Privacy at DST
1. Privacy of personal information is an important
principle to DST. We are committed to collecting, using and
disclosing personal information responsibly and to the extent necessary
for the services we provide. We also try to be open and transparent as
to how we handle personal information. This document describes our
privacy policy and covers personal information of employees, customers,
suppliers and others.
What is Personal Information?
2. Personal information is information about an
individual and includes information that relates to their personal
characteristics (e.g., gender, age, income, home address, phone number,
ethnic background, family status), their health (e.g., disabilities
affecting mobility) or their activities and views (e.g., project plans,
religion, politics, property, expressed opinions). Personal
information contrasts with business information (e.g., an individual’s
business address and telephone number), which is not protected by
privacy legislation.
Who We Are
3. DST provides various services to customers. From
time to time we involve employees, consultants and agencies that may, in
the course of their duties, have access to personal information we hold.
These may include project managers, computer consultants, office
security and maintenance, bookkeepers and accountants, file storage
companies, temporary workers to cover holidays, credit card companies,
website managers, cleaners, our landlord and our lawyers. We restrict
their access to any personal information we hold as much as is
reasonably possible.
Primary Purposes: Information about Customers
4. We collect, use and disclose personal information
in order to serve our customers. For our customers, the primary purpose
for collecting personal information is to provide our services. Where
our customer is an individual, we collect necessary information about
the customer and their project. We then carry out their
instructions.
5. A second primary purpose might be to collect
personal information from third parties (e.g., regulatory agencies,
neighbours) about a customer’s project.
6. A third primary purpose is to obtain home contact
information so that we can contact the customer in private or in an
emergency.
7. It would be rare for us to collect any personal
information without the customer’s express consent, but this might occur
in a case of urgency (e.g., the customer is unavailable) or where we
believe the customer would consent if asked and it is impractical to
obtain consent (e.g., a family member who appears to be aware of the
project contacts us to provide additional information).
Primary Purposes: Information About Members of the General Public
8. For members of the general public, our primary
purpose for collecting personal information is usually to gather and
review information that is relevant to the project affecting our
customers. Thus, the personal information is usually incidental to our
providing advice to our customer. Normally this would be done with the
consent of the individual.
9. Another primary purpose for collecting personal
information about members of the general public is to provide notice of
special events (e.g., a seminar or conference) or to make them aware of
services in general or our firm in particular. For example, while we try
to collect work contact information where possible, we might collect
home addresses, fax numbers and email addresses. We try to obtain
consent before collecting any such personal information, but where this
is not, for any reason, possible, we will upon request remove any
personal information from our distribution list.
10. On our websites, we only collect, with the
exception of cookies (electronic markers identifying computers that have
previously visited our website), the personal information provided and
only use that information for the purpose given to us (e.g., to respond
to your email message, to register for a course, to subscribe to our
newsletters). Cookies are only used to help you navigate our website and
are not used to monitor you.
Primary Purposes: Information about Employees
11.1 DST strictly controls access to our employee’s
personal information. Access is provided to our staff who need
this information:
- for regulatory requirements such as
WSIB and CCRA reporting,
- for management purposes such as
contact for workplace location changes
- to serve you (e.g. direct payroll
deposit) or
- to analyze performance in order to
measure and improve our operations.
11.2 For people who are contracted to do work for us
(e.g., temporary workers and volunteers), our primary purpose for
collecting personal information is to ensure we can contact them in the
future (e.g., for new assignments) and for necessary work-related
communication (e.g., sending out pay cheques, year-end tax receipts, tax
filings).
11.3 Examples of the type of personal information we
collect for those purposes include home addresses & telephone numbers,
social insurance numbers, spouse telephone numbers and performance
information for a review. It is rare for us to collect such information
without prior consent, but it might happen for example in the case of a
health emergency (e.g., an outbreak of a contagious disease) or to
investigate a possible breach of law (e.g., if a theft were to occur in
the office).
11.4 Certain personal information (e.g. an employee’s
past employer) may be provided in resumes or other documents for the
express intent of marketing (such as proposals), but only to the extent
that the information is used to illustrate a person’s experience and
qualifications as related to DST’s services.
11.5 DST informs, trains and educates staff in the
matters included in this Policy as well as the privacy
obligations/responsibilities they have to adhere to within this Policy.
Primary Purposes: Information about Suppliers and Project Security
12. We collect personal information about contractors,
consultants and suppliers and their staff to assist us in assessing
their performance, both for specific proje cts and future projects. We
may share this information in a reciprocal way with other professionals
and construction contacts. Often this information is collected with
consent as a part of a written or verbal contract with the organizations
involved. Sometimes collecting personal information occurs without
consent, these relate to publicly available information, breach of
agreement and contravention of the law. Sometimes the information is
business, not personal, information.
13. We may collect personal information to maintain
the security of our projects and assets through security cameras and
security personnel. We try to make it known, through signs or the public
nature of the cameras and security personnel that we are doing so.
Primary Purposes: Third Party Opinions
14. When we are retained to provide an opinion about
the work of another firm or professional, our primary purpose for
collecting personal information is to gather the necessary information
to express a sound opinion on the issue for our customer. In such
circumstances, we often act without the consent of the subject of the
third party opinion because we are inquiring into an apparent breach of
law or an agreement and obtaining consent would compromise the
investigation.
Related and Secondary Purposes
15. Like most organizations, we also collect, use and
disclose information for purposes related to or secondary to our primary
purposes. The most common examples of our related and secondary purposes
are as follows:
- To invoice customers for goods or
services that are not paid for at the time, to process credit card
payments or to collect unpaid accounts.
- To advise customers and others of new
developments or services (e.g., a newsletter sent to a home email of
a customer).
- To advise customers and others of our
newsletters, courses we provide, special offers and promotions that
we have available.
- Our firm reviews customer and other
files for the purpose of ensuring that we provide high quality
services, including assessing the performance of our partners and
staff. In addition, external consultants (e.g., auditors, lawyers,
information technologists) may on our behalf do audits and
continuing quality improvement reviews of our firm, including
reviewing customer files and interviewing our staff.
- Some of our professionals are
regulated by the Ontario government who may inspect our records and
interview our staff as a part of its regulatory activities in the
public interest. In addition, as professionals, we may report
serious misconduct, incompetence or incapacity of other
practitioners, whether they belong to other organizations or our
own. Also, our firm believes that it should report information
suggesting serious illegal behaviour to the authorities. External
regulators have their own strict privacy obligations. These reports
could include personal information about our customers, or other
individuals, to support the concern (e.g., improper services),
although we try to keep this disclosure to a minimum. Also, like all
organizations, various government agencies (e.g., Canada Customs and
Revenue Agency, Information and Privacy Commissioner, Human Rights
Commission, etc.) have the authority to review our files and
interview our staff as a part of their mandates. In these
circumstances, we may consult with professionals (e.g., lawyers,
accountants) who will investigate the matter and report back to us.
- Customers or other individuals we
deal with may have questions about the services they received. We
also provide ongoing services for many of our customers over a
period of months or years for which previous records are helpful. We
retain our customer information for many years after the last
contact to enable us to respond to questions and provide further
services.
- If DST shares or assets were to be
sold, the purchaser may want to conduct a “due diligence” review of
the firm’s records to ensure that it is a viable business that has
been honestly portrayed to the purchaser. This due diligence may
involve some review of our accounting and service files. The
purchaser would not be able to remove or record personal
information. Before being provided access to the files, the
purchaser must provide a written promise to keep all personal
information confidential. Only reputable purchasers who have already
agreed to buy the organization’s business or its assets would be
provided access to personal information, and only for the purpose of
completing their due diligence search prior to closing the purchase.
- At times we may be asked for an
opinion on employees, suppliers or customers (e.g., references).
Only limited personal information will be released as it relates to
performance issues.
16. Customers can choose not to be part of some of these
related or secondary purposes, although there would normally be
additional fees involved. DST does not, however, have much choice
about some of these related or secondary purposes (e.g., external
regulation).
Protecting Personal Information
17. We understand the importance of protecting personal
information. For that reason, we have taken the following steps:
- Paper information is either under
supervision or secured in a locked or restricted area or building.
- Electronic hardware is either under
supervision or secured in a locked or restricted area. In addition,
passwords are used on computers. Not all of our cell phones may be
digital, and there is a possibility that signals can be intercepted.
- Paper information is transmitted
through sealed, addressed envelopes or boxes by reputable companies
or by DST staff.
- Electronic information is transmitted
either through a direct line or is anonymized or encrypted, or is
sent directly by email.
- Staff are trained to collect, use and
disclose personal information only as necessary to fulfill their
duties and in accordance with our privacy policy.
- External consultants and agencies
with access to personal information must provide us with appropriate
privacy assurances.
Retention and Destruction of Personal Information
18. We need to retain personal information for some time to
ensure that we can answer any questions you might have and for our own
accountability to external regulatory bodies.
19. We keep our customer files for many years. If you ask,
we will remove such contact information right away.
20. We destroy paper files containing personal information
by shredding. We destroy electronic information by deleting it.
Alternatively, we may send some or all of the customer file to the
individual. An exception is materials developed for marketing purposes
(e.g. resumes) which may be destroyed by conventional waste disposal or
recycling.
You Can Look at Your Information
21. With some exceptions, you have the right to see what
personal information we hold about you. Often all you have to do is ask.
We can help you identify what records we might have about you. We will
also try to help you understand any information you do not understand
(e.g., short forms, technical language, etc.). We will need to confirm
your identity, if we do not know you, before providing you with this
access. We reserve the right to charge a nominal fee for such requests.
22. We may ask you to put your request in writing. If
we cannot give you access, we will tell you within 30 days if at all
possible and tell you the reason, as best we can, as to why we cannot
give you access.
23. If you believe there is a mistake in the information,
you have the right to ask for it to be corrected. This applies to
factual information and not to any opinions we may have formed. We may
ask you to provide documentation that our files are wrong. Where we
agree that we made a mistake, we will make the correction and notify
anyone to whom we sent this information. If we do not agree that we have
made a mistake, we will still agree to include in our file a brief
statement from you on the point.
Who Looks After Our Privacy Policy?
24. Our Information Officer is the DST Branch Manager at the
location where the information is stored, and the Controller in the case
of information at the Administration Department location. The duties of
the Information Officer are:
- periodic policy review,
- implementing procedures to safeguard
personal information,
- ensuring individuals have the right
to access and correct erroneous information,
- retaining and destroying personal
information as required,
- staff training,
- acting as contact person for
inquiries, and
- ensuring a complaint process is in
place.
Do You Have a Question?
25. The Information Officer will attempt to answer any
questions or concerns you might have.
26. If you wish to make a formal complaint about our privacy
practices, you may make it in writing to our Information Officer who
will acknowledge receipt of your complaint, ensure that it is
investigated promptly and that you are provided with a formal decision
and reasons in writing.
2 7. This policy is made under the Personal Information
Protection and Electronic Documents Act of Canada. It is a complex
Act and provides some additional exceptions to the privacy principles
that are too detailed to set out here. There are some rare exceptions to
the commitments set out above.
28. For more general inquiries, the Information and Privacy
Commissioner of Canada oversees the administration of the privacy
legislation in the private sector. The Commissioner also acts as a kind
of ombudsman for privacy disputes. The Information and Privacy
Commissioner (see
www.privcom.gc.ca) can be reached at:
112 Kent Street. Ottawa, ON K1A 1H3
Phone: (613) 995-8210, Toll-free: 1-800-282-1376, Fax: (613)
947-6850