As of July, 2007
Our commitment to maintain the accuracy, confidentiality, and security of Your personal information is reflected in Our application of the privacy principles enumerated by the Canadian Standards Association (the Privacy Principles), which conform to the objectives set forth in PIPEDA.
Source is responsible for maintaining and protecting Your personal information that is under Our control, including personal information transferred to third parties for processing. In fulfilling this mandate, We have designated an individual who is accountable for Our compliance with these Privacy Principles.
1.1 - The
Privacy Coordinator is responsible for Our compliance with this Privacy
Policy even though other individuals within Source may be responsible
for the day-to-day collection and processing of personal information.
Other individuals within Source may be delegated to act on behalf of
the Privacy Coordinator.
1.2 - The identity of the Privacy Coordinator has been internally designated and shall be made available to You upon request.
1.3 - We use contractual and other means to protect personal information that has been transferred to third parties for processing, (i.e., billing)
- Procedures to safeguard personal information;
- Procedures to receive and respond to complaints and inquiries;
- Training staff to understand and comply with Our policies and procedures; and
- Informing Our customers as to Our policies and procedures.
2 - Identifying Purposes
The purposes for which personal information is collected will be identified before or at the time that the information is collected .(please consult Your contract with Source and Our website)
2.1 - We collect personal information such as Your name, telephone number, billing and/or mailing address, credit card information, birth date, and email address, for the following reasons:
- To establish and maintain responsible commercial relations with You and provide You with ongoing service;
- To understand Your needs and eligibility for Our products and services;
- To recommend particular Source products and services to meet Your needs;
- To develop, enhance, market or provide Our products and services, including sending You offers, publications or other promotional communication regarding Source products and services;
- To contact You regarding Our contests, including advising You of a Source contest or contacting You as a potential winner of a Our contest:
- To manage and develop Our business and operations, including personnel and employment matters; and
- To meet legal and regulatory requirements.
2.2 - We contact Our customers from time to time by letter, email or by telephone for reasons of account management, quality assurance and in order to inform subscribers of changes to programming packages and the introduction of new cable television, internet or other services. You may, at any time, withdraw Your consent to receive communications involving Our services by contacting a customer service representative with a request to be added to Our “do not call” list.
2.3 - We aggregate and anonymize personal information to produce subscriber statistics for internal business purposes (including for marketing reasons) and to provide them to the Canadian Radio-Television and Telecommunications Commission pursuant to the law.
2.4 - We collect Your IP address for the purposes of system administration, including diagnosis of problems with Our server and administration of Our website. All information collected will be done in a fair and lawful manner.
3. Your Persoanl Information
Consent is required for the collection of personal information and the subsequent use or disclosure of this information. In most cases, We will seek consent for the use or disclosure of the information at the time of collection. When We want to use information for a purpose not previously identified, consent with respect to use or disclosure will be sought after the information has been collected, but before it is used, unless required or permitted by law.
3.2 - We reserve the right to collect, use or disclose personal information without Your knowledge or consent in instances where legal or security reasons, or the welfare of an individual, might make it impossible or impractical to seek consent. For example, when personal information is being collected for the detection or prevention of fraud, seeking consent might defeat the purpose of collecting the information. All of the circumstances where We may collect, use or disclose personal information without a customer’s knowledge or consent are as specified, or required or permitted by law.
3.3 - We will ensure that You are made aware of why We need the personal information and how the personal information will be used. To make the consent informed and meaningful, the purposes will be stated so that You can reasonably understand how the information will be used or disclosed.
3.4 - We will not, as a condition of providing a product or service, require You to consent to the collection of, use or disclosure of personal information beyond that required to provide the product or service itself.
3.5 - Consent can be either express or implied. The form of consent We seek may vary, depending upon the circumstances and the type of information. In determining the form of consent to use, We will take into account the sensitivity of the information and Your reasonable expectations. We will generally seek express consent when the information is likely to be considered sensitive. Implied consent is typically appropriate when the information is less sensitive.
3.6 - You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting (privacy email address) We will endeavor to inform You of the implication of withdrawing consent.
3.7 - You can give consent in many ways including the completion and signing of an application form, not checking of a box to request that their names and addresses not be given to other organizations, orally when information is collected over the telephone or in person, or when You provide information to Source voluntarily. In general, Your use of products and services constitutes implied consent for Us to collect, use and disclose personal information for all identified purposes.
4. Principle Limiting Collection
The personal information collected must be limited to those details necessary for the purposes identified by Us. Information must be collected by fair and lawful means.
4.1 - We will collect only the amount and type of personal information needed for specified purposes that have been documented by Us and identified to You. We will specify the type of personal information collected as part of Our information management policies and practices.
4.2 - We will not mislead or deceive You about the purposes for which personal information is being collected.
5. Limited Use, Disclosure and Retention
Personal information may only be used or disclosed for the purpose for which it was collected unless You have otherwise consented, or when it is required or permitted by law. Personal information may only be retained for the period of time required to fulfill the purpose for which it was collected.
5.1 - We will keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Personal information that has been used to make a decision about You will be retained for a period of time that is reasonably sufficient to allow the individual access to the information after the decision
has been made and to permit any recourse under this policy and applicable privacy legislation.
5.2 - We will destroy, erase, or make anonymous personal information that is no longer required to fulfill the identified purposes. We will develop guidelines and implement procedures to govern the destruction of personal information.
5.3 - We may disclose Your personal information to:
- A person who in Our reasonable judgment is seeking the information as Your agent;
- A company for the efficient and cost-effective provision of telecommunications services;
- A company involved in supplying You with communications or communications directory-related services;
- A company or individual for the development, enhancement, marketing or provision of any of Our products or services;
- A agent of Ours used to evaluate Your creditworthiness or to collect Your account;
- A credit reporting agency;
- A public authority or agent or public authority, if in Our reasonable judgment, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; and
- A third party or parties, where You consent to such disclosure or disclosure is required or permitted by law.
5.5 - Only Our employees with a business need to know, or whose duties reasonably so require, are granted access to personal information about You.
Personal information must be maintained in as accurate, complete and up-to-date form as is necessary to fulfill the purposes for which it is to be used.
6.1 - The extent to which personal information shall be accurate, complete, and up-to-date will depend upon how We use the information, taking into account Your interests. Information shall be sufficiently accurate, complete, and up-to-date so as to minimize the possibility that inappropriate information may be used to make a decision about the customer.
6.2 - We will update personal information that is used on an on-going basis to fulfill the identified purposes including information that is disclosed to third parties.
6.3 - We will not routinely update personal information where such updated information is not needed to fulfill the purposes for which it was collected.
7. Safeguarding Personal Information
Personal information must be protected by security safeguards that are appropriate to the
sensitivity level of information.
7.1 - The security safeguards shall protect personal information against loss or theft, as well as unauthorized access disclosure, copying, use, or modification, regardless of the format in which the information is held.
7.2 - The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the extent of the information, and the method of storage. More sensitive information will be safeguarded by a higher level of protection.
7.3 - The methods of protection include:
- Physical measures, for example, locked filing cabinets and restricted access to offices;
- Organizational measures, for example, security clearances and limiting access on a “need to know” basis; and
- Technological measures, for example, the use of passwords, encryption and a firewall.
7.4 - We will make Our employees aware of the importance of maintaining the confidentiality of personal information.
7.5 - We will dispose of personal information in a manner that prevents unauthorized parties from gaining access to the information.
8. Openness About Policies and Procedures
We are required to make information available to You concerning the policies and practices that apply to the management of personal information.
8.1 - We will be open about Our policies and procedures with respect to the management of personal information. You are able to acquire information about Our policies and procedures at minimal cost and without unreasonable effort. This information shall be made available in a form that is generally understandable. This information is available by writing to Us, to the attention of the Privacy Coordinator.
8.2 - The information made available by Us shall include:
- The name or title, and the address, of the individual who is accountable for Our policies and procedures and to whom complaints or inquiries can be forwarded;
- Our means of gaining access to personal information;
- A description of the type of personal information held by Us, including a general account of its use;
- A copy of any documents that describe Our privacy policies, standards, and/or codes and
- A description of personal information made available to related organizations, including subsidiaries, affiliates or agents.
9. Providing Access to Personal Information
Upon request, You will be informed of the existence, use and disclosure of Your personal information, and shall be given access to it. You may verify the accuracy and completeness of Your personal information, and may request that it be amended, if appropriate.
9.1 - Upon request, We will inform a customer whether or not We hold personal information on You and will indicate the source of this information. If We possess such information, We will allow You access to this information. In addition, We will provide an account of the use that has been made or is being made of this information and an account of the third parties to which it has been disclosed.
9.2 - You may be required to provide sufficient information to Us to permit Us to confirm Our accurate use of Your personal information. The required information provided to Us for this purpose shall only be used for this purpose.
9.3 - In certain situations, We may not be able to provide access to all the personal information it holds. Exceptions to the access requirement must be limited to those allowed under law.
9.4 - In providing an account of third parties to which We have disclosed personal information, We will attempt to be as specific as possible. When it is not possible to provide a list of the actual organizations to which We have disclosed information, We will provide a list of organizations to which We may have disclosed information.
9.5 - We will respond to Your request within a reasonable time and at minimal or no cost. The requested information shall be provided or made available