CanREA respects and protects the privacy of our Employees and our Clients and takes great care to safeguard confidentiality, security and privacy of employee and client information. We recognize that collecting, using, and disclosing personal information in an appropriate, responsible, and ethical manner is fundamental to CanREA’s daily operations and that employees at one time or another may receive personal, privileged and/or confidential information which may concern other employees, company operations or clients.
Concerns or complaints related to privacy issues must be made, in writing, to the President and CEO, setting out the details of the concern or complaint. The President and CEO will investigate the matter and make a determination related the resolution of the concern(s) or complaint(s).
- The Policy applies to personal information collected, used, or disclosed by CanREA including personal information of CanREA’s employees and clients.
- The Policy applies to the management of personal information in any form—oral, electronic or written.
- Personal information is defined as any identifying information about an individual or group of individuals, including – name, date of birth, address, phone number, e-mail address, social insurance number, nationality, gender, health history, financial data, assets, debts, liabilities, payment, credit and loan records and personal views.
- Business information is treated and handled with the same level of confidentiality, privacy, and respect as personal information. Additionally, business information includes but is not limited to job titles, structure, business registration numbers, and financial status.
- Consent is obtained when an individual signs the application or other form containing personal information, thereby authorizing the collection, use, and disclosure of information for the purposes stated on the form or in the Appropriate Use section of this policy.
- Implied consent is granted when an individual signs the application or form. This allows CanREA to obtain information from third parties (such as banks, insurance companies, etc.) in the process of assessing the eligibility of a client, job applicant, or business partner.
CanREA collects and uses personal information solely for the purposes of conducting business and developing an understanding of its clients. CanREA hereby asserts that personal information will only be used for the following purposes:
- To establish and maintain responsible commercial relations and provide ongoing service;
- To understand members’ and clients’ needs and suitability for services;
- To develop, enhance, market, or provide products and services;
omanage and develop CanREA’s business and operations, including employment matters;
- To meet legal and regulatory requirements.
- CanREA assumes full accountability for the personal information within its possession and control and has appointed the VP ofBusiness Development, Finance and Operations as the custodian of all privacy matters and legal compliance with privacy laws.
- CanREA obtains personal information directly from the individual to which the information belongs. Individuals are entitled to know how CanREA uses personal information and CanREA will limit the use of any personal information collected only to what is needed for those stated purposes. CanREA will obtain individual consent if personal information is to be used for any other purpose. CanREA will not use that information without the consent of the individual.
- CanREA will retain personal information only for the duration it is needed for conducting business. Once personal information is no longer required, it will be destroyed in a safe and secure manner. However, certain laws may require that certain personal information be kept for a specified amount of time. Where this is the case, the law will supersede this policy.
- In most instances, CanREA will grant individuals access to their personal information upon presentation of a written request and satisfactory identification. If an individual finds errors of fact with their personal information, please notify CanREA as soon as possible to make the appropriate corrections. Should CanREA deny an individual’s request for access to their personal information, CanREA will advise in writing of the reason for such a refusal. The individual may then challenge the decision.
- CanREA vows to protect personal information with the appropriate security measures, physical safeguards, and electronic precautions. CanREA maintains personal information through a combination of paper and electronic files. Where required by law or disaster recovery/business continuity policies, older records may be stored in a secure, offsite location.
- Access to personal information will be authorized only for the employees and other agents of CanREA who require the information to perform their job duties, and to those otherwise authorized by law;
- CanREA’s computer and network systems are secured by complex passwords. Only authorized individuals may access secure systems and databases;
- Active files are kept either in electronic files or in locked filing cabinets;
- Routers and servers connected to the Internet are protected by a firewall, and protected by virus attacks or “snooping” by sufficient software solutions;
- Personal information is not transferred to volunteers, summer students, interns, or other non-paid staff by e-mail or any other electronic format.
- CanREA may use personal information without the individual’s consent under particular circumstances. These situations include, but are not limited to:
- CanREA is under obligation by law to disclose personal information in order to adhere to the requirements of an investigation of the contravention of a regional or federal, under the purview of the appropriate authorities;
- An emergency exists that threatens an individual’s life, health, or personal security;
- The personal information is for in-house statistical study or research;
- The personal information is already publicly available;
- Disclosure is required to investigate a breach of contract.
- Personally identifiable information about the individual that is collected from the website or through affiliate sites.
- Information about the organization collecting the data and how data will be used.
- With whom the data may or may not be disclosed.
- The options available to the individual regarding the collection, use, and disclosure of personal information.
- Any registration or order form asking site visitors to enter personal or financial information will be protected by SSL encryption.
- Site visitors are given the choice to opt out of having their personal information used at the point where the information is gathered.
- The information technology security procedures in place to protect against the destruction, loss, theft, alteration, or misuse of personal information under CanREA possession and control.
- How the individual may access and correct personal information inaccuracies.
- CanREA may share compiled demographic information with its business partners and/or advertisers, but not personal information that can identify an individual.
- This website may contain links to other sites, but CanREA is not responsible for the privacy practices of other organizations’ sites.
- While IP addresses will be logged, in order to administer the site, track visitor movement, and gather demographic information, these IP addresses will not be linked to any personally identifiable information.
Employee obligation to protect CanREA’s confidential information continues after employment with CanREA has terminated. Upon termination of employment or contract, or reassignment all confidential information and documents, including electronic records, and all third-party information entrusted to CanREA must be returned and employee must not disclose any such information. This continuing obligation is particularly important in the case of a departing employee who subsequently works for one of CanREA’s competitors.