaint, please write to:
  Internal: Reg Boon
  Secretary Treasurer, Finance & Administration
  
  Indwisco Limited
  1-9010 Keele Street
  Concord, Ontario
  L4K 2N2
  
  Tel :(905) 760-2200ext. 226
  E-mail: rboon@indwisco.ca
  
  External: Office of Privacy Commission of Canada