POLICY RELATING TO THE COLLECTION AND RETENTION OF PERSONAL PRIVATE INFORMATION

 

Prepared for AVESTIN, INC., 

and VARASMUS (A DIVISION OF AVESTIN, INC.)

 

January 1, 2008

 

PURPOSE:     

 

A)                Where the above companies are all engaged in Commercial Activities that sometimes involve the collection of personal and private information from customers, suppliers and the general public; and

B)                 Where the above companies are sensitive to the collection and use of that information because of its importance to the individual from whom it is collected;

C)                And where the companies wish to be in compliance with certain federal legislation as it relates to the collection and use of personal private information;

 

THE COMPANIES HEREBY ENACT THIS POLICY ON THE COLLECTION AND RETENTION OF PERSONAL PRIVATE INFORMATION.

 

SCOPE:

 

1)                  This policy is intended to address the collection and use of information that is both personal and identifiable to an individual.  Personal and Identifiable information includes personal characteristics such as home address, telephone number, social insurance numbers and financial information.

 

2)                  For clarity, this policy is not meant to capture the collection of corporate information from other companies or businesses.

 

3)                  This policy shall also apply to any consultant such as lawyers and accountants that the companies may engage in the regular course of business.

 

SOURCE OF INFORMATION:

 

            Customers

 

4)                  To ensure proper billing practices and good book-keeping, the Companies are often required to collect home contact information as well as financial details, including credit history, from individual customers.

 

5)                  Further, the collection of one’s profession and previous dealings with our Companies allows us to maintain a list of customers and to ensure that our products continue to serve their needs as they may evolve.

 

Suppliers and Contract Workers

 

6)                  In order to ensure that our Companies have adequate resources to conduct our business, we will often need to acquire supplies and additional casual labour.

 

7)                  To properly pay for these supplies and services, our Companies are required to collect financial information such as banking details and home contact information from service providers.

 

8)                  Additionally, the collection of contact information will permit the Companies to maintain a list of suppliers to fill vacancies or to perform similar tasks in the future as such opportunities arise.

 

Students

 

9)                  Our Companies will often work with Universities through their Co-Operative Education programs and will hire students for a determined work-term.

 

10)              In order to ensure we have hired qualified candidates, our Companies will often collect academic information including student numbers and academic records.

 

11)              In order to ensure the effectiveness of the Co-Op program, the Companies will continue to collect personal information such as performance reviews of students throughout the work-term.  Students acknowledge the importance of this collection process to the program and understand that it will be shared with their university whatever its content.

 

General Public

 

12)              In order to ensure a high quality of staffing as vacancies arise, our Companies will solicit applications from qualified individuals.

 

13)              Although not requested by our Companies, candidates will often supply personal information such as birth dates, social insurance numbers, citizenship, educational background and community involvement.

 

14)              In order to ensure the safety and security of our staff and of visitors to our facility, our Companies utilize a Closed-Circuit Camera in the lobby of our building.  The data obtained from this camera is not recorded and is not used for any other purpose.

 

USE AND DISCLOSURE:

 

15)              None of the personal information collected shall be used for any other purpose than the purposes outlined in this policy.

 

16)              It is rare that our Companies would disclose any personal information without the consent of the individual concerned.  There are certain instances, however, where such consent is not required such as medical emergencies, debt collection, reporting to federal agencies (such as Canada Customs and Revenue) and the Courts or during the investigation of criminal activity.

 

STORAGE OF PRIVATE INFORMATION:

 

17)              The Companies shall endeavor to keep the information covered by this policy secure during the entire time it is in the possession of our companies.  To that end, private information (with the exception of certain financial information contained on invoices) shall be kept in company safes whose combinations are known only to three employees.

 

18)              As a general rule, personal information shall be maintained for a minimum period of seven years to satisfy the audit requirements of the Canada Customs and Revenue Agency.  At the expiration of that period, the documents shall be disposed of in a manner acceptable to the tax authorities.  Applications submitted by the general public shall be maintained for a maximum of six months at which time they shall be destroyed.

 

ACCESS TO INFORMATION:

 

19)              Any individual who knows or suspects our companies are in possession of personal information is entitled to know the degree and content of that information. 

 

20)              In order to view the information, an individual must arrange an appointment with the Privacy Officer either verbally or in writing and must detail the nature of the information sought with as much precision as is possible in the circumstances.  No information will be revealed in any manner other than during a personal meeting with the Privacy Officer.

 

21)              We may charge a nominal fee to process your request.

 

22)              Not every request to view personal information will be granted.  There are certain legal exceptions to the disclosure of information to an individual.  In the event your request has been denied, the Privacy Officer will advise you in writing of the detailed reasons for the refusal.

 

23)              Upon viewing the information, an individual may request that the Companies correct factual errors.  In the event the Companies disagree as to the accuracy of the information and the correction proposed, a notation shall be made in the file of your objection and delivered to any individual who has had access to that information.

 

CONCERNS:

 

24)              Any concerns regarding this policy or its application may be directed to the Privacy Officer:

 

Peter Goodings

2450 Don Reid Drive

Ottawa, ON   K1H 1E1

 

-or-

 

Michelle Gomes

2450 Don Reid Drive

Ottawa, ON   K1H 1E1

 

25)              If you wish to make a formal complaint please address your concerns in writing to the Privacy Officer.  All complaints received by the Privacy Officer shall be investigated and a report detailing the results of that investigation shall be delivered to you within 60 days.

 

26)              For more general inquiries regarding privacy legislation in Canada, please address your questions to:

 

The Information and Privacy Commissioner of Canada

112 Kent Street

Ottawa, ON   K1A 1H3

 

 

 

 

_______________________                                      __________________________

 

Peter Goodings                                                             Michelle Gomes