12.  Destination Leadership Privacy Policy

Introduction

Destination Leadership is committed to protecting and keeping clients’ personal information accurate, confidential, secure and private. This policy is based on the Canadian Standards Association (CSA) Model Code for the Protection of Personal Information (CAN/CSA-Q830-96), and the Federal Personal Information Protection and Electronic Documents Act ('PIPEDA'). It describes how Destination Leadership subscribes to the principles of the CSA Model Code. Copies of the CSA Model Code are available on request from the Canadian Standards Association at 1-800-463-6727.

This policy describes the principles Destination Leadership will use to protect the privacy of individual clients’ personal information in the carrying out commercial activities in Canada, no matter how the information is collected, used or disclosed.

This policy applies to each Associate of Destination Leadership as defined within this policy with respect to their operations in Canada. Where any Destination Leadership Associate is subject to laws or industry regulation or self regulatory requirements which impose greater or additional obligations with respect to the protection of personal information, Destination Leadership Associate also complies with those additional obligations.

Destination Leadership maintains electronic files including client name, email address, contact information for purposes of program enrollment, certification, and program historical data for reporting and record keeping. Destination Leadership will not share, disclose or provide personal information and follows the PIPEDA privacy principles within Canada.

The Ten Principles of Privacy

The privacy policy was 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 personal information in the course of commercial activity as defined in the Act.

The ten principles of PIPEDA that form the basis of this Privacy Policy are as follows:

• Principle #1: Destination Leadership Associate Accountability - The President is accountable for ensuring privacy and compliance is strictly adhered to and complied with on a day to day basis with all Destination Leadership Associates. 

• Principle #2: Identifying the Purposes of Collecting Personal Information - Each Destination Leadership Associate will identify the purposes for which it collects the personal information, before or when the information is collected.

• Principle #3: Getting the Client’s Consent - Each Destination Leadership Associate will make a reasonable effort to make sure clients understand how their personal information will be used by Destination Leadership. Each Destination Leadership Associate will obtain consent from its clients before or when it collects or uses the personal information. The Destination Leadership Associate will not attempt to deceive a customer into giving consent. A client’s consent can be express, implied, or given through an authorized representative. A client can withdraw consent at any time, with certain exceptions. The Destination Leadership Associate, however, may collect, use or disclose personal information without the client’s knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or as required by law.

• Principle #4: Limits for Collecting Personal Information - Destination Leadership limits the amount and type of personal information it collects. Each Destination Leadership Associate will collect personal information for the purposes it identifies to the customer. Destination Leadership collects personal information using policies and procedures which are fair and lawful.

• Principle #5: Limits for Using, Disclosing and Keeping Personal Information - Destination Leadership will use or disclose personal information only for the reasons it was collected, unless a client gives consent to use or disclose it for another reason, or it is permitted or required by law. Under certain exceptional circumstances, Destination Leadership may have a legal duty or right to disclose personal information without the client’s knowledge or consent to protect matters, which include the public interest. Destination Leadership will keep personal information only as long as necessary for the identified purposes for which it was collected.

• Principle #6: Keeping Personal Information Accurate - Destination Leadership will keep personal information as accurate, complete and current as necessary for the identified purposes for which it was collected. Clients may, in writing, challenge the accuracy and completeness of their personal information and request that it be amended as appropriate.

• Principle #7: Safeguarding Personal Information - Destination Leadership protects personal information with safeguards appropriate to the sensitivity of the information.

• Principle #8: Making Information About Policies and Procedures Available to Clients - Destination Leadership is open about the policies and procedures it uses to manage personal information. Clients have access to information about these policies and procedures. The information will be made available in a manner that is generally easy to understand.

• Principle #9: Customer Access to Personal Information - When clients make a request in writing, Destination Leadership will within a reasonable time tell them what personal information Destination Leadership has, what it is being used for, and to whom it has been disclosed. When clients request it in writing, Destination Leadership will give them access to their personal information. Destination Leadership will respond to the written request in a timely fashion. In certain situations, however, Destination Leadership may not be able to give clients access to all their personal information. Destination Leadership will explain the reasons for this lack of access and any recourse the client may have, except if prohibited by law.

• Principle #10: Handling Complaints and Questions - Clients may challenge Destination Leadership's compliance with this policy.

• 10.1 Destination Leadership has policies and procedures to receive, investigate, and respond to clients’ complaints and questions relating to privacy. Destination Leadership will inform clients of these policies and procedures, which are generally easy to understand and use. The complaint resolution process and the person to whom clients should contact are part of these policies and procedures.

• 10.2 Destination Leadership will investigate all complaints and if it finds a complaint justified, Destination Leadership will try to resolve it. If necessary, Destination Leadership will take appropriate measures, including changing its policies or procedures, to ensure that other clients will not experience the same problem.

• 10.3 If a client is not satisfied with the way Destination Leadership has responded to a complaint concerning their personal information, Destination Leadership will identify an outside agency to aid in the resolution.

• 10.4 If a customer is not satisfied that Destination Leadership is operating in compliance with the requirements of this policy the customer may file a written complaint with the Commissioner.

Federal Privacy Commissioner
112 Kent Street
Ottawa, Ontario. K1A 1H3
Tel: 1-613-995-8210
Toll free: 1-800-282-1376
Fax: 1-613-947-6850
Internet: https://www.priv.gc.ca/en/privacy-topics/privacy-laws-in-canada/the-personal-information-protection-and-electronic-documents-act-pipeda/p_principle/