Principle 1: Accountability
Emergency Response Management Services Corporation (ERMS) is responsible for personal information under its control and will designate one or more persons who are accountable for ERMS' compliance with the following principles.
1.3 ERMS is responsible for personal information in its possession or control. ERMS will use contractual or other means to provide a comparable level of protection while information is being processed or used by a third party.
implementing procedures to receive and respond to complaints or inquiries;
training employees to understand and follow ERMS' policies and procedures;
developing information materials to explain ERMS' policies and procedures; and
Principle 2: Identifying Purposes for Collection of Personal Information
ERMS will identify the purposes for which personal information is collected at or before the time the information is collected.
2.1 ERMS collects personal information only for the following purposes:
to identify individuals;
to establish, maintain, communicate and renew ERMS Partnerships ;
to advertise, develop, enhance and provide marketing services and products;
to measure and improve the effectiveness of ERMS services, products and marketing endeavours;
to manage and develop ERMS' business operations, including personnel and employment matters;
to protect ERMS against error and fraud; and
to meet legal and regulatory requirements.
Further reference to "identified purposes" mean the purposes identified in this Principle.
2.2 Upon request, persons collecting personal information will explain these identified purposes or refer the individual to a designated person within ERMS who can explain the purposes.
2.3 When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose will be identified prior to use. Unless otherwise permitted or required by law, the consent of the individual will be acquired before the information will be used or disclosed for the new purpose.
2.4 ERMS will document the purposes for which personal information is collected prior to the information being collected.
2.5 ERMS will make reasonable efforts to ensure that individuals are aware of the purposes for which personal information is collected, including any disclosures to third parties.
Principle 3: Obtaining Consent for Collection, Use or Disclosure of Personal Information
3.1 In obtaining consent, ERMS will use reasonable efforts to ensure that, where not obvious, an individual is advised of the purposes for which personal information will be used or disclosed. The identified purposes will be stated in a manner that can be reasonably understood by the individual.
3.2 Generally, ERMS will seek consent to use and disclose personal information at the same time it collects the information. However, ERMS may seek consent to use and/or disclose personal information after it has been collected, but before it is used and/or disclosed for a new purpose.
3.3 ERMS may require individuals to consent to the collection, use and/or disclosure of personal information as a condition of the supply of a product or service only if such collection, use and/or disclosure are required to fulfill the explicitly specified and legitimate identified purposes.
3.4 In determining the appropriate form of consent, ERMS will take into account the sensitivity of the personal information and the reasonable expectations of the individual.
3.5 The purchase or use of products and/or ERMS services by a Partner or Customer, or the acceptance of employment or benefits by an employee, may constitute implied consent for ERMS to collect, use and disclose personal information for the identified purposes, including communicating with the individual.
3.6 An individual may withdraw consent at any time, subject to legal or contractual restrictions, provided that reasonable notice of withdrawal of consent is provided to ERMS and the withdrawal of consent is in writing and includes understanding by the individual that withdrawal of consent could mean that ERMS cannot provide the individual with a related product or service. Individuals may contact ERMS for more information regarding the implications of withdrawing consent.
3.7 ERMS may collect, use or disclose personal information without knowledge or consent if it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is seriously ill or mentally incapacitated.
3.8 ERMS may collect, use or disclose personal information without knowledge or consent if seeking the consent of the individual might defeat the purpose of collecting, using or disclosing the information, such as in the investigation of a breach of an agreement or a contravention of a law.
3.9 ERMS may collect, use or disclose personal information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened.
3.10 ERMS may use or disclose personal information without knowledge or consent to a lawyer representing ERMS, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law.
Principle 4: Limiting Collection of Personal Information
ERMS will limit the collection of personal information to that which is necessary for the purposes identified by ERMS. ERMS will collect personal information by fair and lawful means.
4.1 ERMS collects personal information primarily from Partners, Customers, potential future customers (prospects) and employees.
4.2 ERMS may also collect personal information from other sources including credit bureaus, employers or personal references, or other third parties who represent that they have the right to disclose the information.
Principle 5: Limiting Use, Disclosure, and Retention of Personal Information
ERMS will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. ERMS will retain personal information only as long as necessary for the fulfillment of those purposes.
5.1 ERMS may disclose an individual's personal information to: a third party who in the reasonable judgment of ERMS is seeking the information as an agent of the individual;
a third party involved in supplying the individual with ERMS products or services;
a third party engaged by ERMS to perform functions on its behalf;
a third party engaged by ERMS for the development, enhancement, marketing or provision of any of ERMS' products or services;
a third party engaged by ERMS to collect the Partner's account;
a credit reporting agency;
a public authority or agent of a public authority if, in the reasonable judgment of ERMS, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or
a third party or parties, where the individual consents to such disclosure or disclosure is required or permitted by law.
for normal personnel and benefits administration, such as the initiation, management or termination of the employment relationship; or
in the context of providing references regarding current or former employees in response to requests from prospective employers.
5.3 Only ERMS employees with a business "need-to-know", or whose duties reasonably so require, are granted access to personal information about Partners, Customers, Prospects and employees.
5.4 ERMS will keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about an individual, ERMS will retain, for a period of time that is reasonably sufficient to allow for access by the individual, either the actual information or the rationale for making the decision.
5.5 ERMS will maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction that 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.
Principle 6: Accuracy of Personal Information
Personal information will be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
6.1 Personal information used by ERMS will be sufficiently accurate, complete, and up-to date to minimize the possibility that inappropriate information may be used to make a decision about an individual.
6.2 ERMS will update personal information about individuals as necessary to fulfill the identified purposes or upon notification by the individual.
Principle 7: Security Safeguards
ERMS will protect personal information by security safeguards appropriate to the sensitivity of the information.
7.1 ERMS will protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held.
7.2 ERMS will protect personal information disclosed to third parties by contractual or other means to safeguard the confidentiality of the information and the purposes for which it is to be used.
7.3 All ERMS employees with access to personal information will be contractually required to respect the confidentiality of that information.
7.4 The nature of the safeguards will vary depending on the sensitivity, amount, distribution and format of the information, and the method of storage. More sensitive information will be safeguarded by a higher level of protection.
7.5 The methods of protection will include:
physical measures, for example, locked filing cabinets and restricted access to offices;
organizational measures, for example, controlling entry to data centre and limiting access to information on a "need-to-know" basis;
technological measurers, for example, the use of passwords and encryption; and
investigative measures, in cases where ERMS has reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed.
Principle 8: Openness Concerning Policies and Procedures
ERMS will make readily available to individuals specific information about its policies and procedures relating to the management of personal information.
8.1 ERMS will make information about its policies and procedures easy to understand, including:
the means of gaining access to personal information held by ERMS;
a description of the type of personal information held by ERMS, including a general account of its use; and
a description of what personal information is made available to third parties.
Principle 9: Access to Personal Information
ERMS will inform an individual of the existence, use, and disclosure of his or her personal information upon request and will provide the individual access to that information except where inappropriate. An individual will be able to challenge the accurateness and completeness of the information and have it amended as appropriate.
9.1 Upon request, ERMS will afford individuals a reasonable opportunity to review personal information in the custody of ERMS. Personal information will be provided in understandable form within a reasonable time, and at minimal or no cost to the individual.
9.2 In certain situations, ERMS may not be able to provide access to all the personal information that it holds about an individual. For example, ERMS may not provide access to information if doing so would likely reveal personal information about a third party, such as another individual, or could reasonably be expected to threaten the life or security of another individual. Also, ERMS may not provide access to 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 the laws of Canada or a province.
9.3 Upon request, ERMS will provide an account of the use and disclosure of personal information and, where reasonably possible, will state the source of the information. In providing an account of disclosure, ERMS will provide a list of third parties to which it may have disclosed personal information about the individual when it is not possible to provide an actual list.
9.4 In order to safeguard personal information, an individual may be required to provide sufficient identification information to permit ERMS to account for the existence, use and disclosure of personal information and to authorize such access. Any such information will be used only for this purpose.
9.5 ERMS 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 by ERMS. Where appropriate, the Company will transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.
9.6 Individuals can obtain information or seek access to their personal information by contacting the ERMS Privacy Officer.
Principle 10: Challenging Compliance
10.1 ERMS will maintain procedures for addressing and responding to all inquiries or complaints from individuals regarding the ERMS' handling of personal information.
10.2 ERMS will inform individuals about the existence of these procedures as well as the availability of complaint procedures.
10.5 If you are not satisfied with how ERMS responds to a complaint you may contact the Office of the Privacy Commissioner of Canada (OPC) to make a complaint. www.priv.gc.ca | 1-800-282-1376
Website Privacy Policies
Our site may automatically record some general information about your visit which we use for statistical analysis to help make our site more useful to visitors. This information might include the:
Internet domain for your Internet service provider, such as 'company.com' or 'service.ca' and the IP address of the computer accessing the website, such as 'ppp-55';
type of browser you are using, such as Internet Explorer or Netscape;
date and time you visit our site and Web pages that you visit on our site, along with the address of the previous website you were visiting, if you linked to us from another website.
We may also use "cookies" that identify you as a return visitor and which can help us tailor information to suit your individual preferences. A cookie is a piece of data that a website can send to your browser, which may then store the cookie on your hard drive. The goal is to save you time and provide you with a more meaningful visit and to measure website activity. Cookies do not contain any personally identifying information. Many browsers, however, allow you to disable cookie collection if you wish, or inform you when a cookie is being stored on your hard drive.
This policy discloses the privacy practices for our website. However, our site contains links to other sites. Once you link to another site, you are subject to the privacy and security policies of the new site. We encourage you to read the privacy policies of all websites you visit.
Emergency Response Management Services Corporation
2916 South Sheridan Way, Suite 300
Oakville, ON L6J 7J8
Attention: Privacy Officer