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PRIVACY POLICY Novus Consulting Inc. Personal Information Protection Policy At Novus Consulting Inc. ("Novus" and "we"), 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. In accordance and compliance with BC’s Personal Information Protection Act ("PIPA") and the Federal Personal Information Protection and Electronic Documents Act ("PIPEDA"), Novus is pleased to present the following privacy policy. Both PIPA and PIPEDA came into effect January 1, 2004. PIPA regulates how business may use, disclose, and exchange personal information collected in the course of business. PIPEDA establishes "in an era in which technology increasingly facilitates the circulation and exchange of information, rules to govern the collection, use and disclosure of personal information in a manner that recognizes the right of privacy of individuals with respect to their personal information and the need of organizations to collect, use or disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances." The British Columbia Personal Information Protection Act may be viewed at www.qp.gov.bc.ca/statreg/stat/P/03063_01.htm. The Federal Personal Information Protection and Electronic Documents Act may be viewed at www.parl.gc.ca/36/2/parlbus/chambus/house/bills/government/C-6/C-6_4/90052bE.html#3. Novus will inform our clients of why and how we collect, use and disclose their personal information, obtain consent where required, and handle personal information in a manner that a reasonable person would consider appropriate in the circumstances. This Personal Information Protection Policy, in compliance with PIPA, PIPEDA, and the National Standard of Canada Entitled Model Code for the Protection of Personal Information (Schedule 1, section 5 of PIPEDA, CAN/CSA-Q830-96), outlines the principles and practices Novus undertakes to protect clients' personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients' personal information and allowing our clients to request access to, and correction of, their personal information. Definitions Personal Information - includes but is not limited to information about an identifiable individual (for example, age, home address, credit history) but 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, PIPA, or PIPEDA. Privacy Officer - means the individual designated responsibility for ensuring that Novus complies with this policy, PIPA, and PIPEDA. Policy 1 - Collecting Personal Information 1.1 Unless the purposes for collecting personal information are obvious and the client voluntarily provides his or her personal information for those purposes, Novus will communicate the purposes for which personal information is being collected, either orally or in writing, before or during collection. 1.2 Novus will only collect client information that is necessary for:
Policy 2 - Consent 2.1 Novus will obtain client consent for collecting, using or disclosing personal information (except where, as noted below, we are authorized to do so without consent). 2.2 Consent can be provided via telephone, written, or by email, or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client, voluntarily provides personal information for that purpose. 2.3 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), clients can withhold or withdraw their consent for Novus 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 the client in making the decision. 2.4 Novus may collect, use or disclose personal information without the client's knowledge or consent in the following limited circumstances:
Policy 3 - Using and Disclosing Personal Information 3.1 Novus will only use or disclose client personal information where necessary to fulfill the purposes identified during collection such as but not limited to:
3.2 Novus will not use or disclose client personal information for any additional purpose unless we obtain consent to do so. 3.3 Novus will not sell or provide client lists or personal information to other parties under any circumstances. Policy 4 - Retaining Personal Information 4.1 If Novus uses client personal information to make a decision that directly affects the client Novus will retain that personal information for at least one year so that the client has a reasonable opportunity to request access to it. 4.2 Subject to policy 4.1, we will retain client 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 Novus will make reasonable efforts to ensure that client personal information is accurate and complete where it may be used to make a decision about the client. 5.2 Clients may request 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 Novus' Privacy Officer. 5.3 If the personal information is demonstrated to be inaccurate or incomplete, Novus will correct the information as required and will confirm the correction with the client. Policy 6 - Securing Personal Information 6.1 Novus is committed to ensuring the security of client 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, among others, will be followed by Novus and its employees to ensure that client personal information is appropriately protected: the use of locked filing cabinets; physically securing offices where personal information is held; the use of user IDs, passwords, encryption, and firewalls; and, restricting employee access to personal information as 6.3 Novus will use appropriate security measures when destroying client's personal information. 6.4 Novus will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security. Policy 7 - Providing Clients Access to Personal Information 7.1 Clients have a right to access their personal information, subject to limited exceptions. 7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought, and must be forwarded to the Privacy Officer. 7.3 Upon request, Novus will also inform clients how we use their personal information and to whom it has been disclosed if applicable. 7.4 Novus will make the requested information available within 30 business days. 7.5 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. Policy 8 - Questions and Complaints: The Role of the Privacy Officer or designated individual 8.1 The Privacy Officer (as required by PIPA) and designated individual (as required by PIPEDA) is responsible for ensuring Novus' compliance with this policy, PIPA, and PIPEDA. 8.2 Clients should direct any complaints, concerns or questions regarding Novus' compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client may also write to the Information and Privacy Commissioner of British Columbia, or alternatively, to the Office of the Privacy Commissioner of Canada. Contact information for Novus Consulting Inc.'s Privacy Officer: Jeremy Denegar Telephone: (250) 383-HELP (4357) |
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