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NetTwo Solutions Privacy Policy

NetTwo.ca is bound by PIPEDA and requires consent where the personal information it collects, uses, discloses and retains is used in the course of its commercial activities. The Nettwo.ca  collects, uses, discloses and retains for Regulatory purposes does not require consent.

The following are the 10 principles with which Nettwo.ca is required to comply with respect to personal information:

1. ACCOUNTABILITY

Nettwo.ca is responsible for personal information under its control and shall designate one or more administrative members who are accountable for Nettwo.ca compliance. The identity of the staff members shall be made known by NetTwo.ca upon request.

Policy:

• General questions and comments related to PIPEDA , Nettwo.ca’s compliance with the legislation, as well as, that of individual business-related practices should be forwarded to Owner, Ron Jacobs at rjacobs@nettwo.ca.  Concerns related to Nettwo.ca’s  Compliance with the legislation, including the collection, use, retention and destruction of personal information held by Nettwo.ca should be also be forwarded to Nettwo.ca Manager, Ron Jacobs at rjacobs@nettwo.ca

2. IDENTIFYING PURPOSES

The purpose for which personal information is collected, used and disclosed by Nettwo.ca in the course of its commercial activities is as follows:

Policy:

• Personal information collected, used and disclosed by Nettwo.ca in the course of its commercial activities is outlined above.

Procedure:

• A Consent Form, setting out the use of the personal information by Nettwo.ca  in the course of its commercial activities, will be sent providing an opportunity to accept or deny its use. Any individual may subsequently amend his/her consent in writing.

3. CONSENT

The knowledge and consent of the individual is required for the collection, use, disclosure or retention of personal information in the course of Nettwo.ca commercial activities except where inappropriate. The form of the consent sought by Nettwo.ca may vary depending on the circumstances and the type of information and the reasonable expectations of the individual. Given the nature of the personal information it is reasonable to infer that an individual has given implied consent for the collection, use, disclosure or retention of personal information necessary for the identified purposes until the individual has returned the above noted Consent Form to Nettwo.ca An express consent with check off boxes allowing an individual to request that contact information not be given to other organizations which may use it for commercial activities will be included in the Consent Form. Nettwo.ca may collect, use and disclose personal information in the course of its commercial activities without the knowledge or consent of the individual if the collection, use or disclosure is clearly in the interest of the individual and the consent cannot be obtained in a timely manner or if it is reasonable to expect that the collection, use or disclosure with the knowledge or consent of the individual would compromise the availability or the accuracy of the information as more particularly set out in the PIPEDA .

An individual may withdraw his/her consent at any time upon reasonable notice subject to legal or contractual restrictions.

The only commercial entities to whom Nettwo.ca will divulge any personal information gathered in the course of its commercial activities are affiliate associations including but not limited to Better Business Bureau. Requests by such commercial entities will be addressed individually and evaluated by Nettwo.ca manager(s). Nettwo.ca reserves the right to refuse personal player information to any organization who is deemed non-compliant with PIPEDA .

Policy:

• Personal information collected, used, disclosed and retained by Nettwo.ca in the course of its commercial activities is identified in the Consent Form. Nettwo.ca will obtain written consent from all members to collect, use, disclose and retain his/her personal information in the course of its commercial activities.

• Any clients that are on Nettwo.ca will give prior consent in writing.

4. LIMITING COLLECTION

The collection, use and disclosure of personal information in the course of its commercial activities shall be limited to that which is necessary for the purposes identified by Nettwo.ca. Information shall be collected by fair and lawful means.

Policy:

• All personal information collected, used and disclosed by Nettwo.ca in the course of its commercial activities is obtained from individual Consent Forms.

Procedure:

• Collect, use and disclose personal information in the course of its commercial activities from Consent Forms.

5. LIMITING USE, DISCLOSURE AND RETENTION

Policy:

• Personal information collected, used or disclosed by Nettwo.ca in the course of its commercial activities shall not be used or disclosed for purposes other than those for which it was collected except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
• Nettwo may disclose personal information collected in the course of its commercial activities without the knowledge or consent of the individual if the disclosure is to a lawyer who represents Nettwo.ca or for the purposes of collecting a debt owed by the individual to Nettwo.ca or where such is required to comply with a subpoena or an Order of the Court or a person or body with jurisdiction to compel the production of information or where a request has been made by an investigative body and the disclosure is reasonable for purposes related to investigating a breach of an agreement or contravention of the Laws of Canada or a Province or are required by law.

Procedure:

• Only personal information collected from the Consent Form may be provided to those organizations identified on the Consent Form.

6. ACCURACY

Personal information collected, used or disclosed by Nettwo.ca in the course of its commercial activities shall be as accurate, complete and up to date as is necessary for the purpose for which it is to be used.

Policy:

• Nettwo.ca endeavors to maintain accurate and up-to-date records, however, the onus is on the individual to advise Nettwo.ca, in writing, with respect to any change in particulars.

Procedure:

• Changes to all information submitted in Consent Forms will only be accepted in writing.

7. SAFEGUARDS

Policy:

• Personal information collected, used and disclosed by Nettwo.ca in the course of its commercial activities shall be protected by security safeguards appropriate for the sensitivity of the information.

Procedure:

• Nettwo.ca’s database is password protected using standard encryption means.
• Access to the physical storage medium used is limited to those with access to the building in which the Nettwo.ca server is housed; currently two people.

8. OPENNESS

Nettwo.ca shall make readily available to individuals specific information about its policy of practices relating to the management of personal information collected, used and disclosed in the course of its commercial activities. An individual may contact the designated staff member to obtain further information.

Policy:

• An individual may request access to his/her personal information collected, used or disclosed by Nettwo.ca in the course of its commercial activities (Consent Form).

Procedure:

• Written request to the staff member responsible for Nettwo.ca’s compliance with the PIPEDA .

9. INDIVIDUAL ACCESS

Upon request, an individual shall be informed of the existence, use and disclosure of his/her personal information collected, used or disclosed by NetTwo.ca in the course of its commercial activities and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Policy:

• An individual may request access to his/her personal information collected, used or disclosed by Nettwo.ca in the course of its commercial activities (Consent Form).

Procedure:

• Request to access personal information collected, used or disclosed on the Consent Form must be received in writing, including the date and time when he/she would like to view the Consent Form.
• Staff member accountable for Nettwo.ca’s  compliance with the PIPEDA will remove that Consent Form from the binder for review by the individual.
• Changes to information contained on the Consent Form will be made by the individual in writing, signed and dated.

10. CHALLENGING COMPLIANCE

An individual shall be able to address a challenge concerning compliance with the above 9 principles with the designated administrative member accountable for Nettwo.ca’s compliance.

Policy:

• Complaints may be made to Nettwo.ca designated staff member accountable for Nettwo.ca’s compliance with the PIPEDA in addition to the Federal Privacy Commission.

Procedure:

• Complaint must be made in writing and should be addressed to the designated staff member accountable for ensuring Nettwo.ca’s compliance with the PIPEDA .
• The staff member accountable for Nettwo.ca’s compliance with the PIPEDA , in consultation with the Executive Director, will address the matter and issue a response to the individual within 30 days of receipt of the complaint.

To contact the Nettwo.ca  Privacy Officer, please use the following email address: rjacobs@nettwo.ca