POLICY RELATING TO THE COLLECTION AND RETENTION OF
PERSONAL PRIVATE INFORMATION
Prepared for AVESTIN, INC., AVESTIN INTERNATIONAL, INC.
and
VARASMUS, INC.
January
1, 2004
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.
14.1) Notwithstanding the preceding
paragraph, our facilities located at 499
Sussex Drive are video recorded. Any recordings
made are deleted after 48 hours unless they are required for insurance
purposes, to investigate criminal activity, or for other similar reasons.
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:
Sean A. Moreman,
LL.B., LL.L.
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