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Cook Communications Ministries Canada Ltd. recognizes the importance of
privacy and the sensitivity of personal information for all our members. For
these reasons we have created the following privacy policy (the �policy�). The
privacy policy outlines how we manage your personal information, the uses to
which your personal information is put and how we safeguard your privacy.
Your Privacy Rights
From January 1, 2004 all businesses engaged in commercial activity must
comply with the Personal Information Protection and Electronic Documents Act,
and the Canadian Standards Association Model Code for the Protection of
Personal Information, which it incorporates. These obligations extend
to our company and the act gives you, our members, certain rights concerning the
privacy of your personal information.
Employer is responsible for the personal information we collect and hold. To
ensure this accountability, we have developed this policy and trained our staff
about out policies and practices.
An Overview
1. What this Policy Covers
This policy covers our treatment of the personal information we collect from
you.
This policy also covers our treatment of the personal information we collect
from and about our employees and staff.
2. Purposes for Collection of Personal Information
Our company collects personal information for the following limited purposes:
a) to establish and maintain member mailing lists
b) to monitor customer accounts
c) to retain and utilize credit facilities
d) for inclusion in our weekly news letters
e) to identify customer orders
3. How Do We Collect Your Personal Information?
We collect information only by lawful and fair means that are not reasonably
intrusive. Wherever possible we collect your personal information from you
directly at the start of your relationship with Cook Communications Canada Ltd..
In the case of our employees, we may obtain personal information on you from
other sources, for example:
- your insurance company
- your accountant
- the government
4. How is Personal Information Maintained ?
Our company does not sell, barter, trade or give away your personal
information to third parties. For example, we do not provide our member mailing
list to other companies.
Our company stores and maintains personal information conformity with the
requirements of the Personal Information Protection and Electronic Document
Act and the Model Code for the Protection of Personal Information
created and approved by the Canadian Standards Association.
B. Application of the Code
Employer applies the ten principles of the code as follows:
1. Accountability
Our company is responsible for the personal information collected and
maintained by us and which is under our control. In order to fill this
responsibility:
a) we have designated officials to be responsible for the day to day care and
control of personal information;
b) our staff oversees compliance with the terms of this policy;
c) our company has taken the following measures to ensure compliance with
this policy:
- developing procedures to protect personal information;
- developing procedures to receive and respond to complaints and inquiries;
- training our staff about the policies and practices respecting personal
information;
- developing and distributing information to our staff and the general
public explaining our policies and procedures respecting personal information.
2. Identifying Purposes
We committed to openness to you regarding the collection and use of your
personal information. As discussed above we collect and use personal information
for the following limited purposes:
a) to establish and maintain member mailing lists
b) to monitor customer account
c) to establish and monitor credit facilities
d) for inclusion in our monthly news letters
e) to identify and process customer orders
f) to maintain the employment relationship with our employees
To demonstrate this openness that we require the consent of our clients and
mailing list subscribers prior to using their personal information for any
purpose other than that for which is was originally collected.
If any individuals wish to be advised of the personal information we have in
relation to them, they are advised to follow the procedure listed in Section C
below.
3. Consent
In most cases, we shall ask you to specifically consent, if we collect, use,
or disclose your personal information. Normally we ask you for your consent in
writing but in some circumstances, we may accept your oral consent. Sometimes
your consent may be implied throughout your conduct with us.
For example, it is the company�s position that all personal information may
be collected, used and disclosed for the purposes listed in Section 2 above. If
you do not wish your personal information for one such purpose please contact
the company�s privacy officer at the address listed in Section C below.
The company will only further disclose your personal information, without
notice, only in the situations described in Section 5 below.
4. Limiting Collection
Our company restricts the collection of personal information only to that
information that is necessary for the limited purposes noted above. We are
committed to collecting personal information in a fair, open and lawful manner.
For this reason, our company does not indiscriminately collect personal
information. We collect personal information to fulfill the above noted purposes
only, and for no other purpose.
5. Limiting Use, Disclosure and Retention
Our company does not use personal information for purposes other than those
for which it was originally collected, unless it has first obtained the consent
of the person from whom such information was received.
Further, Employer will only disclose your personal information under the
following circumstances:
- when we are required or authorized by law to do so, for example if a court
issues a subpoena;
- when you have consented to the disclosure;
- where it is necessary to establish or collect fees;
- if the information is already publicly known.
- We retain personal information only for as long as it is needed and only for
the fulfilment of the purposes for which it was originally collected.
6. Accuracy
Since we use your personal information to maintain our company roster list,
it is important that the information be accurate and up-to-date. If during the
course of your membership any of your information changes, please inform us of
such changes and we will update our records accordingly.
You may confirm the accuracy of your personal information by contacting us in
writing or by e-mailing your request to the address set out in Section C below.
7. Safeguards
Our company takes all reasonable precautions to ensure that your personal
information is kept safe from loss, unauthorized access, modification or
disclosure. Among the steps taken to protect your information are:
premise security;
restricted file access to personal information;
secured data bases where customer information is stored;
hard copies of customer information kept in a locked office in filing
cabinets.
We also ensure that any of our employees who deal with personal information
are properly trained and are aware of the necessary and appropriate measures
required to protect personal information.
8. Openness
Our company makes information about its policies and practices respecting the
collection and maintenance of personal information available to all interested
parties.
We are pleased to answer any questions that you may have regarding the
collection and maintenance of personal information. Please forward any questions
in writing or by e-mail to the address set out in Section C below.
9. Individual Access
You may ask for access to any personal information which we hold about you.
However, we reserve the right to confirm the identity of the persons seeking
access to personal information before complying with any requests.
Summary information is available upon request. More detailed requests which
require archival or other retrieval costs may be subject to a nominal fee.
However, your rights to access of your personal information are not absolute.
We may deny access when;
- denial of access is required or authorized by law;
- information relates to existing or anticipated legal proceedings against you;
- when granting you access would have an unreasonable impact on other people�s
privacy;
- when to do so would prejudice negotiation with you;
- to protect our company�s rights and property;
- when the request is frivolous or vexatious.
If we deny your request to information we shall provide you with a written
explanation for such denial.
10. Challenging Compliance
Our company has designated officials who are responsible for the day to day
care and control of personal information. These officials will receive and
respond to all information requests concerning our privacy policies or about
your personal information under our care and control.
We investigate all complaints received by us and will respond in writing in a
timely manner. If any complaint is found to be justified, then we will take the
appropriate measures to respond to the matter to the satisfaction of the
complainant.
C. How to Access or Amend Your Personal Information
1. Requests for Access
If you have any questions, or wish to access your personal information,
please write to our privacy contact at:
Cook Communications Canada Ltd.
Attention: Hardy Willms
55 Woodslee Ave, PO Box 98
Paris, Ontario
N3L 3E5
If you are not satisfied with our response, the Privacy Commissioner of
Canada can be reached at:
112 Kent Street
Ottawa, ON
K1A 1H3
1-800-282-1376
2. Communicating With Us
You should be aware that e-mail is not a 100% secure medium, and you should
be aware of this when contacting us to send personal or confidential
information.
D. Notes
2. Changes to This Privacy Policy
Since Employer regularly reviews all of its policies and procedures, we may
change our privacy policy from time to time.
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