GETUS COMMUNICATIONS Ltd. (“GETUS”) and its subsidiaries and affiliates (collectively “GETUS Companies”, and each individually “GETUS Company”) provide a broad range of telecommunications services to customers, including Internet access, and local and long distance services in Canada.
The GETUS Companies (as defined in Part IV below) are committed to maintaining the privacy, confidentiality, security and accuracy of customer and employee personal information.
In 1996, the Canadian Standards Association Model Code for the Protection of Personal Information, CAN/CSA-Q830-96 (the “CSA Code”), was published as a National Standard of Canada. Subsequently, the CSA Code was largely incorporated into the Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5, as amended (“PIPEDA”).
Principle 1 – Accountability The GETUS Companies are responsible for personal information under their control and shall designate one or more persons who are accountable for compliance with the following principles.
GETUS COMMUNICATIONS Ltd.
9327 63 Ave NW
Edmonton, AB T6E 0G2
Email: [email protected]
1.3 The GETUS Companies are responsible for personal information in their possession or control, including information that has been transferred to a third party for processing. The GETUS Companies shall use appropriate means to provide a comparable level of protection while information is being processed by a third party (see Principle 7).
Principle 2 – Identifying Purposes for Collection of Personal Information The GETUS Companies shall identify the purposes for which personal information is collected at or before the time the information is collected.
2.1 The GETUS Companies collect personal information only for the following purposes:
Further references to “identified purposes” mean the purposes identified in this Principle 2.1.
2.2 The GETUS Companies shall specify orally, electronically or in writing the identified purposes to the customer or employee at or before the time personal information is collected. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within the GETUS Companies who shall explain the purposes.
2.3 Unless required by law, the GETUS Companies shall not use or disclose, for any new purpose, personal information that has been collected without first identifying and documenting the new purpose and obtaining the consent of the customer or employee.
Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information The knowledge and consent of a customer or employee is required for the collection, use or disclosure of personal information, except where inappropriate.
3.1 In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual. For example, the GETUS Companies may collect or use personal information without knowledge or consent if it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is a minor, seriously ill or mentally incapacitated.
3.2 In obtaining consent, the GETUS Companies shall use reasonable efforts to ensure that a customer or employee is advised of the identified purposes for which personal information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the customer or employee.
3.3 Generally, the GETUS Companies shall seek consent to use and disclose personal information at the same time they collect the information. However, the GETUS Companies may seek consent to use and disclose personal information after it has been collected but before it is used or disclosed for a new purpose.
3.4 The GETUS Companies will require customers to consent to the collection, use or disclosure of personal information as a condition of the supply of a product or service only if such collection, use or disclosure is required to fulfill the identified purposes.
3.5 In determining the appropriate form of consent, the GETUS Companies shall take into account the sensitivity of the personal information and the reasonable expectations of their customers and employees.
3.6 In general, the use of products and services by a customer, or the acceptance of employment or benefits by an employee, constitutes implied consent for the GETUS Companies to collect, use and disclose personal information for all identified purposes.
3.7 A customer or employee may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Customers and employees may contact the GETUS Companies for more information regarding the implications of withdrawing consent.
Principle 4 – Limiting Collection of Personal Information The GETUS Companies shall limit the collection of personal information to that which is necessary for the purposes identified. The GETUS Companies shall collect personal information by fair and lawful means.
4.1 The GETUS Companies collect personal information primarily from their customers or employees.
4.2 The GETUS Companies may also collect personal information from other sources including credit bureaus, employers or personal references, or other third parties that represent that they have the right to disclose the information.
Principle 5 – Limiting Use, Disclosure and Retention of Personal Information The GETUS Companies shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. The GETUS Companies shall retain personal information only as long as necessary for the fulfillment of those purposes.
5.1 In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual. (See Principle 3.1)
5.2 In addition, the GETUS Companies may disclose a customer’s personal information to:
5.3 The GETUS Companies may disclose personal information about their employees:
5.4 Only those employees of the GETUS Companies who require access for business reasons, or whose duties reasonably so require, are granted access to personal information about customers and employees.
5.5 The GETUS Companies shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about a customer or employee, the GETUS Companies shall retain, for a period of time that is reasonably sufficient to allow for access by the customer or employee, either the actual information or the rationale for making the decision.
5.6 The GETUS Companies shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.
Principle 6 – Accuracy of Personal Information Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
6.1 Personal information used by the GETUS Companies shall be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a customer or employee.
6.2 The GETUS Companies shall update personal information about customers and employees as and when necessary to fulfill the identified purposes or upon notification by the individual.
Principle 7 – Security Safeguards The GETUS Companies shall protect personal information by security safeguards appropriate to the sensitivity of the information.
7.1 The GETUS Companies shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. The GETUS Companies shall protect the information regardless of the format in which it is held.
7.2 The GETUS Companies shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.
7.3 All employees of the GETUS Companies with access to personal information shall be required as a condition of employment to respect the confidentiality of personal information.
Principle 8 – Openness Concerning Policies and Practices The GETUS Companies shall make readily available to customers and employees specific information about their policies and practices relating to the management of personal information.
8.1 The GETUS Companies shall make information about their policies and practices easy to understand, including:
8.2 The GETUS Companies shall make available information to help customers and employees exercise choices regarding the use of their personal information and the privacy-enhancing services available from the GETUS Companies.
Principle 9 – Customer and Employee Access to Personal Information The GETUS Companies shall inform a customer or employee of the existence, use and disclosure of his or her personal information upon request and shall give the individual access to that information. A customer or employee shall be able to challenge the accuracy and completeness of the information and to have it amended as appropriate.
9.1 Upon request, the GETUS Companies shall afford to a customer or an employee a reasonable opportunity to review the personal information in the individual’s file. Personal information shall be provided in understandable form within a reasonable time and at minimal or no cost to the individual.
9.2 In certain situations, the GETUS Companies may not be able to provide access to all of the personal information that they hold about a customer or employee. For example, the GETUS Companies may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, the GETUS Companies may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law. If access to personal information cannot be provided, the GETUS Companies shall provide the reasons for denying access upon request.
9.3 Upon request, the GETUS Companies shall provide an account of the use and disclosure of personal information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, the GETUS Companies shall provide a list of organizations to which it may have disclosed personal information about the individual when it is not possible to provide an actual list.
9.4 In order to safeguard personal information, a customer or employee may be required to provide sufficient identification information to permit the GETUS Companies to account for the existence, use and disclosure of personal information and to authorize access to the individual’s file. Any such information shall be used only for this purpose.
9.5 The GETUS Companies shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file. Where appropriate, the GETUS Companies shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.
9.6 A customer can obtain information or seek access to his or her individual file by contacting a designated representative at 1.877.779.1575 in English or 1.800.368.6909 in French, or by sending an email containing such a request in English or French to [email protected]
9.7 An employee can obtain information or seek access to his or her individual file by contacting his or her immediate supervisor within the applicable GETUS Company.
10.1 The GETUS Companies shall maintain procedures for addressing and responding to all inquiries or complaints from their customers and employees about the GETUS Companies’ handling of personal information.
10.2 The GETUS Companies shall inform their customers and employees about the existence of these procedures as well as the availability of complaint procedures.
For inquiries, complaints or more information contact:
GETUS COMMUNICATIONS Ltd.
9327 63 Ave NW
Edmonton, AB T6E 0G2
Email: [email protected]
Q. What is personal information? A. Personal information is information about an identifiable individual. This includes information about your product and service subscriptions and usage.
Q. Why does GETUS collect information? A. Collecting information helps us serve you better. The GETUS Companies collect personal information only for the following purposes:
Your personal information will not be used for any other purpose without your consent.
Q. Why do we share information among the GETUS Companies? A. Sharing information among the GETUS Companies helps us understand your full needs and serve you better. Such sharing helps us identify your information, communication, and entertainment needs, and provide you with relevant information, advice, products and services. In some cases, certain products and service are available only from some of the GETUS Companies and not others. Therefore, in such cases, the sharing of information may also be necessary for the provision of certain bundles of products and/or services. Should you identify incorrect or outdated information to us, we will make the necessary changes promptly.
Q. Can I withdraw my consent to the sharing of information among the GETUS Companies when such sharing is for the purpose of promoting products and services? A. You may decide that you prefer us not to share your personal information among the GETUS Companies to promote products and services. If this is the case, you may advise us by calling us at 1.877.779.1575 in English or 1.800.368.6909 in French.
Q. Do you share personal information with any other parties, and if so, who? A. Our general policy is not to provide personal information to any party outside of the GETUS Companies. However, there are certain limited circumstances, outlined below, in which it is necessary to do so. When we do provide personal information to third parties, we provide only that information that is required in the circumstances. Information provided to third parties is used only for the purpose stipulated and is subject to strict terms of confidentiality. Employees of the companies to whom we may provide information must adhere to our privacy standards.
Third parties to whom we may have to provide personal information include:
Q. How do the GETUS Companies safeguard personal information? A. We take all of the necessary precautions to ensure the safeguarding of your information, whether it is stored electronically or in paper format. In all cases, information is retained in secure facilities, protected from unauthorized access and kept only as long as is reasonably required. For example, our electronic files are backed up for redundancy, password protected and accessible only by authorized employees, on a need-to-know basis.
Q. What do I do if I have further questions or concerns? A. If you have further questions or concerns about your privacy, you can contact us at 1.800.111.1111 in English or 1.800.111.1111 in French, or by sending an email containing such a request in English or French to [email protected] Our customer service representatives will assist you in this regard
You should write to:
GETUS COMMUNICATIONS Ltd.
9327 63 Ave NW
Edmonton, AB T6E 0G2
Email: [email protected]
Please note that complaints to the Privacy Ombudsman must be in writing and may be delivered only by mail or fax.
Q. Is there a further complaint procedure? A. If the GETUS Privacy Ombudsman does not resolve a privacy issue to your satisfaction, you may file a complaint with the Privacy Commissioner of Canada by writing to:
Privacy Commissioner of Canada
112 Kent Street
Place de Ville
Tower B, 3rd Floor
For a copy of the Personal Information Protection and Electronic Documents Act, please see the Privacy Commissioner of Canada website at http://www.priv.gc.ca/.
For copies of the CSA Model Code for the Protection of Personal Information contact:
Canadian Standards Association
5060 Spectrum Way
For more information on the CSA Model Code visit the CSA Web Site at: http://www.csa.ca/cm/ca/en/search.
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