- "personal information" means information about you. Personal information does not include information that cannot be attributed to you. For example, information of an aggregate or anonymous nature.
Personal Information Made Anonymous
To the extent that we make any of your personal information anonymous or we aggregate it with the personal information of others, then that information will no longer be considered to be personal information. Therefore, CLAC will be entitled to use and disclose personal information in any manner that it desires provided the personal information has been rendered anonymous or aggregated where that information cannot be attributed to you.
Choosing to Provide Personal Information
In using any of the Websites and in dealing with us you will have the ability to control the amount of personal information you are providing and therefore you may restrict the disclosure of your personal information by not providing your personal information to the Websites or us in the first place. If you choose to limit the personal information you provide, it may limit the manner in which you can make use of the Websites or otherwise interact with CLAC.
Depending on the circumstances, your consent may be express or implied. Express consent would arise if you specifically consented to a particular dealing in your personal information. Express consent can be given orally, electronically or in writing. Implied consent can be inferred from the circumstances. For example, if we indicate that we may send certain correspondence to your home address and then you provide us with your home address in response, we would not normally obtain your explicit consent to use your home address to send you that correspondence; your consent would be implied in those circumstances.
We will assume your consent to the collection, use or disclosure of your personal information for a particular purpose if you voluntarily provide the information for that purpose.
Opting In and Opting Out
CLAC may, from time to time, provide you with an opportunity to opt out of certain collection, uses and disclosures of your personal information. At the same time, an implied consent to collect, use or disclose your personal information would arise if you fail to indicate that you wish to opt out of the particular collection, use or disclosure when you are given an opportunity to do so.
As well, CLAC may, from time to time, provide you with an opportunity to opt into certain collection, uses and disclosures of your personal information. In that case, if you do not opt-in, CLAC will assume that you do not consent to your personal information being collected, used or disclosed in that particular manner.
CLAC will generally use an opt-out method when the particular use or disclosure is not unusual, the information is not particularly sensitive or when CLAC believes that most people would likely consent to the particular use or disclosure. CLAC will generally use the opt-in method in other circumstances.
You may change or withdraw your consent at any time on reasonable notice, subject to pre-existing legal and contractual obligations, by contacting our Privacy Officer as set out below. If you withdraw certain consents, it may limit the manner in which you can make use of the Websites and to otherwise interact with CLAC. For clarity, your ability to change or withdraw consent is not absolute. CLAC reserves the right to continue handling your personal information in those circumstances required or permitted by law despite a change or withdrawal of consent.
In some instances, we may collect your personal information directly from a third party. In that case, we will generally either obtain your consent to do so or we will require that the third party confirm to us that they are entitled to disclose your personal information to us.
- using identification information and contact information, such as your name and e-mail address to provide information about CLAC and the Websites when you request that information;
- using identification information and contact information, such as your name and e-mail address so that we can identify you and deliver services, including in connection with the Websites, that you request and to communicate with you regarding those services;
- using payment method preferences and related financial information that you provide to us so that we can obtain payment for the services that you request;
- using information relating to your preferences so that we are able to deliver our services, including in connection with the Websites, to you in accordance with those preferences;
- using relationship information such as your service requests, instructions, comments and feed back to assist us in delivering services, including in connection with the Websites, in accordance with your wishes;
- using personal information for the purpose for which it was provided and certain other activities that are reasonably ancillary to that purpose. For example, if you send us an e-mail with a question or comment, CLAC will use your e-mail address to respond to you. Further, CLAC may store your e-mail and e-mail address and a copy of our response for future reference;
- using your e-mail address to provide you with information about new features or enhancements to our services and the Websites;
- analyzing your personal information to assist us in developing and enhancing our services and the Websites; and
- analyzing your personal information to assist us in conducting market analysis and strategic planning.
- Your personal information that you supply to the Websites will be disclosed in accordance with the description of disclosures as set out in the related documentation for the Websites or as may be readily apparent through the general operation of the Websites;
Use of the Websites
In order to use some of the features of the Websites, CLAC may require that you provide some personal information. CLAC may issue to you a unique "user id" which you will be required to provide each time you use certain features and services.
If you have a user id, then CLAC may collect information about your use of the features and services (whether or not you provide your user id each time) and CLAC may associate this information with your other personal information.
Our web servers collect the domain names, IP addresses and the activity of visitors. This information is aggregated for the purposes of measuring the number of visits, average time spent on the Websites, pages viewed, and other similar purposes. CLAC uses this information to measure the use of the Websites and to improve the content of the Websites.
Use of the [Profile Builder Portal]
In order to use the [Profile Builder Portal], you may need to provide certain of your personal information including current addresses, phone numbers, places of employment and any special skills and classifications. Any information that you provide may be sent to potential employers. If you do not wish for specific information to be provided to potential employers then you should not provide that information to the [Profile Builder Portal]. For additional details please see the [Profile Builder Portal Participation Agreement].
A technology called cookies may be used on certain pages of the Websites. A cookie is a tiny element of data that a website can send to your browser, which may then be stored on your hard drive. Cookies allow us to track visitors to the Websites so we will know when they return. Cookies also allow us to provide the visitor with tailored information and services based on their previous visits. Cookies do not enable us to identify the visitor unless that visitor has previously provided personal information during a visit. If your browser permits, you may set your browser to notify you when you receive a cookie or to reject cookies altogether. (See the documentation provided with your Internet browser for more information on cookies and how to disable them.)
Other Collection, Use and Disclosure
As well, the law permits or requires the collection, use and disclosure of personal information without the knowledge or consent of the individual in a number of circumstances. We reserve the right to collect, use and disclose your personal information in these circumstances without your knowledge or consent as the law may permit or require.
Accuracy and Completeness
When we collect, use or disclose personal information, we will make a reasonable effort to ensure that it is accurate, up to date and complete. To do so, we may need to request additional information from you or have you verify your information. If your personal information does change, we would appreciate it if you could inform us of those changes in order that your personal information in our possession remains accurate.
Retention and Destruction
For legal and business purposes we may retain your personal information for as long as it is reasonably needed. Upon expiry of the appropriate retention period, bearing in mind our reasonable legal and business requirements, your personal information will either be destroyed in a secure manner or made anonymous. You should be aware that there are legally required minimum retention periods, which CLAC must and does observe.
Security of Personal Information
CLAC recognizes its obligation to protect personal information in its possession and will make reasonable arrangements to secure that personal information against unauthorized access. These measures will be reasonable in the circumstance and may include providing access to only those individuals with a need to know the information, locked doors and/or filing cabinets and other physical and electronic security measures as well as contractual measures, such as non-disclosure or confidentiality agreements.
Requests for Access to Personal Information
On your written request we will provide you with:
- access to your personal information (if any) under our custody or control;
- information about the purposes for which your personal information under our custody or control has been and is being used by us; and
- the names of persons to whom, and the circumstances in which, your personal information has been and is being disclosed by us.
All requests may be subject to reasonable fees and disbursements. Where appropriate to do so, we may require advance payment of a deposit or the entire costs of responding to a request for access to personal information.
Requests Must be in Writing
We require that all requests for access be in writing and be signed by the requestor. We required sufficient information and detail from the requestor in order to verify their identity, properly locate the information and respond to the request.
Limits on Individual Rights to Information
An individual's ability to access his or her personal information under our control is not absolute. CLAC reserves all rights to not disclose personal information in certain circumstances. For example, we may not disclose personal information where:
- the disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual;
- the disclosure would reveal personal information about another individual;
- the disclosure of the information would reveal confidential commercial information; or
- the personal information was collected by us for an investigation or legal proceeding.
Requests for Correction of Personal Information
On request by you, we will correct errors or omissions in your personal information where that information is in our custody or control. We require that all such requests be in writing and signed by you. We may require sufficient information and detail from the individual in question in order to verify their identity, properly locate the information and respond.
If you make such a request, we will either:
- correct the personal information and, if reasonable to do so, send correction notifications to any third party to whom we disclosed the incorrect information; or
- decide not to correct the personal information but we will annotate the personal information that a correction was requested but not made.
Corrections or amendments will rarely, if ever, be made to opinions, including expert or professional opinions, as opposed to factual information, which may be corrected if in error.
Contacting or Communicating With Us
- have any questions with respect to our privacy policies or practises;
- have any questions with respect to our handling of your personal information;
- if you wish to request access to or correction of your personal information under our care or control; or
- if you are dissatisfied with our handling of your personal information,
please contact our Privacy Officer at:
Attention: Privacy Officer
45 Commmerce Court
Cambridge, ON N3C 4P7