Privacy Policy

The Employers’ Choice Inc. (“TEC”) is a human resources management consulting firm that provides advice, programs, human resources outsourcing, and training to employer clients.

Our employees hold various human resources professionals’ designations by recognized authoritative bodies and their activities may be governed by outside professional codes of conduct and standards of practice. Consistent with our obligations as professionals, we are dedicated to maintaining high standards of confidentiality with respect to the information that has been provided to us.

In addition to existing professional obligations, TEC is committed to ensuring that all handling of personal information occurs in compliance with applicable privacy legislation including the Personal Information Protection and Electronic Documents Act. This Privacy Policy (the “Policy”) has been prepared to communicate the principles, guidelines and practices that flow from our commitment to protecting the privacy of the personal information of our clients, their employees, service providers and other individuals. In particular, the Policy addresses the following:

1. The Professional Relationship
2. The Definition of Personal Information
3. Collection of Personal Information
4. The Types of Personal Information we collect
5. Disclosure of Personal Information
6. Consent to Collection, Use and Disclosure
7. Storage, Security and Protection of Personal Information
8. Retention of Personal Information
9. Access and Accuracy
10. Privacy and Electronic Communication
11. Changes to the Privacy Policy
12. Questions and Further Information
    
    

1. The Professional Relationship

As a general rule, all information concerning the business, the employee make-up of the business and/or affairs of an employer acquired either for the purpose providing proposals or fee estimates or in the course of providing services shall be held in strict confidence and will not revealed to anyone unless expressly or implicitly authorized by the person or organization concerned.

A professional relationship develops when TEC has determined that it is appropriate to offer services to a particular client and the client has agreed to retain the services of TEC. It is TEC’s practice to provide proposals and time estimates for every project and to obtain a consent and acknowledgement before beginning any work.

2. The Definition of Personal Information

Canadian privacy legislation defines “Personal Information” broadly as information about an identifiable individual or as information that allows an individual to be identified. For the purposes of this Policy, Personal Information means information about an identifiable individual as defined from time to time in applicable privacy legislation. Generally speaking, Personal Information does not include what is considered business contact information; i.e. an individual’s name, title or position, business address, telephone number, facsimile number, and e-mail address.

3. Collection of Personal Information

TEC collects, uses and discloses Personal Information about our clients, employees of clients, and service providers in order to provide clients with consulting services. Personal Information is also collected, used and disclosed for client communication, marketing and internal professional development purposes. More specifically, we collect, use and disclose Personal Information for the following purposes:

• to establish and manage client relationships, provide services, and avoid conflicts of interest;
• to analyze in order to make specific recommendations for changes to employer practices;
• to organize and prepare Personal Information for submission to third parties designated and approved by clients. Such third parties may include the client’s legal counsel, accountants, group benefit providers, compensation surveyors, pension investment managers, authoritative governing bodies, and payroll services;
• to establish and maintain commercial relationships with clients, suppliers and other third parties, including to issue invoices, administer accounts, collect and process payments, and to fulfil contractual obligations;
• to understand and respond to client, supplier and other third party needs and preferences, including to contact and communicate with such parties and to conduct surveys, research and evaluations;
• to distribute our Employers’ Edge newsletters, seminar information and other material to individuals on our mail and e-mail lists;
• to develop and manage our knowledge-management precedent systems and databases;
• to develop and manage TEC’s business and operations;
• to detect and protect TEC and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activity, and to audit compliance with TEC’s policies and contractual obligations;
• as permitted by, and to comply with, any legal or regulatory requirements or provisions; and
• for any other purpose to which you consent.

4. The types of Personal Information we collect

The types of Personal Information that TEC may collect include an individual’s name, home address, telephone number, personal e-mail address, and billing and account information. In addition, in the course of providing services, we may collect or be exposed to a wide variety of information about a client’s employees and job applicants including social insurance numbers, health insurance numbers, education and training courses taken, group insurance policy application and claim numbers, chequing account numbers, personal health information, health and safety records, workers’ compensation claim information, results of a self-identification study as may be reported under an employment equity program, credit history, compensation information, individual performance data, and shareholder status.

We do not sell, trade, barter or exchange any information obtained, including and especially any information obtained in the course of professional relationships.

5. Disclosure of Personal Information

In the course of providing services, TEC may disclose Personal Information to:

• service providers, including an organization or individual retained by TEC to perform functions on its behalf, such as marketing, data processing, document management and office services;
• an organization or individual retained by TEC to evaluate your creditworthiness or to collect debts outstanding on an account;
• a financial institution, on a confidential basis and solely in connection with the assignment of a right to receive payment, the provision of security or other financing arrangements;
• a person who, in the reasonable judgment of TEC, is providing or seeking the information as your agent; or
• any third party or parties, where you consent to such disclosure or where disclosure is required or permitted by law.

6. Consent to Collection, Use and Disclosure

By submitting Personal Information to TEC or its service providers and agents, you agree that we may collect, use and disclose such Personal Information in accordance with this Privacy Policy and as permitted or required by law. Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting TEC’s Chief Privacy Officer identified below. If you refuse to consent or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information which may be of value to you. If you provide TEC or our service providers and agents with Personal Information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose such Personal Information for the purposes set forth in this Privacy Policy and in accordance therewith.

There are circumstances where collection, use or disclosure may be justified or permitted or where we are obliged to disclose information without consent. These circumstances could include:

• Where the information is publicly available;
• Where required by law or by order of a court or tribunal;
• Where we believe, upon reasonable grounds, that there is an imminent risk of death or serious bodily harm to an identifiable person or group;
• Where it is alleged that a partner, associate or employee of TEC is guilty of a criminal offence or guilty of malpractice or misconduct;
• Where it is necessary to establish or collect fees.

In such circumstances, we will not collect, use or disclose more information than is required.

7. Storage, Security and Protection of Personal Information

TEC endeavours to maintain adequate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any unauthorized access, disclosure, copying, use or modification. Your Personal Information is stored in secured locations and on servers controlled by the owners of The Employers’ Choice Inc., located either at our office or at the offices of our services providers. To help protect the confidentiality of your Personal Information, TEC employs physical, administrative and technological safeguards appropriate to the sensitivity of your Personal Information. For instance, we operate secure data networks protected by industry standard firewall and password protection systems. In addition, where Personal Information is sent to a third party for processing, we make sure, through our contracts with such third parties, that all Personal Information is kept secure.

8. Retention

Because of the nature of the professional relationship and the services we provide it is our practise to retain paper versions of our files and the Personal Information contained therein for three (3) years, unless for legal purposes it is required to be retained for longer periods. Paper files are shredded by qualified outside vendors. Electronic data will be stored for a minimum of seven (7) years. This retention policy has developed for the convenience of our clients, many of whom have expressed their expectation that we retain our copies of their files many years after the services we have provided have been performed and completed in case they require access in the future.

9. Access and Accuracy

Access requests should be sent to our Chief Privacy Officer, using the contact information provided below. Upon receiving a written request and subject to any applicable exemptions, TEC will inform you of the existence, use, and disclosure of your Personal Information and will give you access to that information and the opportunity to correct any inaccurate Personal Information that is in the possession of TEC. TEC endeavours to maintain the accuracy of any information in its possession, with respect to active matters. Information contained in closed files is not actively updated or maintained.

We encourage our clients and other individuals to make efforts to advise TEC of any changes in the information that we have in our possession.

10. Privacy and Electronic Communication

• Exchange of Information Via E-mail - TEC does not guarantee the confidentiality of any communications made by you via e-mail or otherwise through our website and cannot guarantee that any such communications are confidential. If you wish to provide information of a confidential or sensitive nature to TEC, please contact your TEC representative directly by telephone to arrange for delivery/transmission of such information by secure means.
• Distribution Lists – By virtue of the nature of our contacts the human resources field, TEC has created an e-mail distribution list in order to circulate employment opportunities in the HR field, or information regarding upcoming training or events or services available. The positions circulated may or may not be opportunities within TEC or with one of TEC’s retained clients. Anyone in the general public may elect to join this distribution list at any time. Any individual consenting to be on this list consents to receiving information about employment opportunities, information regarding upcoming training or events or services available. Any individual on the list may request removal at any time.
• Web Site - In order to provide our website visitors with a service or information, visitors may voluntarily submit Personal Information to us via email for purposes such as asking a question, obtaining information, reviewing or downloading a publication or participating in a seminar or other event. Occasionally, we may send marketing or promotional e-mail communications to you with information that may be useful.
• Cookies - In browsing the Internet, you will encounter a technology called "cookies" which can be used to provide you with specific information from a Web site. A "cookie" is an element of data that a Web site can send to your browser, which may then store it on your system. TEC’s website does not currently use cookies.
• Links - Our website may contain links to other websites which are provided as a convenience only. Visitors are advised that other third party websites may have different privacy policies and practices than TEC, and TEC has no responsibility for such third party websites.

11. Changes to the Privacy Policy

TEC reserves the right to modify or supplement this Policy at any time. If we make a change to this Policy, we will post such changes on our website and make such revised policy and changes available upon request to TEC’s Chief Privacy Officer. However, TEC will obtain the necessary consents required under applicable privacy laws if it seeks to collect, use or disclose your Personal Information for purposes other than those to which consent has been obtained, unless otherwise required or permitted by law.

12. Questions and Further Information

Any question concerning the management of their Personal Information, should first be addressed by the client to the lawyer responsible for the client’s legal affairs. In addition, TEC has appointed a Chief Privacy Officer to oversee compliance with this Policy and applicable privacy laws. Any questions related to this Policy or the handling of Privacy Information by TEC can be addressed with the Privacy Officer at the contact information below:

CHIEF PRIVACY OFFICER
The Employers’ Choice Inc.
2 County Court Blvd.
Suite 430
Brampton, Ontario L6W 3W8

If you are not satisfied with TEC’s response to a privacy related matter, you may contact the Office of the Privacy Commissioner of Canada at 1-800-282-1376 or at www.privcom.gc.ca.

... Providing human resources solutions, systems and training