Privacy Statement
Privacy at DST
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?
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
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
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.
A second primary purpose might be to collect personal information from third parties (e.g., regulatory agencies, neighbours) about a customer’s project.
A third primary purpose is to obtain home contact information so that we can contact the customer in private or in an emergency.
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
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.
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.
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
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.
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).
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).
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.
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
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.
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
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
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.
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
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
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.
We keep our customer files for many years. If you ask, we will remove such contact information right away.
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
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.
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.
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?
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?
The Information Officer will attempt to answer any questions or concerns you might have.
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.
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.
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
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