DGBA understands it has a responsibility to protect the personal information under its control. We have implemented several personal information handling policies and procedures to ensure this protection. We will also use contractual or other means, to ensure any third party we share information with has similar, or better, procedures and policies in place to handle its information protection responsibilities. To oversee compliance with PIPEDA the DGBA has assigned Meg Pembleton as its Privacy Officer. She can be contacted as follows:
202 - 42 Wyndham Street North
Guelph, ON N1H 4E6
Ph: (519)836-6144 Fax: (519)767-0698
Email: [email protected]
2. Identifying Purposes, Current Purposes
Membership Surveys and Website Contact Forms
The Downtown Guelph Business Association collects personal information through annual membership surveys its website contact form. Personal information collected from our membership is for DGBA use only and will only be shared in an emergency situation or for legal purposes. Information collected from website contact forms is used for such things as marketing, business development, and visitor relationship management. Visitors who fill out this form can select a checkbox to indicate that they are interested in joining our mailing list for future mailings. Individuals may choose to unsubscribe from this mailing list from an unsubscribe email link in the actual mailing or by calling, faxing or emailing the Downtown Guelph Business Association's Privacy Officer. Information that is collected is kept in electronic form on our servers and/or in hard copy form under secure access. This information is only disclosed to the employees of the Downtown Guelph Business Association.
The Downtown Guelph Business Association does not utilize cookies on http://www.downtownguelph.com/.
Our web servers use log files to analyze trends, administer our site, track users' movements on an aggregate basis, and gather broad demographic information for aggregate use. The log files include things such as Internet Protocol addresses (IP addresses), browser types and versions, Internet service providers (ISPs), referring/exit pages, platform types, date/time stamp, and number of clicks. We currently use Webalyzer and AW Stats as our primary statistics systems.
Notice of Collection
We will inform individuals of the purpose for collecting information before or at the time we collect it. If a new purpose(s) for the information arises after it has been collected, explicit permission to use the information for the new purpose(s) will be obtained from the individuals to whom the information belongs, prior to its use. Any modification to the original purpose(s) will be documented in the Information Log.
The Downtown Guelph Business Association does not share its information with third parties.
The Downtown Guelph Business Association will obtain consent from an individual to collect, use, and/or disclose their personal information. Consent will be obtained either before or at the time of collection and in cases where a new purpose(s) has been identified after collection, consent will be obtained for the new purpose prior to use. We also recognize that the principle of obtaining consent is dependant on the level of sensitivity of the information and the reasonable expectations of the individual. Given this, the Downtown Guelph Business Association will take reasonable efforts to consider these things, in accordance with PIPEDA, whenever necessary.
Any time an individual wishes to withdraw consent they can contact the Downtown Guelph Business Association's Privacy Officer and the procedures and consequences of withdrawal will be explained. After such discussion and the identity of the individual and/or group has been verified, the Downtown Guelph Business Association's Privacy Officer will be more than happy to take the necessary and requested actions required to handle withdrawal of consent.
4. Limiting Collection
The Downtown Guelph Business Association will only collect information for the purposes stated before or at the time of collection of that information from an individual. We will specify the amount and type of information that is being collected and limit collection to those specifications.
5. Limiting Use, Disclosure, and Retention
The Downtown Guelph Business Association will only use and disclose personal information for the purposes stated before or at the time of collection of that information. We will specify the amount and type of information that is being collected and limit use and disclosure to those specifications.
The Downtown Guelph Business Association will retain information collected, used, and disclosed for its for its membership as long as it's current, unless otherwise agreed upon by the Downtown Guelph Business Association or the member. Personal information collected through our online contact form becomes part of a contact list and is kept until the individual unsubscribes or the information is no longer current. When personal information has been used to make a decision about a specific individual, that information will be available to the individual for a minimum of six months and a maximum of one year from the date of the decision. In the event a request for personal information has been refused, the personal information relating to that request shall be retained for a minimum of six months and a maximum of one year from the date refusal was delivered, not received. Once collected information has expired, it will be destroyed, erased, or made anonymous.
Though we make every effort to preserve user privacy, we may need to disclose personal information when required by law when we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order, or legal process served on http://www.downtownguelph.com/ or the Downtown Guelph Business Association.
The Downtown Guelph Business Association will make sure information is as accurate, complete, and up-to-date as is necessary for the purpose(s) that it was collected used, and/or disclosed. We do not routinely update personal information that is submitted through our online contact form. In the event an individual would like to add, edit, or delete their information, the Downtown Guelph Business Association's Privacy Officer would be happy to assist after verifying the individual's identity.
The Downtown Guelph Business Association protects the personal information it collects, uses, and discloses. Physical methods of protection include locks on appropriate office cabinets. Organizational methods of protection include internal policies and procedures for information use, collection and disclosure. Technical methods of protection include firewalls and password access controls. We make our employees aware of these safeguards and take care when disposing of personal information.
The Downtown Guelph Business Association's policies and procedures are primarily made available digitally, namely online via the Internet. In the event that digital access requires unreasonable effort on behalf of the individual, Downtown Guelph Business Association would be happy to send a package on our policies and procedures to requesting individuals, provided the cost of doing so is not prohibitively expensive. Questions, comments, and requests regarding our privacy policies and procedures can be forwarded to our Privacy Officer.
9. Individual Access
The Downtown Guelph Business Association will give an individual access to their personal information upon request, provided none of the exceptions noted in Paragraph 4.9 of Schedule 1 of PIPEDA apply. We must receive a request for access to personal information in writing, as per Paragraph 8(1) of PIPEDA and we will assist anyone in doing so, if required, as per Paragraph 8(2) of PIPEDA. If an individual would like their information added to, edited, or deleted after gaining access, the Downtown Guelph Business Association's Privacy Officer will be happy to comply, if possible. Certain circumstances may require us to refuse to provide a visitor with a copy of their information, but we will provide reasons for our refusal. For example, if you request access to your information and it contains information belonging to another individual who will not grant you permission to view their information, nor can that information be removed, we would be unable to grant you access.
Complaints Regarding Access
Requests for access to information are recorded in our Information Log. If an individual feels a request for information has not been handled satisfactorily, the individual should notify the Downtown Guelph Business Association's Privacy Officer in writing by fax, email or regular mail. Dissatisfaction will also be noted in the Information Log and the Privacy Officer will take reasonable efforts to remedy the complaint, if found justified.
10. Challenging Compliance
If an individual has a challenge regarding the Downtown Guelph Business Association's compliance with PIPEDA and Schedule 1 of PIPEDA, they must contact the Downtown Guelph Business Association's Privacy Officer. The complaint must contain an explicit statement of the events that occurred, the date, individuals involved, and contact information for the individual submitting the complaint. The Privacy Officer will investigate the complaint to the best of her abilities and with reasonable effort. The individual filing the complaint will be notified of the actions taken to remedy the complaint. The complaint will also be noted in the Information Log. In the event an individual is dissatisfied with the remedy for the complaint they may contact the Privacy Commissioner of Canada.
The Downtown Guelph Business Association website contains links to other sites. Please be aware that the Downtown Guelph Business Association is not responsible for the privacy practices of these other sites. We recommend site visitors make themselves aware of the policies of these other sites. Our privacy statement only applies to http://www.downtownguelph.com/.
12. Notification of Changes to Our Policies
13. Children's Privacy
The Downtown Guelph Business Association site does not knowingly collect children's information nor does it target children. In the event we discover we have collected, used, or disclosed children's information through the site we will take immediate action to discontinue such activity. Reasonable effort will be taken to notify the parent/guardian of the child/children involved of the circumstances and any action taken to investigate the matter.
Privacy Commissioner of Canada: Personal Information Protection and Electronic Documents Act (PIPEDA) and Your Responsibilities: A Guide for Businesses and Organizations
This statement was last updated September 4, 2007.