Privacy Policy
The Ferrier Wire Good Company’s Commitment to Privacy
At Ferrier Wire Goods Company Ltd., respecting privacy is an important part of our commitment to our client/customers and employees.
Our commitment to privacy is reflected in The Ferrier Wire Goods Company Ltd. Privacy Code, which has been developed to comply with the relevant portions of the Personal Information and Electronic Documents Act (Canada). In this respect, The Ferrier Wire Goods Company Ltd. Privacy Code governs our behavior with respect to the collection, use and disclosure of our client/customers’ and employees’ personal information.
We have also developed The Ferrier Wire Goods Company Ltd. Privacy Protection Pledge to explain why we collect personal information, how we use personal information and how we keep such information protected. A copy of The Ferrier Wire Goods Company Ltd. Privacy Protection Pledge is being made available to all of our client/customers and employees. You can also review it at www.ferrierwire.com.
THE FERRIER WIRE GOODS COMPANY LIMITED PRIVACY PROTECTION PLEDGE
At Ferrier Wire Goods Company Ltd., we respect your privacy. That is why we have developed The Ferrier Wire Goods Company Ltd. Privacy Code of which the objective is to specify Ferrier Wire Goods Company Ltd.’s guidelines for the collection, use and disclosure of your personal/company information.
The Ferrier Wire Goods Company Ltd. Privacy Code was developed to comply with the relevant portions of the Personal Information Protection and Electronic Documents Act (Canada). We have drafted The Ferrier Wire Goods Company Ltd. Privacy Code to facilitate our compliance with this new legislation and to demonstrate our commitment to protecting your personal/company information.
We have also developed The Ferrier Wire Goods Company Ltd. Privacy Protection Pledge. We want you to understand the purposes for which we collect personal/company information. We also want to make certain that we have your consent to continue to collect, use and disclose your personal/company information for those purposes.
The following is a brief synopsis of our privacy practices:
Why do we need to collect your personal/company information?
If you are a Ferrier Wire Goods Company Ltd. client/customer or employee, Ferrier Wire Goods Company Ltd. may have collected some basic information about you. We respect your privacy, which is why we collect personal/company information only for the following purposes:
- For purposes of contact.
- To establish credit terms.
- To enable Ferrier Wire Goods Company Ltd. to service our clients/customers and employees as efficiently as possible.
- To allow Ferrier Wire Goods Company Ltd. to successfully continue is commercial activities.
When do we disclose personal/company information?
There is a variety of circumstances where we may need to disclose some personal/company information about our clients/customer or employees. Here are some examples:
- Government inquiries/audits and annual financial audit.
- Credit reference requests.
- Law enforcement/legal requests and inquiries.
How do we protect your personal information?
In order to protect your personal information, Ferrier Wire Goods Company Ltd.:
1. will not collect, use or disclose your personal information for any purpose other than those identified above, except with your further consent;
2. will protect your personal information with appropriate security safeguards;
3. will protect the confidentiality of your personal information when dealing with other organizations;
4. will strive to keep your personal information as accurate and up to date as is necessary for the purposes identified above; and
5. will honour any request you may make for access to your personal information.
What are your choices?
We would like to have your consent to continue to collect, use and disclose your personal/company information for the purposes identified above. However, you do have choices and can refuse or withdraw your consent as follows:
1. You may refuse to provide your personal information to us.
2. You may also withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice.
However, in either case, this may limit our ability to serve you.
If you have any questions or concerns about our personal information management system, please contact the Ferrier Wire Goods Company Ltd. Privacy Officer at 416-769-5280, toll-free at 888-769-5280 or via privacy@ferrierwire.com. Otherwise, we will assume that we have your consent to collect, use and disclose your personal/company information for the purposes identified above and in a manner consistent with The Ferrier Wire Goods Company Ltd. Privacy Code.
Please visit the Office of the Privacy Commissioner of Canada’s web site at www.privcom.gc.ca.
THE FERRIER WIRE GOODS COMPANY LTD. PRIVACY CODE
Table of Contents
Introduction
Summary of Principles
Scope and Application
Definitions
The Ferrier Wire Goods Company Ltd. Privacy Code in Detail
Principle 1 - Accountability
Principle 2 - Identifying Purposes for Collection of Personal Information
Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information
Principle 4 - Limiting Collection of Personal Information
Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information
Principle 6 - Accuracy of Personal Information
Principle 7 - Security Safeguards
Principle 8 - Openness Concerning Policies and Procedures
Principle 9 - Client/Customer and Employee Access to Personal Information
Principle 10 - Challenging Compliance
Additional Information
Introduction
At Ferrier Wire Goods Company Ltd., respecting privacy is an important part of our commitment to our clients/customers and employees. That is why we have developed The Ferrier Wire Goods Company Ltd. Privacy Code. The Ferrier Wire Goods Company Ltd. Privacy Code is a statement of principles and guidelines regarding the minimum requirements for the protection of personal information provided by Ferrier Wire Goods Company Ltd. to its clients/customers and employees. The objective of The Ferrier Wire Goods Company Ltd. Privacy Code is to promote responsible and transparent personal information management practices in a manner consistent with the provisions of the Personal Information Protection and Electronic Documents Act (Canada).
Ferrier Wire Goods Company Ltd. will continue to review The Ferrier Wire Goods Company Ltd. Privacy Code to make sure that it is relevant and remains current with changing industry standards, technologies and laws.
Summary of Principles
Principle 1 - Accountability
Ferrier Wire Goods Company Ltd. is responsible for personal/company information under its control and shall designate one or more persons who are accountable for Ferrier Wire Goods Company Ltd.’s compliance with the following principles.
Principle 2 - Identifying Purposes for Collection of Personal/Company Information
Ferrier Wire Goods Company Ltd. shall identify the purposes for which personal/company information is collected at or before the time the information is collected.
Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal/Company Information
The knowledge and consent of a client/customer or employee are required for the collection, use, or disclosure of personal/company information, except where inappropriate.
Principle 4 - Limiting Collection of Personal/Company Information
Ferrier Wire Goods Company Ltd. shall limit the collection of personal/company information to that which is necessary for the purposes identified by Ferrier Wire Goods Company Ltd. Ferrier Wire Goods Company Ltd. shall collect personal/company information by fair and lawful means.
Principle 5 - Limiting Use, Disclosure, and Retention of Personal/Company Information
Ferrier Wire Goods Company Ltd. shall not use or disclose personal/company information for purposes other than those for which it was collected, except with the consent of the individual/company or as required by law.
Principle 6 - Accuracy of Personal/Company Information
Personal/company information shall be as accurate, complete, and up to date as is necessary for the purposes for which it is to be used.
Principle 7 - Security Safeguards
Ferrier Wire Goods Company Ltd. shall protect personal/company information by security safeguards appropriate to the sensitivity of the information.
Principle 8 - Openness Concerning Policies and Procedures
Ferrier Wire Goods Company Ltd. shall make readily available to clients/customers and employees specific information about its policies and procedures relating to the management of personal/company information.
Principle 9 – Client/Customer and Employee Access to Personal/Company Information
Ferrier Wire Goods Company Ltd. shall inform a client/customer or employee of the existence, use, and disclosure of his or her personal/company information upon request and shall give the individual/company access to that information. A client/customer or employee shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Principle 10 - Challenging Compliance
A client/customer or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Ferrier Wire Goods Company Ltd.’s compliance with The Ferrier Wire Goods Company Ltd. Privacy Code.
Scope and Application
The ten principles that form the basis of The Ferrier Wire Goods Company Ltd. Privacy Code are interrelated and Ferrier Wire Goods Company Ltd. shall adhere to the ten principles as a whole. Each principle must be read in conjunction with the accompanying commentary. As permitted by the Personal Information Protection and Electronic Documents Act (Canada), the commentary in The Ferrier Wire Goods Company Ltd. Privacy Code has been drafted to reflect personal/company information issues specific to Ferrier Wire Goods Company Ltd.
The scope and application of The Ferrier Wire Goods Company Ltd. Privacy Code are as follows:
- The Ferrier Wire Goods Company Ltd. Privacy Code applies to personal/company information collected, used, or disclosed by Ferrier Wire Goods Company Ltd. in the course of commercial activities.
- The Ferrier Wire Goods Company Ltd. Privacy Code applies to the management of personal/company information in any form, whether oral, electronic or written.
- The Ferrier Wire Goods Company Ltd. Privacy Code does not impose any limits on the collection, use or disclosure of the following information by Ferrier Wire Goods Company Ltd.:
(a) an employee’s name, title or business address or telephone number;
(b) information that Ferrier Wire Goods Company Ltd. collects, uses or discloses for journalistic, artistic or literary purposes and does not collect, use or disclose for any other purpose; or
(c) other information about the individual that is publicly available and is specified by regulation pursuant to the Personal Information Protection and Electronic Documents Act (Canada).
- The Ferrier Wire Goods Company Ltd. Privacy Code will not typically apply to information regarding Ferrier Wire Goods Company Ltd.’s corporate clients/customers. However, such information may be protected by other Ferrier Wire Goods Company Ltd. policies and practices and through contractual arrangements.
- The application of The Ferrier Wire Goods Company Ltd. Privacy Code is subject to the requirements and provisions of the Personal Information Protection and Electronic Documents Act (Canada), the regulations enacted thereunder, and any other applicable legislation or regulation.
Definitions
collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.
consent: Voluntary agreement for the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of Ferrier Wire Goods Company Ltd. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.
Client/Customer: An individual/company who/which purchases or otherwise acquires or uses any of Ferrier Wire Goods Company Ltd.’s products or services or otherwise provides personal/company information to Ferrier Wire Goods Company Ltd. in the course of Ferrier Wire Goods Company Ltd.’s commercial activities.
disclosure: Making personal/company information available to a third party.
employee: An employee of or independent contractor to Ferrier Wire Goods Company Ltd. .
personal information: Information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization.
Ferrier Wire Goods Company Ltd.: Ferrier Wire Goods Company Ltd.
third party: An individual or organization outside of Ferrier Wire Goods Company Ltd.
use: The treatment, handling, and management of personal/company information by and within Ferrier Wire Goods Company Ltd. or by a third party with the knowledge and approval of Ferrier Wire Goods Company Ltd.
The Ferrier Wire Goods Ltd. Privacy Code in Detail
Principle 1 - Accountability
Ferrier Wire Goods Company Ltd. is responsible for personal/company and employee information under its control and shall designate one or more persons who are accountable for Ferrier Wire Goods Company’s compliance with the following principles.
1.1 Responsibility for compliance with the provisions of The Ferrier Wire Goods Company Ltd. Privacy Code rests with the Ferrier Wire Goods Company Ltd. Privacy Officer who can be reached at 416-769-5280, toll free at 888-769-5280 or via privacy@ferrierwire.com. Other individuals within Ferrier Wire Goods Company Ltd. may be delegated to act on behalf of The Ferrier Wire Goods Company Ltd. Privacy Officer or to take responsibility for the day-to-day collection and/or processing of personal information.
1.2 Ferrier Wire Goods Company Ltd. shall make known, upon request, the title of the person or persons designated to oversee Ferrier Wire Goods Company Ltd.’s compliance with The Ferrier Wire Goods Company Ltd. Privacy Code.
1.3 Ferrier Wire Goods Company Ltd. is responsible for personal information in its possession or control. Ferrier Wire Goods Company Ltd. shall use contractual or other means to provide a comparable level of protection while information is being processed or used by a third party.
1.4 Ferrier Wire Goods Company Ltd. shall implement policies and procedures to give effect to The Ferrier Wire Goods Company Ltd. Privacy Code, including:
(a) implementing procedures to protect personal information and to oversee Ferrier Wire Goods Company Ltd.’s compliance with The Ferrier Wire Goods Company Ltd. Privacy Code;
(b) implementing procedures to receive and respond to complaints or inquiries;
(c) training and communicating to staff about Ferrier Wire Goods Company Ltd.’s policies and procedures; and
(d) developing information materials to explain Ferrier Wire Goods Company Ltd.’s policies and procedures.
Principle 2 - Identifying Purposes for Collection of Personal Information
Ferrier Wire Goods Company Ltd. shall identify the purposes for which personal information is collected at or before the time the information is collected.
2.1 Ferrier Wire Goods Company Ltd. collects personal information only for the following purposes:
to allow the successful continuation of Ferrier Wire Goods Company Ltd.’s commercial activities.
Further reference to “identified purposes” mean the purposes identified in this Principle.
2.2 Ferrier Wire Goods Company Ltd. shall specify orally, electronically or in writing the identified purposes to the client/customer or employee at or before the time personal information is collected. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within Ferrier Wire Goods Company Ltd. who can explain the purposes.
2.3 When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is permitted or required by law, the consent of the client/customer or employee will be acquired before the information will be used or disclosed for the new purpose.
Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of a client/customer or employee are required for the collection, use, or disclosure of personal information, except where inappropriate. In certain circumstances personal information can be collected, used, or disclosed without the knowledge and consent of the individual.
3.1 In obtaining consent, Ferrier Wire Goods Company Ltd. shall use reasonable efforts to ensure that a client/customer or employee is advised of the identified purposes for which personal information will be used or disclosed. The identified purposes shall be stated in a manner that can be reasonably understood by the client/customer or employee.
3.2 Generally, Ferrier Wire Goods Company Ltd. shall seek consent to use and disclose personal/company information at the same time it collects the information. However, Ferrier Wire Goods Company Ltd. may seek consent to use and/or disclose personal information after it has been collected, but before it is used and/or disclosed for a new purpose.
3.3 Ferrier Wire Goods Company Ltd. may require client/customer to consent to the collection, use and/or disclosure of personal information as a condition of the supply of a product or service only if such collection, use and/or disclosure is required to fulfill the explicitly specified, and legitimate identified purposes.
3.4 In determining the appropriate form of consent, Ferrier Wire Goods Company Ltd. shall take into account the sensitivity of the personal/company information and the reasonable expectations of its client/customer and employees.
3.5 The purchase or use of products and services by a client/customer, or the acceptance of employment or benefits by an employee, may constitute implied consent for Ferrier Wire Goods Company Ltd. to collect, use and disclose personal information for the identified purposes.
3.6 A client/customer or employee may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Clients/customers and employees may contact Ferrier Wire Goods Company Ltd. for more information regarding the implications of withdrawing consent.
3.7 Ferrier Wire Goods Company Ltd. may collect or use personal information without knowledge or consent if it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is seriously ill or mentally incapacitated.
3.8 Ferrier Wire Goods Company Ltd. may collect, use or disclose personal information without knowledge or consent if seeking the consent of the individual might defeat the purpose of collecting, using or disclosing the information, such as in the investigation of a breach of an agreement or a contravention of a law.
3.9 Ferrier Wire Goods Company Ltd. may collect, use or disclose personal information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened.
3.10 Ferrier Wire Goods Company Ltd. may use or disclose personal information without knowledge or consent to a lawyer representing Ferrier Wire Goods Company Ltd., to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law.
Principle 4 - Limiting Collection of Personal Information
Ferrier Wire Goods Company Ltd. shall limit the collection of personal information to that which is necessary for the purposes identified by Ferrier Wire Goods Company Ltd. Ferrier Wire Goods Company Ltd. shall collect personal information by fair and lawful means.
4.1 Ferrier Wire Goods Company Ltd. collects personal information primarily from its clients/customers or employees.
4.2 Ferrier Wire Goods Company Ltd. may also collect personal information from other sources including credit bureaus, employers or personal references, or other third parties who represent that they have the right to disclose the information.
Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information
Ferrier Wire Goods Company Ltd. shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Ferrier Wire Goods Company Ltd. shall retain personal information only as long as necessary for the fulfillment of those purposes.
5.1 Ferrier Wire Goods Company Ltd. may disclose a client/customer’s personal information to:
(a) government or legal agent/agency with proper authority and consent;
(b) collect a debt or for dispute resolution;
(c) respond to a request for a credit reference;
(b) banking or accounting audits.
5.2 Ferrier Wire Goods Company Ltd. may disclose personal information about its employees to:
(a) government or legal agent/agency with proper authority and consent;
(b) assist an employee if their life, safety or security is in danger.
5.3 Only Ferrier Wire Goods Company Ltd.’s employees with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about clients/customers and employees.
5.4 Ferrier Wire Goods Company Ltd. shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about a client/customer or employee, Ferrier Wire Goods Company Ltd. shall retain, for a period of time that is reasonably sufficient to allow for access by the client/customer or employee, either the actual information or the rationale for making the decision.
5.5 Ferrier Wire Goods Company Ltd. shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.
Principle 6 - Accuracy of Personal Information
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
6.1 Personal information used by Ferrier Wire Goods Company Ltd. shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a client/customer or employee.
6.2 Ferrier Wire Goods Company Ltd. shall update personal information about clients/customers and employees as necessary to fulfill the identified purposes or upon notification by the individual.
Principle 7 - Security Safeguards
Ferrier Wire Goods Company Ltd. shall protect personal information by security safeguards appropriate to the sensitivity of the information.
7.1 Ferrier Wire Goods Company Ltd. shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held.
7.2 Ferrier Wire Goods Company Ltd. shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.
7.3 All of Ferrier Wire Goods Company Ltd.’s employees with access to personal information shall be required to respect the confidentiality of that information.
Principle 8 - Openness Concerning Policies and Procedures
Ferrier Wire Goods Company Ltd. shall make readily available to clients/customers and employees specific information about its policies and procedures relating to the management of personal information.
8.1 Ferrier Wire Goods Company Ltd. shall make information about its policies and procedures easy to understand, including:
(a) the title and address of the person or persons accountable for Ferrier Wire Goods Company Ltd.’s compliance with The Ferrier Wire Goods Company Ltd. Privacy Code and to whom inquiries and/or complaints can be forwarded;
(b) the means of gaining access to personal information held by Ferrier Wire Goods Company Ltd.;
(c) a description of the type of personal information held by Ferrier Wire Goods Company Ltd., including a general account of its use; and
(d) a description of what personal information is made available to related organizations (e.g., subsidiaries).
8.2 Ferrier Wire Goods Company Ltd. shall make available information to help clients/customers and employees exercise control of the collection, use and/or disclosure of their personal information and, where applicable, privacy-enhancing services available from Ferrier Wire Goods Company Ltd.
Principle 9 - client/customer and Employee Access to Personal Information
Upon request, Ferrier Wire Goods Company Ltd. shall inform a client/customer or employee of the existence, use, and disclosure of his or her personal information and shall give the individual access to that information. A client/customer or employee shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
9.1 Upon request, Ferrier Wire Goods Company Ltd. shall afford clients/customers and employees a reasonable opportunity to review the personal information in the individual’s file. Personal information shall be provided in understandable form within a reasonable time, and at minimal or no cost to the individual.
9.2 In certain situations, Ferrier Wire Goods Company Ltd. may not be able to provide access to all the personal information that it holds about a client/customer or employee. For example, Ferrier Wire Goods Company Ltd. may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, Ferrier Wire Goods Company Ltd. may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of the laws of Canada or a province.
9.3 Upon request, Ferrier Wire Goods Company Ltd. shall provide an account of the use and disclosure of personal information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, Ferrier Wire Goods Company Ltd. shall provide a list of third parties to which it may have disclosed personal information about the individual when it is not possible to provide an actual list.
9.4 In order to safeguard personal information, a client/customer or employee may be required to provide sufficient identification information to permit Ferrier Wire Goods Company Ltd. to account for the existence, use and disclosure of personal information and to authorize access to the individual’s file. Any such information shall be used only for this purpose.
9.5 Ferrier Wire Goods Company Ltd. shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file. Where appropriate, Ferrier Wire Goods Company Ltd. shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.
9.6 clients/customers and employees can obtain information or seek access to their individual files by contacting the Ferrier Wire Goods Company Ltd. Privacy Officer.
Principle 10 - Challenging Compliance
A client/customer or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Ferrier Wire Goods Company Ltd’s compliance with The Ferrier Wire Goods Company Ltd. Privacy Code.
10.1 Ferrier Wire Goods Company Ltd. shall maintain procedures for addressing and responding to all inquiries or complaints from its clients/customers and employees regarding Ferrier Wire Goods Company Ltd.’s handling of personal information.
10.2 Ferrier Wire Goods Company Ltd. shall inform its clients/customers and employees about the existence of these procedures as well as the availability of complaint procedures.
10.3 The person or persons accountable for compliance with The Ferrier Wire Goods Company Ltd. Privacy Code may seek external advice where appropriate before providing a final response to individual complaints.
10.4 Ferrier Wire Goods Company Ltd. shall investigate all complaints concerning compliance with The Ferrier Wire Goods Company Ltd. Privacy Code. If a complaint is found to be justified, Ferrier Wire Goods Company Ltd. shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A client/customer or employee shall be informed of the outcome of the investigation regarding his or her complaint.
Additional Information
For more information regarding The Ferrier Wire Goods Company Ltd. Privacy Code, please contact the Ferrier Wire Goods Company Ltd. Privacy Officer at 416-769-5280 or via privacy@ferrierwire.com.
Please visit the Privacy Commissioner of Canada’s web site at www.privcom.gc.ca.