Introduction
January 01, 2004 was the date this complex provision of privacy legislation affected all Canadian business. On that date the federal Personal Information Protection and Electronic Document ACT (PIPEDA) came into force in all Provinces that have not enacted their own privacy legislation. Organizations covered by the Act must obtain an individual’s consent when they collect, use and disclose the individual’s personal information. Personal information can only be used for the purposes for which it was collected. An individual may complain to the organization in question or to the Office of the Privacy Commissioner of Canada about any breaches of the law.
To contact the Privacy Commissioner of Canada
Phone: 800-282-1376 available 9:00 A.M. to 6 P.M. (EST)
Website: www.privcom.gc.ca
Email: info@pricom.gc.ca
TransferEASE Relocation Inc., a national leader in relocation, provides a wide range of services to the public that involve managing their personal information in order to smoothly relocate you to a new location and work environment. These services include, but not limited to: coordination of moving furniture, property evaluation, home finding, home sale/purchase/rental assistance, lease cancellation, property management, financial assistance, interim living accommodations, guidance on financial and taxation, area neighbourhood information, settling in services i.e. schools, elder care, hospitals, banking etc. To provide these services and products, TransferEASE Relocation Inc. will collect, with proper consent of the recipient, certain personal information about its customers. Personal information does not include the name, title, business address or telephone number of an employee of an organization.
We understand the importance of protecting your personal information and are seriously committed to collecting, using and disclosing your personal information responsibly throughout our organization and in dealing with third parties. We also try to be open and transparent as possible about the way we handle your information. All staff members who come in contact with your personal information are aware of the sensitive nature of the information you have disclosed. It is important to us to provide this service to our clients.
The Ten Principals that a business must follow are:
- Accountability
- Identifying purposes
- Consent
- Limiting collection
- Limiting use, disclosure, and retention
- Accuracy
- Safeguards
- Openness
- Individual access
- Challenging compliance
The following sets out the responsibilities for each of the 10 principles:
1. Be Accountable: (Our Responsibility)
- Our company will comply with all 10 principles.
- Appoint an individual to be responsible for our organization’s compliance.
- Protect all personal information held by our organization or transferred to a third party for processing.
- Develop and implement personal information policies and practices.
2. Identifying the purpose: (Our Responsibility)
- Before or when any personal information is collected we identify why it is needed and how it will be used.
- Individuals from who the information is collected are informed why it is needed.
- Identify any new purpose for the information and obtain your consent before using it.
3. Obtain consent: (Our Responsibility)
- Inform you in a meaningful way of the purposes for the collection, use and disclosure of personal data.
- Obtain your consent before or at any time of collection, as well as when a new use is identified.
4. Limit collection: (Our Responsibility)
- Collect personal information indiscriminately.
- Not deceive or mislead you about the reasons for collecting personal information.
5. Limit use, disclosure and retention: (Our Responsibility)
- Use or disclose personal information only for the purposes for which it was collected, unless you consent, or the use of discloser is authorized by the Act.
- Information will be kept only as long as necessary to satisfy the purpose.
- Guidelines and procedures are in place for retaining and destroying personal information.
- Personal information used to make a decision about a person will be kept for a reasonable time period. This should allow you to obtain information after the decision and pursue redress.
- Destroy, erase or render anonymous information that is no longer required for an identified purpose or legal requirement.
6. Be accurate: (Our Responsibility)
- Minimize the possibility of using incorrect information about you or when disclosing information to a third party.
7. Use appropriate safeguards: (Our Responsibility)
- Protect personal information against loss or theft.
- Safeguard the information from unauthorized access, disclosure, copying, use or modification.
- Protect personal information regardless of the format in which it is held.
8. Be open: (Our Responsibility)
- Inform customers, clients and employees that we have policies and practices for the management of personal information.
- Make these policies and practices understandable and easily available.
9. Give individual access: (Our Responsibility)
- When requested, inform you if we have any personal information about you.
- Explain how it is or has been used and provide a list of any organizations to which it has been disclosed.
- Give you access to your information.
- Correct or amend any personal information if its accuracy and completeness is challenged and found to be deficient.
- Provide a copy of the information requested, or reasons for not providing access, subject to exceptions as set out in the Act.
- Any disagreement on the file will be noted and third parties advised where appropriate.
10. Provide recourse: (Our Responsibility)
- Simple and easily accessible complaint procedure.
- Inform complainants of your avenue of recourse.
- Investigate all complaints received.
- Take appropriate measures to correct information handling practices and policies.
What Personal Information Do We Collect?
TransferEASE Relocation Inc. collects and uses personal information to provide you with an abundant of relocation services you have requested (through your employer) or to offer additional relocation assistance you may be interested in. For us to provide these products or services we will require personal information. Providing us with the information is your choice, and in some cases, without certain information we may not be able to perform the requested service or product.
Information that is typically required to provide you with relocation services but not limited to, are: name, address, mortgage information, phone numbers, property information, family details, destination requirements, possibly Social Insurance number for tax reporting purposes pursuant to the Income Tax Act, etc. Contact history may be kept in a file for your access to ensure your satisfaction with the services we have provided to you.
Why Do We Collect It?
Many of the services offered by TransferEASE Relocation Inc. require us to obtain personal information about you in order to perform the services we have been engaged to provide. This enables us to design programs to meet your needs. Your consent will always be obtained first and we will never use the information for purposes other than what we had committed to. The individual(s) collecting the personal information will answer your questions about the purposes of the collection.
How Do We Collect It?
Consent can be obtained in person, by phone, by mail, via the Internet, fax, etc. Consent is a voluntary agreement with what is being done or proposed. Personal information can be expressed or implied. Expressed consent is given explicitly, either orally or in writing. Expressed consent is unequivocal and does not require inference on the part of TransferEASE Relocation Inc. seeking consent. Implied consent arises where consent may reasonably be inferred from the action or inaction on you.
We do not make consent a condition for supplying a product or service, unless the information requested is required to fulfill an explicit and legitimate purpose.
How Do We Use Your Information?
Your personal information is used for two basic general purposes:
- To provide you with our product and services we will have to communicate with you during the course of your relocation. This may involve other service providers with specialized programs to better serve your relocation requirements; such as moving companies or consultants.
- Process information to monitor our level of service and report back to you to ensure your satisfaction with the provision of such services. The personal information collected will only be used for the purposes we have disclosed to you. You will be notified and asked for your consent first should this information be used for a different purpose.
Disclosure of Your Personal Information
Your personal information is confidential. TransferEASE Relocation Inc., with your consent, will only release information allowing us to perform the requested service, or where required by law or when permitted by law. You may also withdraw your consent at any time, subject to any legal implications, which we will inform you about. We will always obtain consent from you first, and we will never use the information for purposes other than those we have described.
How Personal Information is Shared
Access to sensitive personal information is limited to TransferEASE employees with a legitimate reason for accessing it. Employees are required to follow all applicable laws and regulations, including the Privacy Policy we have established as a condition of employment. Disciplinary measures inclusive of dismissal may result where employees of TransferEASE disclose unauthorized confidential information.
In order for TransferEASE Relocation Inc. to deliver our products and services we often engage other service providers to deliver a vast array of relocation expertise and services. They consist of lawyers, moving companies, realtors, appraisers, rental agents, and other consultants who assist families with relocating requirements. To ensure your relocation needs are met and with your consent we may share some of your personal information with these suppliers. These providers are also bound to protect the confidentiality of your information. They are required to treat your personal information in a manner consistent with the TransferEASE Relocation Inc. Private Policy.
Website Security
TransferEase offers client’s access to a secured web site. For your protection TransferEASE requires the use of encryption technologies in order to access your account. Clients are required to log on using User IDs with an encrypted password. Clients are also responsible for maintaining the confidentiality of their User Codes.
Accessing Your Personal Information
Personal information kept in your file can be accessed. Any information viewed, if shown to be inaccurate will be amended. To view your file, please make a written request to the Privacy Officer.