Privacy of personal
information is an important principle at Ellis Associates.
We are committed to collecting, using and disclosing personal
information responsibly and only to the extent necessary for
the goods and services we provide. We also try to be open
and transparent as to how we handle personal information.
This document describes our privacy policies.
What is Personal Information?
Personal information is information
about an identifiable individual. Personal information includes
information that relates to: an individual's personal characteristics
(e.g., gender, age, income, home address or phone number,
ethnic background, family status); health (e.g., health history,
health conditions, health services received by them); or,
activities and views (e.g., religion, politics, opinions expressed
by an individual, an opinion or evaluation of an individual).
Personal information is different from business information
(e.g., an individual's business address and telephone number).
This is not protected by privacy legislation.
Who We Are
Ellis Associates is made up of a number
of full-time and part-time consultants and support staff.
We also use some external consultants who may, in the course
of their duties, have access to personal information we hold.
Other peripheral agencies include computer consultants, office
security and maintenance, bookkeepers and accountants, temporary
workers to cover holidays, credit card companies, website
managers, cleaners and lawyers. We restrict their access to
any personal information we hold as much as is reasonably
possible. We also have their assurance that they follow appropriate
privacy principles. Ellis Associates provides its services
to external organizations. Employees and/or external contractors
from these organizations who are directly involved in the
project and have a need to know will also have access to the
personal information that we hold.
Collecting Personal Information: Primary
Purposes
About Clients and Candidates
Ellis Associates collects, uses and
discloses personal information in order to serve our clients
and the individuals presented to us by our clients. Along
with contact information, we also collect information about
an individual's work history and habits including things the
individual has said and done that pertain to their work performance.
In addition, we may collect data based on ability and personality
testing. For our clients, the primary purpose for collecting
personal information is to provide data that they will use
for making hiring, promotion, career development, and other
legitimate personnel decisions. This information will also
be provided to the individual(s) involved for personal development
purposes.
A second primary purpose is to obtain
home contact information so that we can contact the individual
directly in order to arrange interviews, send homework packages,
etc.
A third primary purpose might be to
collect personal information from third parties about an individual's
work performance so that we can use the third party's feedback
to better understand the performance issues of the individual
in question. Some or all of this information may or may not
be shared with the client organization and/or the individual
depending on the arrangements made between the individual,
the organization and Ellis Associates.
About Members of the General Public
For members of the general public,
our primary purposes for collecting personal information are
to provide notice of special events (e.g., a seminar or conference)
or to make them aware of Ellis Associates' services in general.
For example, while we try to use work contact information
where possible, we might collect home addresses, fax numbers
and email addresses. We try to obtain consent before using
any such personal information, but where this is not, for
any reason, possible, we will upon request immediately remove
any personal information from our distribution list.
On our website we only collect, with
the exception of cookies, the personal information you provide
and only use that information for the purpose for which you
gave it to us (e.g., to respond to your email message). Cookies
are only used to help you navigate our website and are not
used to monitor you.
About Contract Staff
For people who are contracted to do
work for us (e.g., subcontractors, temporary workers), our
primary purpose for collecting personal information is to
ensure we can contact them in the future (e.g., for new assignments)
and for necessary work-related communication (e.g., sending
out pay cheques, year-end tax receipts, etc). Examples of
the type of personal information we collect for those purposes
include home addresses and telephone numbers. It is rare for
us to collect such information without prior consent, but
it might happen in the case of a health emergency (e.g., a
SARS outbreak) or to investigate a possible breach of law
(e.g., if a theft were to occur). If contract staff, volunteers
or students wish a letter of reference or an evaluation, we
will collect information about their work-related performance
and provide a report as authorized by them.
Collecting Personal Information: Related
and Seconday Purposes
Like most organizations, we also collect,
use and disclose information for purposes related to or secondary
to our primary purposes. The most common examples of our related
and secondary purposes are as follows:
- To invoice for goods or services that were not paid for
at the time, to process credit card payments or to collect
unpaid accounts.
- To advise individuals that their product or service may
need to be reviewed or updated (e.g., the next round of
a 360 degree feedback program)
- To advise individuals and client organizations of special
events or opportunities (e.g., a seminar, development of
a new service, arrival of a new product) that we have available.
- We review client and other files for the purpose of ensuring
that we provide high-quality services, including assessing
the performance of our staff. In addition, external consultants
(e.g., auditors, lawyers, practice consultants, voluntary
accreditation programs, IT professionals) may on our behalf
do audits and continuing quality improvement reviews of
our services, including reviewing client files and interviewing
our staff.
- Some of our consultants may be registered psychologists
and as such, may be regulated by the Ontario Psychological
Association. This organization may inspect our records and
interview our staff as a part of their regulatory activities
in the public interest. In addition, as professionals, we
will report serious misconduct, incompetence or incapacity
of other practitioners, whether they belong to other organizations
or our own. Also, our organization believes that it should
report information suggesting serious illegal behaviour
to the authorities. External regulators have their own strict
privacy obligations. Sometimes these reports include personal
information about our clients, or other individuals, to
support the concern (e.g., improper services). Also, like
all organizations, various government agencies (e.g., Canada
Customs and Revenue Agency, Information and Privacy Commissioner,
Human Rights Commission, etc.) have the authority to review
our files and interview our staff as a part of their mandates.
In these circumstances, we may consult with professionals
(e.g., lawyers, accountants) who will investigate the matter
and report back to us.
- The cost of most goods/services provided by Ellis Associates
is paid for by the client organization requesting the service.
As such, they often have your permission to direct us to
collect and disclose to them certain information in order
to demonstrate entitlement to the payments.
- Clients or other individuals we deal with may have questions
about our goods or services after they have been received.
We also provide ongoing services for many of our clients
over a period of months or years for which our previous
records are helpful. We retain our client information for
a minimum of eight years after the last contact to enable
us to respond to those questions and provide these services.
- If the Ellis Associates or its assets were to be sold,
the purchaser would want to conduct a “due diligence”
review of the company's records to ensure that it is a viable
business that has been honestly portrayed to the purchaser.
This due diligence may involve some review of our accounting
and service files. The purchaser would not be able to remove
or record personal information. Before being provided access
to the files, the purchaser must provide a written promise
to keep all personal information confidential. Only reputable
purchasers who have already agreed to buy the organization’s
business or its assets would be provided access to personal
information, and only for the purpose of completing their
due diligence search prior to closing the purchase.
You can choose not to be part of some
of these related or secondary purposes (e.g., by declining
to receive notice of special events or opportunities, by paying
for your services in advance). We do not, however, have much
choice about some of these related or secondary purposes (e.g.,
external regulation).
Protecting Personal Information
We understand the importance of protecting
personal information. For that reason, we have taken the following
steps:
- Paper information is either under
supervision or secured in a locked or restricted area.
- Electronic hardware containing
personal information is supervised at all times or locked
away. When staff leave terminals, they will ensure that
no personal information is left on screen. Computers and
laptops are all protected by passwords.
- All cell phones are digital as
these signals are more difficult to intercept.
- Paper information is transmitted
by reputable companies through sealed, addressed envelopes
or boxes.
- Electronic information is transmitted
either through a direct line or has identifiers removed,
is encrypted and/or is password protected.
- All fax correspondence contains
a privacy clause. Fax machines for both recipient and sender
are securely located and there is no basis to expect otherwise.
- Staff are trained to collect, use
and disclose personal information only as necessary to fulfill
their duties and in accordance with our privacy policy.
Retention and Destruction of Personal Information
We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy.
We keep our client files for about
ten years. Our client and contact directories are much more
difficult to systematically destroy, so we remove such information
when we can if it does not appear that we will be contacting
you again. However, if you ask, we will remove such contact
information right away. We keep any personal information relating
to our general correspondence (i.e., with people who are not
clients), newsletters, seminars, and marketing activities
for about six months after the newsletter ceases publication
or a seminar or marketing activity is over.
We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed.
You Can Look At Your Information
With only a few exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests.
If there is a problem we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.
If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.
Do you Have a Question?
Our Information Officer is:
Sandra Edwards
Ellis Associates Inc.
2025 Sheppard Ave E., Suite 4409
Toronto, ON
M2J 1V6
PHONE: 416-491-8385
She will attempt to answer any questions or concerns you might have.
If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. She will acknowledge receipt of your complaint, ensure that it is investigated promptly and that you are provided with a formal written decision with reasons.
If you have a concern about the professionalism or competence of our services or the mental or physical capacity of any of our professional staff we would ask you to discuss those concerns with us.
This policy is made under the Personal Information Protection and Electronic Documents Act. That is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above.
For more general inquiries, the Information and Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Information and Privacy Commissioner can be reached at:
112 Kent Street Ottawa, Ontario K1A
1H3 Phone (613) 995-8210 | 800-282-1376 | Fax (613) 947-6850
| TTY (613) 992-9190 www.privcom.gc.ca
|
