Privacy Policy

Coles Bridge

Personal Information Protection Policy

(Privacy Policy)

At Coles Bridge, we are committed to providing our subscribers with exceptional service.  As providing this service involves the collection, use and disclosure of some personal information about our subscribers, protecting their personal information is one of our highest priorities.

While we have always respected our subscribers privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of Ontario’s Personal Information Protection Act (PIPA).  PIPA, which came into effect on January 1, 2004, sets out the ground rules for how Ontario businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our subscribers of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting subscribers’ personal information.  Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our subscribers’ personal information and allowing our subscribers to request access to, and correction of, their personal information.
Definitions

Personal Information –means information about an identifiable individual.  (Example: Name and Email address). Personal information does not include contact information (described below).

Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.  Contact information is not covered by this policy or PIPA.

Webmaster – means the individual designated responsibility for ensuring that Coles Bridge complies with this policy and PIPA.

 

Policy 1 – Collecting Personal Information
1.1  Unless the purposes for collecting personal information are obvious and the subscriber voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2  We will only collect subscriber information that is necessary to fulfill the following purposes:

·       To open and manage an account;

·       To deliver requested products and services

·       To process a newsletter subscription;

 

Policy 2 – Consent

2.1  We will obtain subscriber consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2  Consent can be provided or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the subscriber voluntarily provides personal information for that purpose.

2.3  Consent may also be implied where a subscriber is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the subscriber does not opt-out.

2.4  Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), subscribers can withhold or withdraw their consent for Coles Bridge to use their personal information in certain ways.  A subscriber’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product.  If so, we will explain the situation to assist the subscriber in making the decision.

2.5  We may collect, use or disclose personal information without the subscriber’s knowledge or consent in the following limited circumstances:

·       When the collection, use or disclosure of personal information is permitted or required by law;

·       In an emergency that threatens an individual’s life, health, or personal security;

·       When the personal information is available from a public source (e.g., a telephone directory);

·       When we require legal advice from a lawyer;

·       For the purposes of collecting a debt;

·       To protect ourselves from fraud;

·       To investigate an anticipated breach of an agreement or a contravention of law

 

Policy 3 – Using and Disclosing Personal Information

3.1  We will only use subscriber personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:

·       To conduct subscriber surveys in order to enhance the provision of our services;

·       To contact our [subscribers] directly about products and services that may be of interest;]

3.2  We will not use subscriber personal information for any additional purpose unless we obtain consent to do so.

3.3  We will not sell subscriber lists or personal information to other parties.

 

Policy 4 – Retaining Personal Information

4.1  If we use subscriber personal information to make a decision that directly affects the subscriber, we will retain that personal information for at least one year so that the subscriber has a reasonable opportunity to request access to it.

4.2  Subject to policy 4.1, we will retain subscriber personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

 

Policy 5 – Ensuring Accuracy of Personal Information

5.1  We will make reasonable efforts to ensure that subscriber personal information is accurate and complete where it may be used to make a decision about the subscriber.

5.2  Subscribers may request correction to their personal information in order to ensure its accuracy and completeness.  A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.

5.3  If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required.

 

Policy 6 – Securing Personal Information

6.1  We are committed to ensuring the security of subscriber personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2  The following security measures will be followed to ensure that subscriber personal information is appropriately protected:

·       the use of user IDs, passwords, encryption, firewalls;

·       restricting employee access to personal information as appropriate;

·       contractually requiring any service providers to provide comparable security measures.

6.3  We will use appropriate security measures when destroying subscriber’s personal information such as deleting electronically stored information.

6.4  We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

 

Policy 7 – Providing Subscribers Access to Personal Information

7.1  Subscribers have a right to access their personal information, although the only personal information Coles Bridge will have is your name and email address.

7.2  A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.

7.3  Upon request, we will also tell subscribers how we use their personal information.

7.4  We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

 

Policy 8 – Questions and Complaints: 

8.1  The webmaster is responsible for ensuring Coles Bridge’s compliance with this policy and the Personal Information Protection Act.

8.2  Subscribers should direct any complaints, concerns or questions regarding Coles Bridge’s compliance in writing to the webmaster. If the webmaster is unable to resolve the concern, the subscriber may also write to the Information and Privacy Commissioner of Ontario.

Contact information for Coles Bridge’s webmaster:  greg@midlanddbc.com