PRIVACY POLICY

POLICY 1 – COLLECTING PERSONAL INFORMATION

1.1  Unless the purposes for collecting personal information are obvious and the client or candidate voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2  We will only collect client or candidate information that is necessary to fulfill the following purposes:

• To verify identity

• To verify creditworthiness

• To identify client, candidate preferences such as role or preferred location

• To deliver requested products and services

• To ensure a high standard of service to our clients and candidates

• To meet regulatory requirements

POLICY 2 – CONSENT

2.1  We will obtain client or candidate consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2  Consent can be provided orally, in writing or electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client or candidate voluntarily provides personal information for that purpose.

2.3  Consent may also be implied where a client or candidate is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products and the client or candidate does not opt-out.

2.4  Subject to certain exceptions (e.g. the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients and candidates can withhold or withdraw their consent for Black Tusk Recruitment Inc. to use their personal information in certain ways. A client’s or candidate’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client or candidate in making the decision.

2.5  We may collect, use or disclose personal information without the client’s or candidate’s knowledge or consent in the following limited circumstances:

• When the collection, use or disclosure of personal information is permitted or required by law

• In an emergency that threatens an individual's life, health, or personal security

• When the personal information is available from a public source (e.g., a telephone directory)

• When we require legal advice from a lawyer

• For the purposes of collecting a debt

• To protect ourselves from fraud

• To investigate an anticipated breach of an agreement or a contravention of law

POLICY 3 – USING AND DISCLOSING PERSONAL INFORMATION

3.1  We will only use or disclose client or candidate’s personal information where necessary to fulfill the purposes identified at the time of collection [or for a purpose reasonably related to those purposes such as:

• To conduct client’s or candidate’s surveys in order to enhance the provision of our services

• To contact our client or candidates directly about products and services that may be of interest

3.2  We will not use or disclose client’s or candidate’s personal information for any additional purpose unless we obtain consent to do so.

3.3  We will not sell client’s or candidate’s lists or personal information to other parties.

POLICY 4 – RETAINING PERSONAL INFORMATION

4.1  If we use client or candidate personal information to make a decision that directly affects the client or candidate, we will retain that personal information for at least one year so that the client or candidate has a reasonable opportunity to request access to it.

4.2  Subject to policy 4.1, we will retain client and candidates personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

POLICY 5 – ENSURING ACCURACY OF PERSONAL INFORMATION

5.1  We will make reasonable efforts to ensure that client or candidates personal information is accurate and complete where it may be used to make a decision about the client or candidate or disclosed to another organization.

5.2  Clients or candidates may request correction to their personal information in order to ensure its accuracy and completeness.  A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.

5.3  A request to correct personal information should be forwarded to the Privacy Officer.

5.4  If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year.  If the correction is not made, we will note the client’s or candidate’s correction request in the file.

POLICY 6 – SECURING PERSONAL INFORMATION

6.1  We are committed to ensuring the security of client and candidate personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2  The following security measures will be followed to ensure that client or candidate personal information is appropriately protected:

• Physically securing offices where personal information is held

• The use of user IDs, passwords, encryption, firewalls, two factor authentication

• Restricting employee access to personal information as appropriate (i.e., only those that need to know will have access

• Thorough vetting of all service providers and software partners to ensure they comply with our security standards

6.3  We will use appropriate security measures when destroying client’s or candidate’s personal information such as:

• Shredding documents

• Deleting electronically stored information

• Encrypting all data and devices

6.4  We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

POLICY 7 – PROVIDING ACCESS TO PERSONAL INFORMATION 

7.1  Clients and candidates have a right to access their personal information, subject to limited exceptions.

• Solicitor-client privilege, disclosure would reveal personal information about another individual

• Health and safety concerns

7.2  A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer.

7.3  Upon request, we will also tell client’s or candidate’s how we use their personal information and to whom it has been disclosed if applicable.

7.4  We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

7.5  A minimal fee may be charged for providing access to personal information.  Where a fee may apply, we will inform the client or candidate of the cost and request further direction from the client or candidate, whether or not we should proceed with the request.

7.6  If a request is refused in full or in part, we will notify the client or candidate in writing, providing the reasons for refusal and the recourse available to the client or candidate.

POLICY 8 – QUESTIONS AND COMPLAINTS

8.1  The Privacy Officer or designated individual is responsible for ensuring Name of organization’s compliance with this policy and the Personal Information Protection Act.