As of July 2016
Acting as a 3rd party processor
As a client services firm, Young Associates frequently comes into contact with personal information held by our clients via our role as a third party processor. In these instances, we make every effort to support our clients in meeting their legislative requirements in regard to the privacy of personal information, and treat all sensitive data that we interact with according the privacy standards of PIPEDA and CASL.
Personal Information and PIPEDA
According to PIPEDA:
Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:
- age, name, ID numbers, income, ethnic origin, or blood type;
- opinions, evaluations, comments, social status, or disciplinary actions; and
- employee files, credit records, loan records, medical records, existence of a dispute between a consumer and a merchant, intentions (for example, to acquire goods or services, or change jobs).
Personal information does not include the name, title, business address or telephone number of an employee of an organization.
Young Associates bases its privacy activities on the 10 principles of fair information practices, our responsibilities under PIPEDA:
We have a designated privacy officer responsible for facilitating the organization’s compliance via policy and practice. Young Associates is accountable for all personal information held by us or transferred to a third party for processing or other administrative functions.
Young Associates identifies why personal information is collected before or at the time of collection and documents why it is needed and how it will be used. The individual from whom the information is collected is informed of why it is needed and their consent is sought in advance if a new purpose for its use is identified. We collect personal information to provide relevant products and/or services and maintain commercial relations, to recommend products and/or services, to manage our business, and to meet regulatory and legal requirements.
Young Associates secures consent from individuals before or at the time of the collection of personal information, as well as when a new use is identified, by communicating the purposes for the collection, use, or disclosure of the data.
Young Associates only collects the personal information required to carry out relevant work. We do not collect personal information indiscriminately nor in a deceptive manner.
Limiting use, disclosure, and retention:
We limit use of personal information to the purpose for which it was collected, unless the individual consents to another use, or its use or disclosure is legislatively authorized. Personal information is maintained only as long as it is necessary at which point it is disposed of and/or anonymized.
Young Associates makes every effort to ensure the accuracy of personal information in its possession.
Young Associates makes every effort to ensure that personal information is protected against loss, theft, unauthorized access, disclosure, copying use, or modification, regardless of its format.
Young Associates responds to individuals who seek to know if we have personal information about them. We make every effort to provide a clear explanation around how the information has been used and if applicable, to which organizations it has been disclosed. We make every effort to give individuals access to their information, to correct and/or amend any inaccurate information, and to provide a copy of the information (if requested) or an explanation of why access cannot be provided.
Young Associates makes a record of any disagreements and advises third parties where appropriate.
If you have a complaint about the role of Young Associates as it relates to your personal information, please direct it to our Privacy Officer (contact information below). We make every effort to cooperate with you and/or the Privacy Commissioner, to resolve the privacy concern and if necessary, will take the appropriate measures to correct our information handling practices and policies.
Electronic messages and CASL
From time to time, Young Associates distributes electronic messages for promotional purposes. Our policy and procedures for sending such messages adhere to the legislative requirements of Canada’s Anti-spam legislation. In all instances, either express or implied consent is secured prior to sending the message, and personal contact information is only used for the purpose intended. Our electronic messages all contain a clear opt out / unsubscribe option. We do not share / disclose contacts with third parties.
Please communicate all privacy related matters, including requests for information and complaints, to:
Privacy Officer, Young Associates
675 King St. W, Suite 203
Toronto ON M5V 1M9