|
About Us
Canadian University Press Media Services, Ltd. (“Campus Plus”)
Campus Plus Privacy Policy
The purpose of this Policy is to identify the types of personal information collected by Canadian University Press Media Services, Ltd. (“Campus Plus”), to specify the purposes for which that information is collected, the uses to which it may be put and the extent to which it may be disclosed to others.
This Policy also describes the security appropriate for each type of personal information held and the duration for which than information will be held. Finally, it identifies the way in which any person whose information we hold may review any information we hold on such person and may, if not satisfied with either that information or these policies, make complaint to a designated individual.
Campus Plus recognizes that it is responsible for the personal information it collects and holds. These procedures are intended to assure that personal information is given the protections required by the Personal Information Protection and Code for the Protection of Personal Information, which it incorporates.
Definitions
Collection: the act of gathering, acquiring, recording and obtaining Personal Information from any source, including Third Parties, by any means.
Consent: voluntary agreement with 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 Person or by an authorized representative. Express consent can be given orally, electronically or in writing but is always unequivocal and does not require any interference on the part of Campus Plus. Implied consent is consent that can reasonably be inferred from a Person’s action or inaction.
Individual: an individual other than an Employee who: (a) uses, or applies to use, the products or services of Campus Plus; or (b) corresponds with Campus Plus, including both complainants and applicants for employment; (c) enters a contest or completes a survey sponsored by Campus Plus.
Disclosure: making Personal Information available to a Third Party.
Employee: an employee or independent contractor of Campus Plus.
Person: an Employee or Individual.
Personal Information: information about an identifiable Person, but not: (a) information that is publicly available, such as a Person’s name, address, telephone number and electronic address, when listed in a directory or made available through directory assistance; (b) business-contact information, such as the name, title or business address or telephone number of an employee of an organization; (c) aggregate information that cannot be associated with a specific person, such as demographic statistics about Campus Plus customers, or number of visitors and average time spent on a website.
Third Party: a person other than an Employee or an Individual.
Use: the treatment, handling, and management of Personal Information by Campus Plus.
Accountability
Campus Plus is responsible for Personal Information under its control and shall designate one or more persons who are accountable for Campus Plus’s compliance with the following principles.
Responsibility for ensuring compliance with the provision of the Campus Plus Privacy Policy rests with the senior management of Campus Plus, which shall designate one or more persons to be accountable for compliance with the Campus Plus Privacy Policy. Other people within Campus Plus may be delegated to act on behalf of the designated person(s) or to take responsibility for the day-to-day collection and processing of Personal Information.
Campus Plus has designated a Chief Privacy Officer to oversee compliance with the Campus Plus Privacy Policy. The name and contact information of the Chief Privacy Officer shall be made available on the Campus Plus website at www.campusplus.com.
Campus Plus is responsible for Personal Information in its possession or control, including information that has been transferred to a Third Party for processing. Campus Plus shall use appropriate means to provide a comparable level of protection while information is being processed by a Third Party.
Campus Plus has implemented policies and procedures to give effect to the Campus Plus Privacy Policy, including: (a) implementing procedures to protect Personal Information and to oversee Campus Plus’s compliance with the Campus Plus Privacy Policy; (b) establishing procedures to receive and respond to inquiries or complaints; (c) training and communicating to staff about Campus Plus’s policies and practices; and (d) developing public information to explain Campus Plus’s policies and practices.
Identifying Purposes
Campus Plus will identify the purpose for which personal information is collected at or before the time the information is collected. The purposes for which information is collected, used or disclosed by Campus Plus must be those that a reasonable person would consider are appropriate in the circumstances.
2.1
Campus Plus endeavors to examine opportunities for using non-identifiable information (i.e., coded, anonymous or aggregated data) rather than personal information to meet Campus Plus’s purposes, which include client services and new business ventures.
2.2
Campus Plus has collected and collects Personal Information for the following purposes: (a) to establish and maintain responsible commercial relations with Individuals and/or Clients and to provide ongoing service; (b) to develop, enhance, market or provide products and services; (d) to manage and develop its business and operations, including personnel and employment matters.
2.3
Campus Plus may from time to time use a Person’s Personal Information to contact the Person about changes or similar notices related to Campus Plus products and services.
2.4
If a Person participates in a survey, enters a contest or other promotion offered on the Campus Plus website, Campus Plus may, under the prescribed rules of the promotion, use the Person’s name and certain other information to administer the promotion, such as contacting, announcing and promoting the winners of the promotion.
2.5
Unless required by law, Campus Plus shall not use or disclose, for any new purpose, Personal Information that has been collected without first identifying the new purpose and obtaining the consent of the Person.
Consent
The knowledge and informed consent of a Person are required at or before the collection, use or disclosure of Personal Information, except where exempted by law.
3.1
In obtaining consent for collection, use and disclosure of Personal Information, Campus Plus shall use reasonable efforts to ensure that a Person is advised of the identified purposes for which Personal Information will be used or disclosed.
3.2
Campus Plus shall take into account the sensitivity of the Personal Information when determining what form of consent is appropriate for the circumstances (e.g. express or implied consent). In general, the use of products and services by an Individual, or the acceptance of employment or benefits by an Employee, constitutes implied consent for Campus Plus to collect, use and disclose Personal Information for all identified purposes.
3.3
A Person may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Individuals may contact Campus Plus for more information regarding the implications of withdrawing consent.
Limiting Collection
The collection of Personal Information shall be limited to that which is necessary for the purposes identified by Campus Plus. Information shall be collected by fair and lawful means.
4.1
Campus Plus collects Personal Information primarily from Individuals or its Employees.
4.2
Campus Plus restricts the amount and type of information it collects to that which the individual has consented to.
Limiting Use, Disclosure, and Retention of Personal Information
Personal Information shall not be used or disclosed by Campus Plus for purposes other than those for which it was collected, except with the informed consent of the individual or as required by law. Personal Information shall be retained by Campus Plus only as long as necessary for the fulfillment of those purposes.
5.1
Campus Plus shall use and disclose personal information in Campus Plus’s control only for purposes for which Campus Plus collected it, unless Campus Plus obtains consent, or the use or disclosure are required by law.
5.2
Campus Plus retains information only as long as necessary to fulfill Campus Plus’s identified purposes.
5.3
Campus Plus shall retain Personal Information used to make a decision about an individual long enough to allow the individual to access that data and challenge its accuracy.
5.4
Campus Plus 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.
Accuracy
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 Campus Plus 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 Person.
6.2
Campus Plus shall update Personal Information about Persons as and when necessary to fulfill the identified purposes or upon notification by the Person.
Safeguards
Campus Plus shall protect Personal Information by security safeguards appropriate to the sensitivity of the information.
7.1
Campus Plus shall protect Personal Information against such risks as loss or theft, unauthorized access, disclosure, copying, use, or modification. Campus Plus shall protect all personal information it keeps regardless of its format.
7.2
All Campus Plus staff with access to Personal Information are aware of the importance of maintaining the confidentiality of Personal Information in Campus Plus’s control.
7.3
Campus Plus shall dispose of or destroy Personal Information in a way that prevents unauthorized parties from gaining access to it.
Openness
Campus Plus shall make readily available to Individuals specific information about its policies and practices relating to the management of Personal Information.
8.1
Campus Plus shall make its management policies and practices readily available, including (a) The name or title and address of the person who is accountable for Campus Plus’s Privacy Policy, and to whom individuals may direct their complaints or inquiries; (b) How individuals can get access to Personal Information in Campus Plus’s control; (c)The type of Personal Information Campus Plus holds, including a general account of its use.
Individual Access
Upon request, Campus Plus shall inform Individual(s) of the existence, use, and disclosure of his or her Personal Information and shall be given access to that information. An Individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
9.1
Upon request, Campus Plus shall tell individuals if it has Personal Information about them and provide access to that data, except in limited circumstances. If access to Personal Information about the individual cannot be provided, Campus Plus shall provide the reasons for denying upon request. Campus Plus shall respond to an individual’s request for access in a reasonable time, and at a minimal, or preferably no, cost. Campus Plus shall provide the requested information to the Individual in a format that generally understandable, along with any explanation needed to facilitate the Individual’s understanding.
9.2
Campus Plus shall enable the Individual to challenge the accuracy and completeness of Personal Information in Campus Plus’s control, and amend it as appropriate. If Campus Plus does not agree with an Individual’s proposed amendment, Campus Plus will attach a statement of disagreement where Campus Plus cannot agree to the requested amendment.
9.3
Upon request, Campus Plus shall tell Individuals how their Personal Information is being used, and to whom it has been disclosed. In providing an account of disclosure, Campus Plus shall provide a list of organizations to which t may have disclosed Personal Information about the Individual when it is not possible to provide an actual list.
Challenging Compliance
An Individual shall be able to address a challenge concerning compliance with the above principles to the designated Individual or Individuals accountable for the organization’s compliance.
10.1
Campus Plus shall implement and maintain procedures to receive and respond to complaints or inquiries about Campus Plus’s handling of Personal Information. If any Person at any time has any questions or concerns about Campus Plus’s privacy practices, the Person can write to the Chief Privacy Officer at:
Campus Plus, c/o Chief Privacy Officer
920 Yonge Street, Suite 508
Toronto, Ontario
M4W 3C7
10.2
Campus Plus shall explain its inquiry and complaint procedures to Individuals. Campus Plus shall investigate all complaints; all appropriate measures to rectify a situation shall be taken if Campus Plus finds a complaint to be justified.
10.3
Campus Plus shall change its information management policies and practices, if necessary.
|
