At Leadership Charisma Group, we are committed to providing our clients with exceptional service.  As providing this service involves the collection, use, and disclosure of some personal information about our clients protecting their personal information is one of our highest priorities.

While we have always respected our clients’ privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection & Electronic Document Act (PIPEDA).  PIPEDA, which was amended and came into effect on June 23, 2015, sets out the ground rules for how businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our clients of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection & Electronic Document Policy, in compliance with PIPEDA, outlines the principles and practices we will follow in protecting our clients’ personal information.  Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients, and prospects personal information and allowing our clients, and prospects to request access to, and correction of, their personal information.

Definitions

Personal Information –means information about an identifiable individual name, phone number, and email address.  Personal information does not include contact information (described below).

Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.  Contact information is not covered by this policy or PIPEDA.
Privacy Officer – means the individual designated responsibility for ensuring that Leadership Charisma Group complies with this policy and PIPEDA.

Policy 1 – Collecting Personal Information

1.1  Unless the purposes for collecting personal information are obvious and the clients voluntarily provide his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2  We will only collect our clients’ information that is necessary to fulfill the following purposes:

  • To send white papers, or information of interest or information about our services via email.

Policy 2 – Consent

2.1  We will obtain our clients’ consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2  Consent can be provided orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and our clients voluntarily provide personal information for that purpose.

2.3  Consent may also be implied where our clients are given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, and the client does not opt-out.

2.4  Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), our clients, and prospects can withhold or withdraw their consent for Leadership Charisma Group to use their personal information in certain ways.  A client’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product.  If so, we will explain the situation to assist our clients, and prospects in making the decision.

2.5  We may collect, use or disclose personal information without the client’s, prospect’s  knowledge or consent in the following limited circumstances:

  • When the collection, use or disclosure of personal information is permitted or required by law;
  • When the personal information is available from a public source (e.g., a telephone directory);
  • For the purposes of collecting a debt;
  • To protect ourselves from fraud;
  • To investigate an anticipated breach of an agreement or a contravention of law

Policy 3 – Using and Disclosing Personal Information

3.1  We will only use or disclose our clients’ personal information where necessary to fulfill the purposes identified at the time of collection:

  • To conduct client, customer, surveys in order to enhance the provision of our services;
  • To contact our clients, customers directly about products and services that may be of interest.

3.2  We will not use or disclose our clients’ personal information for any additional purpose unless we obtain consent to do so.

3.3  We will not sell our clients lists or personal information to other parties.

Policy 4 – Retaining Personal Information

4.1  If we use our clients’ personal information to make a decision that directly affects our clients,  we will retain that personal information for at least one year so that our clients has a reasonable opportunity to request access to it.

4.2  Subject to policy 4.1, we will retain our clients’ personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

 Policy 5 – Ensuring Accuracy of Personal Information

5.1  We will make reasonable efforts to ensure that our clients’ personal information is accurate and complete where it may be used to make a decision about our clients, and prospects.

5.2  Our clients may request a correction to their personal information in order to ensure its accuracy and completeness.  A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. A request to correct personal information should be forwarded to the Privacy Officer [or designated individual.

5.3  If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year.  If the correction is not made, we will note our clients’ correction request in the file.

Policy 6 – Securing Personal Information

6.1  We are committed to ensuring the security of our clients’ personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2  The following security measures will be followed to ensure that our clients, and prospects personal information is appropriately protected: physically securing offices where personal information is held; the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access; contractually requiring any service providers to provide comparable security measures).

6.3  We will use appropriate security measures when destroying our clients prospects personal information such as shredding documents, deleting electronically stored information.

6.4  We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Policy 7 – Providing Clients, and Prospects Access to Personal Information

7.1  Clients have a right to access their personal information, subject to limited exceptions such that disclosure would reveal personal information about another individual.

7.2  A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.  A request to access personal information should be forwarded to the Privacy Officer [or designated individual]

7.3  Upon request, we will also tell clients how we use their personal information and to whom it has been disclosed if applicable.

7.4  We will make the requested information available within 30 business days or provide written a notice of an extension where additional time is required to fulfill the request.

7.5  A minimal fee may be charged for providing access to personal information.  Where a fee may apply, we will inform the client, or prospect of the cost and request further direction from the client on whether or not we should proceed with the request.

7.6  If a request is refused in full or in part, we will notify the client in writing, providing the reasons for refusal and the recourse available to the client or prospect.

Policy 8 – Questions and Complaints:  The Role of the Privacy Officer or designated individual

8.1  The Privacy Officer or Charlie Regan is responsible for ensuring Leadership Charisma Group’s compliance with this policy and the Personal Information Protection & Electronic Document Act.

8.2  Clients should direct any complaints, concerns or questions regarding Leadership Charisma Group’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client, or prospect may also write to the Information and Privacy Commissioner of Ontario.

Contact information for Leadership Charisma Group’s Privacy Officer at 125 Alexandra Way, Blue Mountains, Ontario  L9Y 0S3