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Privacy
INTRODUCTION
S.D.G. Community Futures Development Corporation (S.D.& G. CFDC) is a federally supported not-for-profit community organization with a volunteer Board of Directors and professional staff whose purpose is to support community economic development and small business growth through business loans or loan guarantees.
Our privacy policies and procedures have been developed to comply with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA). PIPEDA sets out rules for the collection, use and disclosure of a client's or customer's personal information, as well as safeguarding that information in the course of commercial activity as defined in the legislation.
WHAT IS "PERSONAL INFORMATION"
Under PIPEDA, "Personal Information" means any information that is identifiable to an individual, including name, address, telephone number, Social Insurance Number, and date of birth. It also includes, but is not limited to, other information relating to identity, such as, nationality, gender, marital status, financial information and credit history.
COLLECTION OF PERSONAL INFORMATION
In the course of providing services to our clients, we collect personal information on occasion. Our primary purposes of collecting personal information is typically related to the following:
- address, e-mail and telephone information for marketing purposes
- business contact information for the maintenance of the SDG Business Directory
- personal information required to assess a prospective applicant's eligibility for financial assistance, as well as to report to Industry Canada, the federal department that administers the Ontario Community Futures Program.
Personal information is collected directly from the individual concerned. Unless permitted by law, no personal information is collected about an individual without first obtaining the consent of the individual to the collection, use and dissemination of that information.
S.D.& G. CFDC does not knowingly collect Personal Information from anyone under the age of 18, especially children under 13, and does not use such information if S.D.& G. CFDC discovers that it is has been provided by a minor.
CONSENT
At the time of collecting personal information, the express, written consent of the individual applicant will be sought for the collection, use, retention and disclosure of their personal information for the purposes set out in S.D.& G. CFDC's privacy policy. An applicant may choose not to provide some or all of the personal information requested, but if S.D.& G. CFDC is unable to collect sufficient information to validate a financing request, the application for financing may be turned down.
ACCURACY
S.D. & G. CFDC endeavours to ensure that all personal information in active files are accurate, current and complete. When a client notifies S.D.&G. CFDC that his or her personal information requires correction or updating, the necessary changes will be made. Information contained in closed files is not updated.
LIMITING USE, RETENTION & DISCLOSURE
S.D. & G. CFDC uses and retains personal information for only those purposes to which the individual has consented.
S.D. & G. CFDC may disclose personal information of clients to organizations that perform services on its behalf. This will only be done if such organizations agree to use such information solely for the purposes of providing services to S.D. & G. CFDC and, with respect to that information, to act in a manner consistent with this Policy.
S.D. & G. CFDC does not sell, trade, barter or exchange for consideration any personal information it has obtained.
Please note that there are circumstances where the use and/or disclosure of personal information may be justified or permitted or where S.D. & G. CFDC is obliged to disclose information without consent. Such circumstances may include:
- Where required by law or by order or requirement of a court, administrative agency or other governmental tribunal;
- Where S.D. & G. CFDC believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
- Where it is necessary to establish or collect monies owning to S.D. & G. CFDC;
- Where it is necessary to permit S.D. & G. CFDC to pursue available remedies or limit any damages that S.D. & G. CFDC may sustain; or
- Where the information is public.
Where obliged or permitted to disclose information without consent, S.D. & G. CFDC will not disclose more information than is required.
SAFEGUARDS
S.D. & G. CFDC endeavours to maintain adequate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of personal information.
ACCESS TO PERSONAL INFORMATION
S.D. & G. CFDC permits access to and review of personal information held by S.D. & G. CFDC about an individual by the individual concerned.
If an individual believes any personal information concerning that individual is not correct, that person may request an amendment of that information by sending a request to our Privacy Officer.
S.D. & G. CFDC reserves the right to decline access to Personal Information where the information requested:
- Would disclose the Personal Information of another individual or of a deceased individual;
- Would disclose business confidential information that may harm S.D. & G. CFDC or the competitive position of a third party;
- Is subject to solicitor-client or litigation privilege;
Could reasonably result in: (i) serious harm to the treatment or recovery of the individual concerned; (ii) serious emotional harm to the individual or another individual; or (iii) serious bodily harm to another individual;
- May harm, or interfere with, law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions;
- Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information; or
- Does not exist, is not held, or cannot be found by S.D. & G. CFDC.
- Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.
Where information will be disclosed, S.D. & G. CFDC will endeavor to provide the information within a reasonable time and no later than 60 days following the request.
To guard against fraudulent requests for access, S.D. & G. CFDC will require sufficient information to allow it to confirm the identity of the person making the request before granting access or making corrections.
INVESTIGATING COMPLAINTS
Any concern or issue about S.D. & G. CFDC's personal information handling practises may be made, in writing, to the S.D. & G CFDC Privacy Officer. Upon verification of the individual's identity, the Chief Privacy Officer will act promptly to investigate the complaint and provide a written report to the individual.
If the individual is dissatisfied with the report provided by the Privacy Officer, or feels that the corrective action taken by S.D. & G. CFDC is insufficient, the individual may direct a complaint to the Federal Privacy Commissioner in writing. The address of the Federal Privacy Commissioner is provided in this Privacy Statement for your convenience.
AMENDMENT OF PRACTICES AND THIS POLICY
This statement is in effect as of January 1, 2004. S.D. & G. CFDC will from time to time review and revise its privacy practices and this Policy. In the event of any amendment, a notice will be communicated to clients and others in an appropriate manner.
S.D. & G.'s PRIVACY OFFICER
Questions about this privacy policy or requests to view personal information should be directed to our Privacy Officer:
Gay Hamilton
Privacy Officer
S.D & G. CFDC
26 Pitt Street, Suite 207
Cornwall ON K6J 3P2
Phone: (613) 932-4333
Facsimile: (613) 932-0596
OTHER HELPFUL PRIVACY LINKS
For a copy of PIPEDA, or for answers to other questions regarding privacy legislation, contact the following offices.
Federal Privacy Commissioner
www.privcom.gc.ca
112 Kent Street
Ottawa, ON
K1A 1H3
Provincial Privacy Commissioner
www.privcom.on.ca
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