• Personal Information – Personal information means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization.
• PIPEDA – All Canadian organizations engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Canadian Standards Association Model Code for the Protection of Personal Information incorporated by reference into PIPEDA.
Personal Information at BOCI
BOCI provides branding, marketing and public relations services to a wide range of clients. In doing so, we may collect and use personal information. As well, BOCI may send information and marketing materials concerning developments in our industry and our services to individuals.
Collecting Personal Information
We collect personal information fairly and in accordance with the law. Generally, we collect your personal information directly from you. Such collection may be done at the start of our relationship or during the course of our engagement. With respect to our institutional clients, we may collect information about your directors, officers, independent contractors and employees.
Sometimes we may obtain information about you from other sources including, for example:
1) from a government agency or registry;
2) your website and other public sources of information;
3) other professionals who serve you; and
4) other parties or participants in a commercial transaction.
We may collect personal information from candidates for employment to assess qualifications.
Your knowledge and consent of our collection, use and disclosure of your personal information is important. We rely on the following actions by you as indications of your consent to our existing and future personal information practices:
1) Your voluntary provision of personal information directly to BOCI or through a representative for the purpose of acquiring a product or service we offer, or for the purpose of participating in or attending an event or promotion we offer such as signing up for our newsletter or connecting with us on our social media pages (including information previously provided to BOCI);
2) Your express consent or acknowledgement contained within a written, verbal or electronic Services Agreement;
3) Your consent solicited by BOCI (or our agent, contractor or representative) for a specified purpose;
5) Your consent given through your authorized representative such as a legal guardian, agent or holder of a power of attorney.
BOCI may provide some of its products, services and benefits through third parties with privacy policies different from ours. We will use reasonable efforts to inform you of the identity of any such third parties and contact information for those parties. Although we use reasonable efforts to associate only with reputable entities, BOCI shall not be responsible for or liable for the information handling practices of any such third party.
Since the internet is a global environment using the internet to collect information necessarily involves transmitting data on an international basis. You agree to the transfer of your personal information outside your country of residence and acknowledge that countries to which BOCI may transfer information may not have as comprehensive a level of data protection as in your country.
You may connect to one or more social networks (such as Facebook, Twitter or LinkedIn) and, if you choose to do so, any information you provide on any such network that constitutes personal information may be collected, used or disclosed by us without your consent.
Use of Personal Information
We use your personal information to provide our services to you, to administer our internal administrative databases, to build and to maintain our expertise and knowledge, and to include you in our information distribution and marketing activities. If you no longer wish to receive information about developments in the industry or our services, you can ask us not to send any further material.
Disclosure of Personal Information
BOCI does not disclose your personal information to third parties to enable them to market their products and services.
Under certain circumstances we may disclose your personal information. Some examples are:
1) when you have consented to the disclosure;
2) when we are required or authorized by law to do so, including, for example, if a court issues a warrant or a subpoena;
3) when the service we are providing to you require us to give your information to third parties (in which case your consent will be implied, unless you tell us otherwise at the outset of the Services Agreement;
4) where it is necessary to collect our fees;
5) if we engage a third party to provide administrative services to us (such as computer back-up services, archival file storage, or insurance) and the third party is bound by obligations regarding privacy that are consistent with this policy; and
6) in the event of a merger by or growth of BOCI (in which case the third party will be bound by obligations regarding privacy that are consistent with this policy)
Updating Your Information
Since we use your personal information to provide our services to you, it is important that the information be accurate and up-to-date. If, during the course of the Services Agreement, any of your information changes, please inform us so that we can make any necessary changes. We may also periodically inquire of you whether your personal information is accurate and up-to-date.
Securing Personal Information
BOCI takes precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your personal information are:
1) premises security;
2) deploying technological safeguards like security software and firewalls to prevent unauthorized computer access or “hacking”; and
3) internal password and security policies.
You should be aware that e-mail is not an entirely secure medium, and you should be aware of this when contacting us to send personal or confidential information.
Accessing Personal Information
You may ask for access to personal information we hold about you. Detailed requests that require archive or other retrieval costs may be subject to our normal fees. Your rights to access your personal information are not absolute. There are a number of situations where we may deny access. If we deny your request for access to, or refuse a request to correct personal information, we will provide a reason or reasons for doing so.
To help us make credit decisions about clients, to try to prevent fraud, and to check the identity of new clients, on occasion we may request information about you from the files of consumer reporting agencies.
Our website contains links to other sites, which are not governed by this policy.
Requests for Access
If you have any questions, or wish to access your personal information, please contact us or write to our Privacy Contact at:
270 Blantyre Avenue
If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at:
112 Kent Street
Ottawa, ON K1A 1H3