Hamilton Civic
League’s Privacy Policy
It is the policy of Hamilton
Civic League to ensure all individual personal information is accurate,
confidential, private and secure.
Personal information is defined
as any information about an individual, which provides a means to identify
specifically, the individual to whom it relates. The only exception
would be information normally contained on a business card.
The collection, use, storage,
and disclosure of Personal Information under this Policy is consistent
with generally accepted privacy and business practices, as well as the
requirements of the Personal Information Protection and Electronic
Documents Act (PIPEDA) and applicable provincial privacy laws.
1. Accountability: HCL
is responsible for all Personal Information that it collects, uses or
discloses. All of our employees are accountable for and trained to safeguard
and protect the confidentiality and security of Personal Information
under their care and control. HCL is committed to ensuring that contractors
and third parties apply privacy safeguards comparable to those of HCL
when Personal Information is being processed outside HCL.
2. Identifying Purposes:
HCL will identify the purposes for which it collects, uses or discloses
personal information at or before the time the information is collected,
unless otherwise required or prescribed by law. HCL may collect or use
personal information for the following purposes:
3. Consent: HCL will
make a reasonable effort to make sure individuals understand how it
will use the personal information collected and will obtain consent
at or before it collects, uses, or discloses their Personal Information.
Consent may be expressed, implied or given through an authorized representative.
Where HCL identifies a new purpose, it will seek consent to use and
or disclose Personal Information prior to using or disclosing it for
that new purpose.
Individuals always have the
right to withdraw consent at any time with certain exceptions and HCL
will inform you of the implications of such withdrawal. HCL, however,
may collect, use or disclose Personal Information without your knowledge
or consent in exceptional circumstances where such collection, use or
disclosure is permitted or as required by law.
4. Limiting Collection:
HCL will limit its collection of Personal Information to that which
is necessary for the purposes identified by HCL. HCL’s staff will
collect the Personal Information directly from the individual to whom
the Personal Information relates wherever possible.
5. Limiting Use, Disclosure,
and Retention: HCL will only collect or use Personal Information
for the purpose described and for which consent was provided. We will
not disclose personal information except as prescribed or required by
law. Personal Information will be retained only as long as necessary
to fulfill the stated purposes. Thereafter, it will be destroyed or
made anonymous.
6. Accuracy: HCL will
keep Personal Information accurate, complete and up to date taking into
account, its use and the interest of the individual. Personal Information
will be updated only when necessary to fulfil the specified purposes.
7. Safeguards: HCL will
protect Personal Information with security safeguards that meet or exceed
industry standards based on the sensitivity of the information. Standards
may include locked filing cabinets, restricted access to offices, alarm
systems, passwords, encryption, firewalls, security clearances and limiting
access on a “need-to know” basis.
8. Openness:
HCL is committed to being open and transparent about its Personal Information
management practices. HCL will make readily available to individuals,
specific information about its policies and practices relating to the
management of Personal Information.
9. Individual Access:
When an individual makes a request in writing, our Privacy Officer will,
within a reasonable time, advise the individual about the Personal Information
HCL has collected about them, what it is being used for, and to whom
it has been disclosed, except as otherwise prescribed or prohibited
by law. An individual shall be able to challenge the accuracy and completeness
of the information and request that it be amended, if appropriate.
10. Challenging Compliance:
Individuals have the right to address any concerns, questions, suggestions
or complaints concerning HCL’s handling of their Personal Information
by writing to our Privacy Officer via the contact form on our website.
If you are not satisfied that
HCL is operating in compliance with the requirements of this policy
you may file a written complaint with:
THE PRIVACY COMMISSIONER OF CANADA
112 Kent Street, Place de Ville, Tour B, 3rd Floor
Ottawa ON K1A 1H3
Tel: 1-613-995-8210
Toll free: 1-800-282-1376
Fax: 1-613-947-6850 Email:
info@privcom.gc.ca
Revised August 2009