What is personal information?
Personal information includes factual or subjective information about an identifiable individual. It does not include the name, title, business address or telephone number of an employee of an organization. However, it does include personal email addresses, credit card information, ID numbers and so on. It also includes personally identifiable information (ie. PIN numbers, access cards and passwords) which can be linked to an identifiable individual.
Who is responsible for the protection of personal information held by the Company?
The following requirements shall be met by the Company unless exempted under PIPEDA or PIPA:
- (i) Accountability
- The Company is responsible for personal information under its control and shall designate a Chief Privacy Officer to be accountable for the Company’s compliance with PIPEDA and PIPA.
- (ii) Identifying Purposes
- The purposes for which personal information is collected shall be identified by the Company at or before the time the information is collected.
- (iii) Consent
- The knowledge and consent of the individual are required for the collection, use or disclosure of personal information.
- (iv) Limiting Collection
- The collection of personal information shall be limited to that which is necessary for the purposes identified by the Company.
- (v) Limiting Use, Disclosure and Retention
- Personal information shall not be used or disclosed for purposes other than those for which it was collected except with the consent of the individual or as permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
- (vi) Accuracy
- Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
- (vii) Safeguards
- Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
- (viii) Openness
- The Company shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.
- (ix) Individual Access
- Upon request, an individual shall be informed of the existence, use and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
- (x) Challenging Compliance
- An individual shall be able to address a challenge concerning compliance with the above principles to the Chief Privacy Officer or his delegate.
All Company employees who collect, maintain and/or use personal information are responsible for insuring that the collection, use and disclosure of this information is carried out in accordance with this policy and relevant procedures.
The Chief Privacy Officer or his delegate is accountable for the Company’s policies and practices with respect to the management of personal information, and is the individual to whom complaints and inquiries can be forwarded.
Swift Messenger Delivery Systems
80 Colonnade Road Unit 8
Ottawa, Ontario K2E 7L2