Privacy Policy

INTEGRATED SAFETY’S COMMITMENT TO PRIVACY

1.1 PURPOSE

At Integrated Safety, we take the issue of safeguarding privacy very seriously. We respect and are committed to protecting the confidentiality and security of Personal Information entrusted to us, and ensuring that all Personal Information we hold is collected, used and disclosed in compliance with all applicable federal and provincial privacy requirements (“Privacy Legislation”). Canada has two federal privacy laws, the Privacy Act and the Personal Information Protection and Electronic Documents Act. Alberta has the Freedom of Information and Protection of Privacy Act and regulation and Personal Information Protection Act, Saskatchewan has Freedom of Information and Protection of Privacy Act and regulations and the Local Freedom of Information and Protection of Privacy Act and regulations, and finally British Columbia has the Freedom of Information and Protection of Privacy Act, and Personal Information Protection Act.

1.2 DEFINITION

Within this Privacy Policy, “Personal Information” means information about an identifiable individual. Personal Information does not include publicly available information such as a public directory listing of an individual’s name, address or phone number; business contact information such as an individual’s name, position name or title, business telephone number, business address, business e-mail, business fax number and other similar business information; or aggregated information that cannot be associated with a specific individual.

1.3 SCOPE

This Privacy Policy applies to Integrated Safety, employees and students who enrol in Integrated Safety courses. In addition, contractors, consultants, agents, auditors, franchisees and other third party service providers are bound to comply with this Privacy Policy and Integrated Safety’s practices governing the protection of Personal Information and privacy, and Integrated Safety’s Acceptable Use of Technology Policy.

1.4 INTEGRATED SAFETY’S PRIVACY PRACTICES

Integrated Safety is committed to the ten principles noted below which are mandated in Privacy Legislation governing the collection, use and disclosure of Personal Information. These principles form the foundation of Integrated Safety’s Privacy Policy:

A. Accountability

• Integrated Safety is responsible for safeguarding Personal Information in its possession or control. Integrated Safety will use appropriate means to provide a comparable level of protection when Personal Information is being processed by a third party.

Responsibility for ensuring compliance with the provisions of this Privacy Policy rests with the designated Privacy Officer of Integrated Safety. The Privacy Officer will have responsibility for giving effect to the Privacy Policy, including:

1. implementing procedures to protect Personal Information and overseeing Integrated Safety’s compliance with this Privacy Policy;

2. b. establishing procedures to receive and respond to inquiries and complaints regarding Personal Information;

3. c. training staff and communicating with staff about Integrated Safety’s policies and practices; and

4. d. developing employee and student communications to explain Integrated Safety’s policies and practices.

5. The contact information of the person currently designated as Integrated Safety’s Privacy Officer is john@integratedsafety.ca.

B. Identifying Purposes for Collection

• Integrated Safety will document the purposes for which Personal Information is collected, and will only collect Personal Information for the identified purposes.

• Integrated Safety will specify to the individual, orally, electronically or in writing, the identified purposes at or before the time Personal Information is collected. Upon request, persons collecting Personal Information will explain these identified purposes or refer the individual to the Privacy Officer of Integrated Safety who will explain the purposes.

• In accordance with Privacy Legislation, Integrated Safety will identify and document any new purposes for which previously collected Personal Information may need to be used and disclosed, and obtain the consent of the individual where applicable.

C. Obtaining Consent for Collection, Use or Disclosure

• Integrated Safety will seek consent to use and disclose Personal Information at the same time it collects the information or in accordance with Privacy Legislation.

• In obtaining consent, Integrated Safety will ensure that an individual is advised of the identified purposes for which Personal Information will be used or disclosed. Purposes will be stated in a manner that can be reasonably understood.

• Examples of when Integrated Safety may collect, use and disclose Personal Information are to:

  • verify an individual’s identity;

  • process a payment or invoice;

  • provide a product or service that Integrated Safety offers;

  • register an individual in a course and/or determine an individual’s eligibility to register in a course whether such course is offered directly through Integrated Safety or through an Integrated Safety agent or franchisee.

  • provide information to agents or franchisees of Integrated Safety regarding student registration in courses;

  • provide the instructor and/or participants in a class or event with a list of attendees;

  • provide an individual with an Integrated Safety certificate regarding a completed course;

  • provide an individual with promotional/marketing materials as it relates to Integrated Safety’s business;

    or

  • provide access for industry participants and their respective member organizations to verify student certification in accordance with Integrated Safety authorized certificate search policies.

• In determining the appropriate form of consent, Integrated Safety will take into account the sensitivity of the Personal Information, the reasonable expectations of the individuals involved, and the requirements of Privacy Legislation.

• An individual may withdraw their consent to the collection, use and disclosure of Personal Information in accordance with this Privacy Policy at any time upon reasonable notice to Integrated Safety in writing, subject to legal or contractual restrictions. The withdrawal of an individual’s consent may affect Integrated Safety’s ability to continue to provide an individual with the products and services that the individual has or would like to receive.

D. Limiting Collection of Personal Information

• Integrated Safety will collect, use and disclose Personal Information in accordance with Privacy Legislation and will limit the amount and type of Personal Information collected to that which is necessary to fulfill identified purposes.

• Integrated Safety collects Personal Information primarily from its employees and students, but Integrated Safety may also collect Personal Information from other sources to meet the requirements of its business.

E. Limiting Use, Disclosure, and Retention of Information

• Integrated Safety will keep Personal Information only as long as it remains necessary or relevant for the identified purposes or as required by law. Specifically, as an educational institution certifying individuals and companies in safety training, Integrated Safety retains all Personal Information on students who have completed an Integrated Safety course and have been certified as doing so for a time period of at least ninety-nine years from the date of completion.

• Integrated Safety will maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to Personal Information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information will be destroyed, erased or made anonymous.

• Integrated Safety will maintain a record of the third parties that Personal Information is disclosed to in accordance with this Privacy Policy.

F. Accuracy of Personal Information

• Those individuals who are party to any Integrated Safety benefit plans or receive other benefits from Integrated Safety shall ensure that their Personal Information, particularly information that deals with benefit entitlement or status, is kept current, and accurately reported.

• Integrated Safety will update Personal Information as and when necessary to fulfill the identified purposes or upon notification by the individual.

G. Security Safeguards

• Integrated Safety will use its commercial best efforts to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, use, modification or destruction, through reasonable security measures. The nature of the safeguards will vary depending on the sensitivity of information collected.

• Integrated Safety will take all reasonable steps in the disposal or destruction of Personal Information, to seek to prevent unauthorized parties from gaining access to the Personal Information.

H. Openness Concerning Policies and Practices

• The information that Integrated Safety makes available about its policies and practices will include:

  1. the Email address, of the person(s) who is accountable for Integrated Safety’s policies and practices regarding the management of Personal Information and to whom complaints or inquiries can be forwarded;

  2. the means of gaining access to Personal Information held by Integrated Safety;

  3. a copy of information that explains Integrated Safety’s policies, standards or codes;

  4. the type of Personal Information made available to related organizations and the context and limitations of such Personal Information; and

  5. a description of the type of Personal Information held by Integrated Safety, including a general account of its use.

I. Individual Access to Personal Information

• Upon written request, Integrated Safety will provide individuals with the opportunity to review the Personal Information that Integrated Safety has collected regarding them, in accordance with the requirements of Privacy Legislation. Integrated Safety will advise the individual in advance of any charges for retrieval, reproduction or delivery of the Personal Information requested.

• In certain situations as specified in Privacy Legislation, Integrated Safety may not be able to provide access to all the Personal Information that it holds about an individual. For example, Integrated Safety may not provide access to information if doing so would likely reveal Personal Information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, Integrated Safety may not provide access to Personal Information if disclosure would reveal confidential commercial information;

• If the information is protected by solicitor client privilege; if the information was generated in the course of a formal dispute resolution process; or, if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law. If, upon a request being made by an individual, access to his or her Personal Information cannot be provided, Integrated Safety will provide the reasons for denying access.

• In order to safeguard Personal Information, an individual will be required to provide sufficient identification information to permit Integrated Safety to authorize access to the Personal Information held regarding that individual. Any such identification information will be used only for this purpose.

• Individuals can obtain information or seek access to their Personal Information by contacting the Privacy Officer

J. Challenging Compliance

• Integrated Safety will maintain procedures for addressing and responding to all inquiries or complaints from individuals about Integrated Safety’s handling of Personal Information.

• Integrated Safety’s Privacy Officer in conjunction with the appropriate parties involved will investigate all complaints concerning compliance with this Privacy Policy. If a complaint is found to be justified, Integrated Safety will take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures, or disciplinary action up to and including termination. An individual will be informed of the outcome of the investigation regarding his or her complaint.

• Integrated Safety will promptly correct or complete any Personal Information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness will be noted in the file in which the Personal Information is contained. Where appropriate, Integrated Safety will notify third parties having access to the Personal Information in question about any amended information or the existence of any unresolved differences.

• An individual that has concerns with Integrated Safety’s privacy practices should contact Integrated Safety’s Privacy Officer.

WEBSITE PRIVACY PRACTICES

1.5 How Integrated Safety Collects Information from the Integrated Safety Website

When an individual visits the Integrated Safety website, no personally identifiable information is collected unless the individual consents to that collection. The Integrated Safety website collects non-personally identifiable information as follows:

1.5.1 Non-personally Identifiable Information

Information from visitors to the Integrated Safety website is not tracked on an individual basis; but rather, the information is collected on an aggregate basis that includes all site visitors. Any visit to the Integrated Safety website automatically generates session log data consisting of the Internet Protocol (IP) address from which the connecting computer came (which contains no personal information), the website that referred the computer to the Integrated Safety website, the pages that are visited by the user, the date and time of those visits; and, the amount of time spent on the Integrated Safety website. Integrated Safety uses this information to perform analytics on users’ experience while using the site and to improve the functionality of Integrated Safety’s website to better meet user wants and needs; identify popular features; measure site activity including peak site usage times; and, page visits and click throughs. These site metrics may be shared with Integrated Safety’s affiliated service providers and others.

1.5.2 Cookies, Web Beacons and Advertisements

The Integrated Safety website uses “cookies”, web beacons/GIF/pixel tags, and third-party advertising networks that use ads and other tracking technologies to collect aggregate or other non-personally identifiable information to develop website metrics and improve a user’s online experience.

The Integrated Safety website may use session and/or persistent cookies to track user movement or other events across the website and the website of franchisees and business partners. A “cookie” is a small text file that helps Integrated Safety to improve the functionality of a user’s visit to the Integrated Safety website. Several different types of cookies are used by the Integrated Safety website. A session cookie is stored only on a visiting computer’s working memory (RAM) and only lasts for an individual’s browsing session. When an individual closes all of the browser’s windows or shuts down their computer, the session cookie disappears forever. A persistent cookie is stored on an individual’s computer hard drive until a specified date. Persistent cookies stay on an individual’s computer until they expire, they are overwritten by new cookies, or the individual manually removes them. Most browsers can be configured not to accept cookies, however, this may prevent a user from having access to some site functions or features.

The Integrated Safety website may use web beacons/GIF/pixel tags to help determine site metrics such as if a page has been viewed and how many times. In general, any electronic image viewed as part of a web page can act as a web beacon. When an individual requests information on a course or a newsletter, Integrated Safety may also use web beacons to establish how many of the emails are actually opened.

1.5.3 Collection and Use of Personally Identifiable Information on Integrated Safety’s Website

There are instances where Integrated Safety requests Personal Information on the Integrated Safety website in order to provide the user with a service, information on a course, a newsletter or where a user participates in interactive online activities such as course registration. Integrated Safety may conduct voluntary online surveys to obtain a user’s feedback. Integrated Safety requests e-mail addresses as a means of contacting a user if the user wishes to obtain ongoing information from Integrated Safety.

1.5.4 Links to other Websites

The Integrated Safety website may contain links to other websites. Integrated Safety encourages users to review the privacy statements of all sites which a user visits, including those whose links are provided, so that a user can understand how those sites collect, use and share a user’s information. Integrated Safety is not responsible for the privacy statements, content or data handling practices on other websites.

1.6 How Integrated Safety Uses and Discloses Information Collected From Integrated Safety’s Website

Information collected from our website will only be used and disclosed in accordance with this Privacy Policy.

1.7 Security and Accuracy of Information

When a user sends personal information to the Integrated Safety website, Integrated Safety uses “Secure Socket Layers” (SSL) to protect the user’s data. SSL is encryption technology that helps safeguard personal information against misuse by unauthorized individuals.

1.8 Related Legislation and Policies

Federal- Privacy Act and Personal Information Protection and Electronic Documents Act.

Alberta- Freedom of Information and Protection of Privacy Act and regulation and Personal Information Protection Act.

Saskatchewan- Freedom of Information and Protection of Privacy Act and regulations and the Local Freedom of Information and Protection of Privacy Act and regulations.

British Columbia- Freedom of Information and Protection of Privacy Act, and Personal Information Protection Act.