HR Strategies Consulting
Personal Information Protection Policy
At HR Strategies Consulting Inc., we are committed to protecting your privacy and safeguarding your personal, business and financial information. The purpose of this Privacy Statement is to inform you about the types of Personal Information that HR Strategies Consulting collects, uses and discloses. It explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information.
As we are a national organization, this Privacy Statement is designed to meet the standards prescribed by the Personal Information Protection and Electronic Documents Act and the regulations thereunder (“PIPEDA”) as well as applicable provincial privacy legislation and regulations, US Privacy Laws, and Fair Information Practices Principles
From time to time, we may make changes to this Privacy Statement. The Privacy Statement is current as of the “last revised” date which appears at the bottom of this introduction.
Updated February 2017
Personal Information –
means information about an identifiable individual
e.g., including name, age, home address and phone number, social insurance number, marital status, religion, income, credit history, medical information, education, employment information. HR Strategies Consulting does NOT collect this information. Personal information does not include contact information (described below).
– 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 or business fax number. Contact information is not covered by this policy or PIPEDA.
– means the individual designated responsibility for ensuring that HR Strategies Consulting complies with this policy and PIPEDA.
Policy 1 – Collecting Personal Information
1.1 Unless otherwise noted, HR Strategies Consulting does not automatically gather any specific information from you, such as your name, telephone number or email address. HR Strategies Consulting would obtain this information only if you supply it to us, for example, by email or filling in a contact form, or registering on our careers portal.
Policy 2 – Consent
2.1 We will obtain client 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 orally, in writing, electronically, 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 client voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client 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 services or products, fundraising and the client 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), client can withhold or withdraw their consent for HR Strategies Consulting to use their personal information in certain ways. A client’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 in making the decision.
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose client 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 client, customer, member surveys in order to enhance the provision of our services;
- To contact our clients directly about products and services that may be of interest
3.2 We will not use or disclose client personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use client personal information to make a decision that directly affects the client we will retain that personal information for at least one year so that the client has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Securing Personal Information
5.1 We are committed to ensuring the security of client personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
5.2 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 6 – Providing Clients Access to Personal Information
6.1 Clients have a right to access their personal information, subject to limited exceptions.
6.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
6.3 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.
6.4 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client of the cost and request further direction from the client on whether or not we should proceed with the request.
6.5 If a request is refused in full or in part, we will notify the client in writing, providing the reasons for refusal and the recourse available to the client.
Policy 7 – Cookies
7.1 The HR Strategies Consulting website puts small files (known as ‘cookies’) onto your computer to collect information about how you browse the site.
Cookies are used to:
- measure how you use the website so it can be updated and improved based on your needs
- remember preferences you’ve chosen, such as language
- remember the notifications you’ve seen so that we don’t show them to you again
7.2 Cookies aren’t used to identify you personally, or to track your behavior on other sites.
Policy 8 – Google Analytics
8.1 We use Google Analytics software to collect information about how you use the website. We do this to help make sure the site is meeting the needs of its users and to help us make improvements.
8.2 Google Analytics stores information about:
- the pages you visit on our website, and how long you spend on each page
- how you got to the site
- what you click on while you’re visiting the site
- how often you visit a given page or pages
8.3 Google Analytics doesn’t collect or store your personal information (e.g., your name or address.)
8.4 We don’t allow Google to use or share our analytics data.
8.5 Information collected by Google Analytics is stored on Google servers in the United States and may be subject to the governing legislation in that country (for example, the USA Patriot Act). Your IP address is anonymized prior to being stored on Googles’ servers in order to help safeguard your privacy.
8.6 If you do not wish to have your information shared with the Analytics software, Google makes available a “plug-in” for users of the Internet Explorer, Firefox, Safari and Chrome browsers which prevents your browser from sharing any information with the Analytics software. You may download and install the “plug-in” here: http://tools.google.com/dlpage/gaoptout
Policy 9 – Outside Links
9.1 This site contains links to other sites. HR Strategies Consulting is not responsible for the privacy practices or the content of such websites.
Policy 10 – Questions and Complaints: The Role of the Privacy Officer or designated individual
10.1 The Privacy Officer is responsible for ensuring HR Strategies Consulting’s compliance with this policy and the Personal Information Protection Act.
10.2 Clients should direct any complaints, concerns or questions regarding HR Strategies Consulting’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client may also write to the Information and Privacy Commissioner of Ontario.
Contact information for HR Strategies Consulting Privacy Officer:
100 York Blvd, Suite 200
Richmond Hill, ON L4B 1J8