Certain of the practices discussed in this Policy reflect requirements set out in both federal and provincial privacy legislation. Intelliware’s policy is to at all times adhere to the requirements of the law and to be responsive to our clients and employees who expect us to respect their privacy and protect their personal information.
Personal information is information about an identifiable individual. It includes information such as age, identification numbers or codes, income, personal contact information and other personal information. It does not include the name, title, business address or business telephone number of an employee of an organization such as Intelliware or our corporate clients.
When a visitor to Intelliware’s website is required to submit registration information as a prerequisite for accessing any content area of Intelliware’s website or to use any of its interactive services, contests or newsgroups or e-Commerce applications, Intelliware will not share or sell that personal information about our users to any outside agency, advertiser or other third party unless the user was made aware of this possibility prior to submitting their personal information.
Intelliware will not supply e-mail addresses to any third party without having first obtained the consent of a user. Intelliware tracks user IP addresses for the purposes of systems administration, demographic profiling and traffic logging, but Intelliware will not use IP addresses to try to identify individual users of the Intelliware Web site.
Principle 1 – We Are Accountable For The Personal Information In Our Possession.
Principle 2 – Intelliware will disclose why we are collecting personal information when the information is collected.
In most instances, Intelliware will collect, use or disclose personal information about clients only for the purpose of providing professional services. Each Services Agreement includes an explanation of how confidential information will be handled, what use will be made of it and with whom it may be shared in order to provide professional services.Intelliware will also collect and use personal information about clients, prospective clients and alumni, for the purpose of sending news and information updates or invitations to events hosted or sponsored by Intelliware. Personal Information may also be shared internally in order to allow us to offer services or products that may be of interest to clients.
Intelliware collects personal information about our employees in order to pay them, comply with laws, provide them with benefits, administer performance management tools, to improve on and manage programs, policies and employee relations and generally to establish, manage or terminate the employment relationship. In certain cases, Intelliware may also aggregate employee personal information to provide business metrics and evaluate the effectiveness of our HR programs, but this aggregated information will not allow the identification of any individual.
We may also use or disclose employee information in the course of investigating, negotiating or completing a sale, financing or other business transaction involving all or any part of our business. We also collect personal information from individuals seeking employment with Intelliware. When Intelliware collects personal information, we will disclose the reasons why we require such information, what use will be made of it and with whom it may be shared. Collection may occur without knowledge or consent as permitted by law, including collection in the course of an investigation.
Principle 3 – Intelliware will not collect, use or disclose personal information without informed consent.
How Will We Ask for Consent?
Client Personal Information
The Terms and Conditions of every Intelliware professional services engagement are documented in each Services Agreement and Statements of Work. These Terms and Conditions include a discussion about how Intelliware may use and disclose personal information. By signing the Services Agreement, the client will be providing its consent to the collection, use and disclosure described in the Terms and Conditions.
Forms and applications used to provide human resources-related services will describe the purposes for which their personal information is required and with whom it will be shared.Employment candidates will also be advised of the purposes for which their personal information is being collected.
What happens if consent is not given? What happens if consent is at a later date?
Intelliware clients always have the option not to provide their consent to the collection, use and distribution of their personal information, or to withdraw their consent at a later stage. Where a client chooses not to provide us with permission to collect, use or disclose personal information, we may not have sufficient information to continue providing the client with our services.Where an employee or candidate for employment chooses not to provide us with permission to collect, use or disclose personal information, we may not be able to employ them, continue to employ them or to provide them with benefits.
Principle 4 – Intelliware limits the amount and type of personal information we collect.
Intelliware will limit the collection of personal information to that which is reasonably required to provide our services or operate our business.
Principle 5 – Intelliware will use and disclose personal information only for the purposes for which we have received consent. We will keep personal information only as long as necessary to accomplish these purposes.
Use of Personal Information
If Intelliware intends to use personal information for any purpose not previously identified to the individual, we will obtain their prior consent. However, Intelliware may use personal information without consent for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual, including steps taken under our pandemic and disaster recovery policies, or as otherwise permitted by law including for purposes of an investigation.
We may also disclose personal information without consent as permitted or required by applicable federal and provincial privacy laws, including:
1. To comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction or to comply with rules of conduct required by regulatory bodies.
2. To a government institution that has requested the information, identified its lawful authority, and indicates that disclosure is for the purpose of enforcing, carrying out an investigation, or gathering intelligence relating to any federal, provincial or foreign law; or suspects that the information relates to national security or the conduct of international affairs; or is for the purpose of administering any federal or provincial law.
3. To an investigative body or government institution on our initiative when we believe the information concerns a breach of an agreement, or a contravention of a federal, provincial, or foreign law, or we suspect the information relates to national security or the conduct of international affair.
Retention of Personal Information
We keep a record of the work performed by Intelliware employees. This record may include personal information and will be retained until such information is no longer reasonably required for legal, administrative, audit or regulatory purposes. This information is safeguarded against inappropriate access, as discussed in Principle “7″ below.Intelliware retains personal information about current and past employees in accordance with employment laws and standards.
We will destroy human resources and other files containing employee personal information when such information is no longer reasonably required for legal, administrative, audit or regulatory purposes. Certain additional information may be retained to administer and keep former employees informed about our corporate activities. Former employees may request at any time that they not be contacted.
Personal information collected from individuals seeking employment with Intelliware will be retained by Intelliware for a period up to 60 months so that Intelliware may contact the applicant about other positions that may also be of interest. If a candidate is hired, the personal information collected during the application process will be retained in order to establish and manage the employment relationship.
Principle 6 – Intelliware will endeavour to keep accurate the personal information in our possession or control.
In order to provide clients with a professional level of service, the personal information that we collect must be accurate, complete and current. From time to time, clients may be asked to update their personal information. Clients are encouraged to advise their project manager of any changes to their personal information that may be relevant to the services we are providing.
In order to establish and manage the employee relationship, the personal information that we collect must be accurate, complete and current. From time to time, employees may be asked to update their personal information. Employees are encouraged to advise the People Shared Services Team of any changes to their personal information.
Principle 7 – Intelliware protects personal information with safeguards appropriate to the sensitivity of the information.
Intelliware will protect personal information by using physically secure facilities, industry standard security tools and practices, and clearly defined internal policies and practices. Security measures are in place to protect the loss, misuse and alteration of the personal information under our control. Personal information is stored in secure environments that are not available to the public (e.g., restricted access premises, locked rooms and filing cabinets).
These third party processors are prohibited from using personal information, except for the specific purpose(s) for which we supply it to them.In some circumstances, personal information may be processed and stored outside of Canada by Intelliware or a third party processor, and such personal information may be subject to disclosure in accordance with the laws applicable in the jurisdiction in which the information is processed or stored. These laws may not provide the same level of protection as Canadian privacy laws.
Principle 8 – Intelliware will be open about the procedures used to manage personal information.
Principle 9 – At their request, Intelliware will advise individuals of what personal information we have in our possession or control about them, what it is being used for, and to whom and why it has been disclosed.
Clients have the right to review and obtain a copy of their personal information on record in our individual offices by contacting their Project Manager.Employees have the right to review and obtain copies of their personal information on record by contacting the Vice-President of Human Resources.In most instances, individuals will receive a response to their access request within 10 days. If an individual has any concerns about the access that is provided, they are encouraged to contact our Privacy Officer at [email protected] at (416) 762-0032.
Intelliware will respond to individual complaints and questions relating to privacy. We will investigate and attempt to resolve all complaints. To challenge compliance with this Policy, individuals should forward their concerns in writing to Intelliware’s Privacy Officer. The Privacy Officer will ensure that a complete investigation of all complaints has been undertaken and will report their findings to the individual in most instances within 30 days.
We know that protecting the privacy of our clients and employees is important. Any questions or concerns about your privacy and our role in protecting it, please contact our Privacy Officer at [email protected] or at (416) 762-0032.