Scope
Protecting your privacy is important to MINDWIRE Systems Ltd, its Directors, Officers and Management (collectively, “MINDWIRE”). This Policy explains how MINDWIRE collects, uses and discloses personal information provided by its consultants, sub-contractors and employees. This policy attests to this concern and corroborates our commitment to protecting such information.
This policy was established in accordance with the Personal Information Protection and Electronic Documents Act (federal “PIPEDA”).
The policy applies to personal information in all its forms – verbal, electronic, written or other – that an organization collects, uses, and discloses in the course of business activities. The term “personal information” refers to any information about an identifiable individual or any information that allows an individual to be identified. In general, personal information does not include business contact information, such as your name, title or position, business address, business telephone or fax number, in your capacity as an employee of an organization. During your relationship with MINDWIRE, you may be asked to provide certain personal information about yourself. Examples of such information include your date of birth, home address, financial and credit information, billing and account information and other information relating to the provision of consulting and staffing services by MINDWIRE.
Information of a public nature is not subject thereto.
Any personal information you provide to MINDWIRE will be treated with care and, subject to this Policy and applicable law, will not be used or disclosed in a way to which you have not consented. By submitting your personal information to MINDWIRE, you signify your consent to the collection, use and disclosure of your personal information in accordance with this Policy. If you do not consent to the collection, use and disclosure of your personal information in accordance with this Policy, please do not provide any personal information to MINDWIRE. Of course, certain services can only be offered to you if you provide MINDWIRE with your personal information. If you choose not to provide MINDWIRE with the required information, we would not be able to offer you those services.
This policy and the related procedures shall be periodically reviewed to ascertain their conformity and effectiveness.
Principles governing the protection of personal information
Accountability
MINDWIRE is responsible for the personal information it handles and shall designate a person responsible for ensuring compliance with the principles set forth below.
It is incumbent on the company’s senior management to control the compliance of this policy with the appropriate regulatory provisions and to appoint a person responsible for that undertaking. MINDWIRE shall disclose the title of the designated person on request. The role of the person responsible covers the following:
- ensuring that the company complies with the legislation respecting the handling and protection of personal information;
- ensuring that the company has implemented the measures required to protect the confidentiality of the personal information held;
- receiving requests for information or access to files and complaints, and processing them in a diligent and satisfactory manner;
- ensuring that all personnel are sensitized to the protection of personal information via training and the transmission of information about MINDWIRE’s policies and procedures;
Other MINDWIRE employees may be delegated to act on behalf of the designated person and look after the daily gathering and processing of personal information. Furthermore, the protection of personal and confidential information is incumbent on all employees at MINDWIRE. To that effect, every employee shall sign a confidentiality agreement as part of their employment. Temporary employees, consultants and subcontractors shall also sign a confidentiality agreement.
Identifying purposes
The purpose for which personal information is gathered shall be determined prior to or at the time of the gathering thereof. MINDWIRE collects, uses, and discloses personal information for the purposes identified prior to or at the time of collection, or as otherwise permitted or required by applicable law, including for the following purposes:
- to provide employment, consulting and other staffing related services;
- to comply with federal and provincial tax requirements, remittance obligations, or other government or regulatory requirements;
- to perform administrative, management and business functions, such as processing invoices, administering accounts, processing and remitting payments, fulfilling contractual obligations, and auditing our business operations;
- to develop our knowledge management systems and databases;
- to distribute MINDWIRE publications, invitations to seminars and events, and other communications which MINDWIRE believes may be of interest to consultants, subcontractors, and employees;
- to contact and communicate with consultants and other individuals for the purpose of conducting market research, and evaluating service and satisfaction;
- to fulfill any other purpose for which we have your consent.
Consent
A person shall be informed of and consent to any gathering, use, or communication of personal information about him or her, unless it is not appropriate to do so. To the extent possible, we will obtain consent to collect, use, and disclose personal information about an individual directly from such individual. However, if you provide personal information concerning another individual to MINDWIRE, you represent that, prior to submitting such information, you have obtained the necessary consent or authority to permit MINDWIRE to collect, use, and disclose such personal information for the purposes set out in this Policy, or the collection, use and disclosure is permitted by applicable law. MINDWIRE will not collect, use, or disclose personal information without the consent of the individual(s) concerned unless we are permitted or required to do so by applicable law. We generally do not obtain the consent of the individual(s) concerned in the following circumstances:
- if legal, medical, or security reasons make it impossible or impractical to seek consent; and
- whenever information is collected for the detection and prevention of fraud or for law enforcement, and when seeking the consent of the individual may defeat the purpose of collecting the information.
Limiting collection, use and disclosure
MINDWIRE shall only gather the personal information needed for a specific purpose and proceed in an honest and lawful manner.
MINDWIRE strives to limit the amount of personal information collected to what is necessary and appropriate for specific purposes. We will not use or disclose your personal information for purposes other than those for which it was collected, except with your consent or as permitted or required by applicable law.
If MINDWIRE is involved in a merger or other reorganization, MINDWIRE may disclose your personal information to the resulting organization.
MINDWIRE does not sell or exchange for consideration any personal information it holds.
MINDWIRE shall not communicate confidential information to any external parties except those needed to conduct its business, as identified above. Some examples of third parties to whom MINDWIRE discloses confidential information to fulfill its mandate include payroll and benefit providers, government tax authorities, financial institutions, and regulatory entities.
Retention
MINDWIRE shall not preserve any personal information it holds beyond the period prescribed for preservation requirements, no matter what medium is used.
The preservation period shall not exceed the longer of the following:
- the period needed for the authorized purposes, or
- the period prescribed by legal or other tax requirements.
The preservation period shall take into account the requests for access that a person might invoke subsequent to decisions made about him or her. However, it shall be limited to the strict interval of time needed for the personal information to fulfill the role for which it is intended.
Accuracy
Personal information shall be as accurate, complete and up-to-date as required for the purpose for which it is used. MINDWIRE shall update this information when needed for a set purpose, or on notification to this effect by the person concerned, if any information is erroneous or no longer valid.
