Last updated on September 24, 2008.
At Upper Canada Stretchers Inc. (UCS) the protection of your personal information has always been a top priority. UCS’s Policy regarding the collection, use and disclosure, if any, of personal information can be broken down into the 10 principles covered in Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”).
UCS is responsible for personal information under its control.
We have designated a Privacy Officer who is accountable for our compliance with this Policy and all applicable privacy laws.
All UCS employees are responsible for day-to-day compliance.
When we use trusted third parties to act on our behalf by performing such functions as fulfilling orders, delivering packages, processing credit card payments or providing customer service, contractual or other appropriate means are used to ensure compliance by such third parties with this Policy and all applicable privacy laws.
2. Identifying Purposes
Unless the purpose is self-evident due to the nature of the transaction in question, UCS will identify the purposes for which personal information is collected at or before the time the information is collected.
The proposed purposes will be described in a reasonably understandable manner.
An example of a self-evident purpose is requesting the name and address of the person placing an order in order to ensure proper delivery.
We will collect, use or disclose your personal information only with your knowledge and consent, except where required or permitted by law.
UCS will not make your consent a requirement to the supply of a product or a service other than required to be able to supply the product or service.
Consent can be express or, in some circumstances, implied, and given in writing, by using or not using a check-off box, electronically, orally (in person or by telephone), or by your conduct, such as use of a product or service.
In determining the type of consent to obtain, UCS will consider all relevant factors, including the sensitivity of the information and your reasonable expectations.
You may withdraw your consent at any time, on reasonable notice, subject to legal or contractual restrictions. UCS will inform you of the implications of doing so.
4. Limiting Collection
The collection of personal information by UCS will be limited to what is necessary for the purposes which it identifies.
We will collect personal information by fair and lawful means.
5. Limiting Use, Disclosure, and Retention
Personal information will not be used or disclosed for purposes other than those for which it was collected, except with your consent or as required or permitted by law.
It will be retained only as long as necessary for these purposes or as required by law.
We will keep your personal information as accurate, complete and up-to-date as necessary for the purposes for which it is to be used.
UCS will protect personal information by security safeguards appropriate to the sensitivity of the information, including through the use of the following measures: physical (e.g., locked filing cabinets, restricted access, appropriate disposal of personal information), organizational (e.g., security clearances, access only on a “need to know” basis), technological (e.g., passwords, encryption) and training of employees.
Information about our policies and practices relating to the management of personal information will be made readily available to individuals.
9. Individual Access
Upon request, UCS will inform you of the existence, use and disclosure of personal information relating to you, and give you access to that information. You have the right to challenge the accuracy and completeness of your information and have it amended as appropriate.
However, in certain circumstances permitted by law, this information will not be disclosed to you. Some examples of these circumstances are information that contains references to other individuals, that cannot be disclosed for legal, security or commercial proprietary reasons, or that is subject to solicitor-client or litigation privilege.
10 Contacting us and/or Challenging Compliance
For anything to do with this Policy, including questions or comments, or to challenge our compliance with this Policy, please contact us as follows:
Robert Nadon, Privacy Officer
Upper Canada Stretchers Inc.
UCS will inform individuals who make enquiries or lodge complaints about its enquiry or complaint procedures, as applicable. If a complaint is found to be justified, we will take appropriate measures, including, if necessary, amending our policies and practices.
Of course, this Policy is subject to PIPEDA and/or any other applicable privacy laws and UCS’s right to change it at any time.