Collection and Use of Personal Information
(a) The Company has determined that personal information is collected in the ordinary course of business from various sources, namely: employees, customers and shareholders.
(b) If the personal information collected by the Company will be used for a new purpose, it will also be documented and consent of the individual will be obtained before the information can be used for that purpose. Collection of the information will normally be done in writing; however, it may be done verbally.
(c) The Company will not collect personal information indiscriminately. Both the amount and the type of information collected will be limited to that which is necessary to fulfill the purposes identified.
(a) The Company will make a reasonable effort to ensure that the individual is advised of the purposes for which the information will be used.
(b) The Company will not, as a condition of the supply of a product or service, require an individual to consent to the collection, use or disclosure of information beyond that required to fulfill the explicitly specified, and legitimate purposes.
(c) Consent will not be obtained through deception.
(d) Consent may also be given by an authorized representative (such as a legal guardian or a person having power of attorney).
(e) An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. The Company will inform the individual of the implications of such withdrawal.
Accuracy of Personal Information
(a) Information will be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about the individual.
(b) The Company will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected.
(c) Personal information that is used on an ongoing basis, including information that is disclosed to third parties, will generally be accurate and up-to-date, unless limits to the requirement for accuracy are clearly set out.
Protection of Personal Information
The Company will protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification by implementing the following safeguards and security measures:
(a) Access to personal information is restricted to those employees who require the information to perform their duties.
(b) Personal information that is stored in databases and computer systems is protected by the use of passwords, encryption files and firewalls.
(c) Personal information in paper form retained in cabinets and desk drawers is locked-up.
(d) Where personal information is transferred to external sources for processing, the Company has entered into contractual relationships where third parties are involved, in order that such personal information is protected and safeguarded.
Retention of Personal Information
North Shore Off-Road has developed guidelines and procedures to be adhered to with respect to the retention of personal information. These guidelines include, amongst other things, minimum and maximum retention periods and where personal information has been used to make a decision about an individual, such information is retained long enough to allow the individual access to the information after the decision has been made.
Destruction of Personal Information
North Shore Off-Road has developed guidelines and procedures to be adhered to with respect to the destruction of personal information, which includes, amongst other things:
(a) established dates as to when the personal information is no longer required;
(b) how the personal information is to be destroyed, erased, or made anonymous; and
(c) standards of care to be used in the disposal or destruction of personal information, to prevent unauthorized parties from gaining access to the information.
Communication Materials, Brochures, etc.
(a) the name or title, the address, fax and phone numbers and e-mail address of the person who is accountable for the Company's policies and practices and to whom complaints or inquiries can be forwarded;
(b) how to access personal information held by the Company;
(c) a description of the type of personal information held by the Company, including a general account of its use;
(d) a copy of any brochures or other information that explains the Company's policies, standards, or codes; and (e) what personal information is made available to related organizations (e.g., subsidiaries).
Access to Personal Information
(a) Upon request, the Company will inform an individual whether or not the Company holds personal information about the individual. The Company may indicate the source of this information. The Company will allow the individual access to this information. In addition, the Company will provide details on the use that has been made or is being made of this information and details of the third parties to which it has been disclosed.
(b) An individual may be required to provide sufficient information to permit the Company to provide details on the existence, use, and disclosure of personal information. The information provided will only be used for this purpose.
(c) In providing details of third parties to which it has disclosed personal information about an individual, the Company will attempt to be as specific as possible. When it is not possible to provide a list of the organizations to which it has actually disclosed information about an individual, the Company will provide a list of organizations to which it may have disclosed information about the individual.
(d) The Company will respond to an individual's request within a reasonable time and at minimal or no cost to the individual. The requested information shall be provided or made available in a form that is generally understandable. For example, if the Company uses abbreviations or codes to record information, an explanation will be provided.
(e) When an individual successfully demonstrates the inaccuracy or incompleteness of personal information, the Company will amend the information as required. Depending upon the nature of the information challenged, amendment involves the correction, deletion, or addition of information. Where appropriate, the amended information will be transmitted to third parties having access to the information in question.
(f) If a challenge is not resolved to the satisfaction of the individual, the substance of the unresolved challenge will be recorded by the Company. When appropriate, the existence of the unresolved challenge will be transmitted to third parties having access to the information in question.
Challenging Compliance, Complaints and Inquiries
The Privacy Officer, 1440 Columbia Street, North Vancouver, BC, V7J 1A2
or by e-mail to firstname.lastname@example.org
or by telephone to: 1-800-416-7656
(b) All correspondence communicated internally and externally regarding the collection and use of personal information, will include details on how to contact the Privacy Officer.
(c) Complaints received by the Privacy Officer will be documented and investigated, indicating the nature of the complaint and if necessary, communicated to the Privacy Team for review and discussion. If a complaint is found to be justified, the Company will take appropriate measures, including, if necessary, amending its policies and practices.
(b) The Company has made its employees aware of the importance of maintaining the confidentiality of personal information.