Under The Personal Information Protection and Electronic Documents Act which governs the collection, use and disclosure of personal information in the commercial sector, Lakeshore Communications is required to adhere to
'Ten Privacy Principles' set out in the National Standard of Canada, Model Code for the Protection of Personal Information effective January 1, 2001. It governs the behavior of employees and agents acting on behalf of Lakeshore Communications when dealing with personal information. The purpose in which information is collected and used. It provides procedures for an individuals access to and correction of personal information.
Ten Privacy Principles:
2. Identifying Purposes
3. Consent 4. Limiting Collection
5. Limiting Use, Disclosure and Retention
9. Individual Access
10. Challenging Compliance
Lakeshore Communications is responsible for personal information under its control and will designate an individual or individuals who are accountable for the organizations compliance with the following principles.
1.1 Accountability for Lakeshore Communications compliance with the principles rests with the senior management of Lakeshore Communications and the person or persons designated by senior management as Privacy Officer, even though other individuals within the organization may be responsible for the day-to-day collection and processing of personal information. In addition, other individuals within the organization may be delegated to act on behalf of senior management or the Privacy Officer.
1.2 Lakeshore Communications senior management has designated the following person to act as Privacy Officer to oversee the organizations compliance with the principles:
Lakeshore Communications Legal Department c/o Privacy Officer
Lakeshore Communications 30 Meteor Drive, Toronto, Ontario M9W 1A4
2. IDENTIFYING PURPOSES
Lakeshore Communications will identify the purposes for which personal information is collected at or before the time the information is collected.
2.1 Lakeshore Communications. collects personal information only for the following purposes (identified purposes):
(a) to provide service(s) and/or products to its customers;
(b) to maintain commercial relations and to communicate with its customers (which will include, but not be limited to: billing, collection, advertising, promotion, account verification);
(c) to identify customer needs and/or preferences;
(d) to meet legal and regulatory requirements;
(e) to administer and manage its business operations
2.2 Lakeshore Communications will provide notice of the identified purposes either orally, electronically or writing prior to or at the time of collection of the personal information.
2.3 On occasion, Lakeshore Communications. may engage third party companies or individuals to perform services on our behalf. Our relationships with such third party companies are governed by our contracts with them. Those companies are required to hold your personal information strictly confidential.
2.4 Lakeshore Communications will use personal information to advise its customers of any information relating to the services provided to them through Lakeshore Communications.. This includes but is not limited to notices for renewal of services, of system upgrades or any information relevant to the product and service. Occasionally, Lakeshore Communications. will communicate to the customer special bonus and new product offers that we think may be of value to the customer. If the customer wishes to opt-out of receiving targeted communications from Lakeshore Communications in electronic, printed or verbal format (other than information included with their renewal notice or monthly billing), simply inform Lakeshore Communications in writing at Privacy Office, Lakeshore Communications 30 Meteor Drive, Toronto, Ontario M9W 1A4 General inquiries: firstname.lastname@example.org (866) 232-2201
2.5 When personal information that has been collected is to be used for a purpose not previously identified, the new purpose will be identified prior to use. Unless the new purpose is required by law, Lakeshore Communications will obtain the consent of the individual before information is used for that new purpose.
The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except where inappropriate.
3.1 In certain circumstances, personal information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, legal, medical or security reasons may make it impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information. Seeking consent may be impossible or inappropriate when there is an emergency threatening the individuals life, health or security, or where the individual is a minor, seriously ill, or mentally incapacitated. In other instances, information may be publicly available. Moreover, Lakeshore Communications may provide personal information to its lawyer or agent to collect a debt, comply with a subpoena, warrant or other court order, government institution requesting the information upon lawful authority, or as may be otherwise required by law.
3.2 Lakeshore Communications will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when Lakeshore Communications wants to use information for a purpose not previously identified).
3.3 Lakeshore Communications will make a reasonable effort to ensure that the individual is advised of the purposes for which the information will be used. To make the consent meaningful, the purposes will be stated in such a manner that the individual can reasonably understand how the information will be used or disclosed.
3.4 Lakeshore Communications will not, as a condition of the supply of a product or service, require an individual to consent to the collection, use, or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes.
3.5 The form of consent sought by Lakeshore Communications may vary, depending upon the circumstances and the type of information disclosed. In determining the form of consent to use, Lakeshore Communications will take into account the sensitivity of the information and the reasonable expectations of the individual. An authorized representative (such as a legal guardian or a person having power of attorney) can also give consent. Lakeshore Communications will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate when the information is less sensitive. The use of services or products by a customer or the acceptance of employment by an employee will be considered implied consent to collect, use and disclose personal information for all identified purposes.
3.6 An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Lakeshore Communications will inform the individual of the implications of such withdrawal. In order to withdraw consent, an individual must provide notice to Lakeshore Communications in writing.
4. LIMITING COLLECTION
The collection of personal information will be limited to that which is necessary for the purposes identified by Lakeshore Communications.. Information will be collected by fair and lawful means.
4.1 Lakeshore Communications collects personal information from its customers and employees for the purposes described under Principle #2.
4.2 Lakeshore Communications may also collect personal information from such third parties as credit bureaus, employers or personal references or other third parties that represent that they have the right to disclose the information.
5. LIMITING USE, DISCLOSURE, AND RETENTION
Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes. 5.1 Lakeshore Communications may collect, use or disclose personal information without the individuals knowledge or consent in certain circumstances as described in Principle #3.1. 5.2 Lakeshore Communications may disclose a customers personal information to:
(a) another web hosting provider or internet service provider for the provision of services to that customer;
(b) a person involved in the development, promotion, marketing or enhancement of Lakeshore Communications services;
(c) a credit collections agency;
(d) emergency services in an emergency situation;
(e) a person, who, in the reasonable estimation of Lakeshore Communications, is an agent of the customer;
(f) any other third party, upon receiving the consent of the customer or as required by law.
5.3 Lakeshore Communications may disclose an employees personal information in the following circumstances:
(a) in the administration of that employees benefits;
(b) in providing references to prospective employers, upon receiving the consent of the employee;
(c) as may be required by law.
5.4 Lakeshore Communications employees may be given access to customer and/or employee information in so far as their duties require access for business purposes. Lakeshore Communications employees are governed by a non-disclosure agreement prohibiting disclosure or use of any confidential or personal information for any purposes other than the stated business purposes.
5.5 Lakeshore Communications will retain personal information for only as long as required to fulfill the identified purposes or as required by law.
5.6 Personal information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by Lakeshore Communications..
Personal information will be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
6.1 The extent to which personal information will be accurate, complete, and up-to-date will depend upon the use of the information, taking into account the interests of the individual. Information will be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about the individual.
6.2 Lakeshore Communications will not routinely update personal information unless such a process is necessary to fulfill the purposes for which the information was collected.
6.3 You have the ability to correct or change your personal information in our records, such as your address and contact information. The process for changing your information begins in the account area of your control panel. You may change this information at any time and as often as necessary. If you need assistance or have questions about changing, updating or correcting information, you can contact us via e-mail at email@example.com.
6.4 Personal information that is used on an ongoing basis, including information that is disclosed to third parties, should generally be accurate and up-to-date, unless limits to the requirement for accuracy are clearly set out.
Personal information will be protected by security safeguards appropriate to the sensitivity of the information.
7.1 Lakeshore Communications will protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution and format of the information, and the method of storage.
7.2 Lakeshore Communications protects all personal information regardless of the format in which it is held. The methods of protection include: (a) physical measures, such as locked filing cabinets and restricted access to offices; (b) organizational measures, such as security clearances and limiting access on a need to know basis; (c) technological measures, such as the use of passwords and encryption.
7.3 Lakeshore Communications makes their employees aware of the importance of maintaining the confidentiality of personal information. Lakeshore Communications employees are governed by a non-disclosure agreement prohibiting disclosure or use of any confidential or personal information for any purposes other than the stated business purposes.
7.4 Lakeshore Communications will use care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.
Lakeshore Communications will make readily available to individuals specific information about its policies and practices relating to the management of personal information.
8.1 Lakeshore Communications will make its policies and practices with respect to the management of personal information easily comprehensible and accessible, by providing upon request: (a) the name, title, and address of the Privacy Officer accountable for Lakeshore Communications policies and practices and to whom complaints or inquiries can be forwarded; (b) the means of gaining access to personal information held by Lakeshore Communications; and a description of the type of information held by Lakeshore Communications and/or its subsidiaries, including a general account of its use.
9. INDIVIDUAL ACCESS
Upon request, an individual will be informed of the existence, use, and disclosure of his or her personal information and will be given access to that information. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
9.1 Upon request, Lakeshore Communications will inform an individual whether or not the organization holds personal information about the individual, and will provide that individual with a reasonable opportunity to review the personal.
9.2 Lakeshore Communications will allow the individual access to his or her personal information and to correct or change personal information in our records, such as their address and contact information. The process for changing information begins in the password protected account area of the individuals control panel. The individual may change this information at any time and as often as necessary. If assistance is needed, or for answers to questions about changing, updating or correcting information, the individual can contact Lakeshore Communications via e-mail or telephone.
9.3 Lakeshore Communications will be as specific as possible in providing an account of third parties to which it has disclosed personal information about an individual. When it is not possible to provide a list of the organizations to which it has actually disclosed information about an individual, Lakeshore Communications will provide a list of organizations to which it may have disclosed information about the individual.
9.4 In certain instances, Lakeshore Communications will not be able to provide the individual access to his or her personal information. For example, Lakeshore Communications where the information contains references to other individuals; where the information cannot be disclosed for legal, security or commercial proprietary reasons; where the information is subject to solicitor-client or litigation privilege; or where the information can best be available from another source. In each case, Lakeshore Communications. will provide reasons for denying any access to personal information.
9.5 When an individual successfully demonstrates the inaccuracy or incompleteness of personal information, Lakeshore Communications will amend the information as required. Depending upon the nature of the information challenged, amendment involves the correction, deletion or addition of information. Where appropriate, the amended information will be transmitted to third parties having access to the information in question.
9.6 When a challenge is not resolved to the satisfaction of the individual, Lakeshore Communications will record the substance of the unresolved challenge. When appropriate, the existence of the unresolved challenge will be transmitted to third parties having access to the information in question.
10. CHALLENGING COMPLIANCE
An individual will be able to address a challenge concerning compliance with the above principles to Lakeshore Communications Privacy Officer.
10.1 Lakeshore Communications will maintain procedures to receive and respond to complaints or inquiries about its policies and practices relating to the handling of personal information. Lakeshore Communications will make every effort to ensure that its procedures are easily accessible and simple to use.
10.2 Lakeshore Communications will inform individuals who make inquiries or lodge complaints of the existence of relevant complaint procedures.
10.4 Lakeshore Communications will investigate all complaints. If a complaint is found to be justified, Lakeshore Communications will take appropriate measures, including, if necessary, amending its policies and practices.
30 Meteor Drive, Toronto, Ontario Canada M9W 1A4
Phone: 1-(866) 232-2201
General inquiries: firstname.lastname@example.org
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