Our privacy policy includes provisions
of Applicable Law including parts of the
Personal Information Protection Act (BC)
and the Personal Information Protection
and Electronic Documents Act (Canada).
SUMMARY OF PRINCIPLES
1.
Accountability
Intersoft
Technologies Ltd. is responsible for personal
information under its control and shall
designate one or more persons who are responsible
for Intersoft Technologies Ltd.’ compliance
with the principles contained in this privacy
policy and for compliance with Applicable
Law.
2. Identifying Purposes for the
Collection of Personal Information
When required by Applicable Law, Intersoft
Technologies Ltd. shall identify the purposes
for which personal information is collected
at or before the time that the information
is collected.
3. Consent for the Collection, Use
or Disclosure of Personal Information
When required by Applicable Law, the knowledge
and consent of a Protected Individual are
required for the collection, use or disclosure
of personal information.
4. Limiting the Collection of Personal
Information
When required by Applicable Law, Intersoft
Technologies Ltd. shall limit the collection
of personal information to that which is
necessary for the purposes identified by
Intersoft Technologies Ltd. . Intersoft
Technologies Ltd. shall collect personal
information by fair and lawful means.
5. Limiting the Use, Disclosure
and Retention of Personal Information
Intersoft Technologies Ltd. shall not use
or disclose personal information for purposes
other than those for which it was collected,
except with the consent of the Protected
Individual or in accordance with Applicable
Law. As required by Applicable Law, Intersoft
Technologies Ltd. shall retain personal
information only as long as necessary for
the fulfillment of those purposes.
6. Accuracy of Personal Information
Personal information shall be as accurate,
complete, and up-to-date as is necessary
for the purposes for which it is to be used.
7. Security Safeguards
As required by Applicable Law, Intersoft
Technologies Ltd. shall protect personal
information by security safeguards appropriate
to the sensitivity of the information.
8. Openness Concerning Policies
+ Practices
Intersoft Technologies Ltd. shall make readily
available to Protected Individuals specific
information about its policies and practices
relating to the management of personal information.
9. Customer and Employee Access
to Personal Information
As required by Applicable Law, Intersoft
Technologies Ltd. shall inform a Protected
Individual of the existence, use, and disclosure
of his or her personal information upon
request and shall give the individual access
to that information. A Protected Individual
shall be able to challenge the accuracy
and completeness of the information and
have it amended as appropriate.
10. Challenging Compliance
A Protected Individual shall be able to
address a challenge concerning compliance
with the above principles or with Applicable
Law to the designated person or persons
accountable for Intersoft Technologies Ltd.
's compliance with this privacy policy.
WHO AND WHAT OUR PRIVACY POLICY
APPLIES TO
This
privacy policy applies to personal information
about Protected Individuals that is collected,
used or disclosed by Intersoft Technologies
Ltd. and which is covered by Applicable
Law.
This privacy policy does not apply to the
following types of information:
-
an employee's or customer's name, title,
business address (including business e-mail
address) or business telephone number
or business fax number;
-
other information that is not personal
information protected by Applicable Law;
or
- other
information about the customer or employee
that is publicly available or which is
specified by regulation under Applicable
Law.
DEFINITIONS
“Applicable Law”: any law (including
statutes and regulations) that applies to
Intersoft Technologies Ltd.. In respect
of privacy issues, Applicable Law may include,
but is not necessarily limited to, the Personal
Information Protection Act (BC) or the Personal
Information Protection and Electronic Documents
Act (Canada) depending upon the circumstances.
“collection”: the act of gathering,
acquiring, recording or obtaining personal
information from any source, including third
parties, by any means.
“consent”: voluntary agreement
with the collection, use and disclosure
of personal information for defined purposes.
Consent can be either express or implied
and can be provided directly by the individual
or by an authorized representative. Express
consent can be given orally, electronically
or in writing, but is always unequivocal
and does not require any inference on the
part of Intersoft Technologies Ltd. . Implied
consent is consent that can reasonably be
inferred from an individual's action or
inaction.
“customer”: an individual (in
their capacity as an individual either personally,
or through a business carried on as a sole
proprietorship or partnership) who uses,
or applies to use, Intersoft Technologies
Ltd.' products or services and the term
‘customer’ shall include a potential
or prospective customer who has provided
personal information to Intersoft Technologies
Ltd..
“disclosure”: making personal
information available to a third party.
“employee”: an employee of Intersoft
Technologies Ltd. .
“personal information”: personal
information as defined by Applicable Law
about a Protected Individual, but does not
include aggregated information that cannot
be associated with a specific individual.
For a customer, such information includes
a customer's credit information, billing
records, service, and any recorded complaints.
For an employee, such information includes
information found in personal employment
files, performance appraisals, and medical
and benefits information, but does not include
the employee's name, title, business address
(including e-mail address) or business telephone
or fax numbers.
“Protected Individual”: means
an individual whose personal information
is protected by Applicable Law. Those persons
who are included in the definition of Protected
Individual will vary depending upon which
Applicable Law applies to Intersoft Technologies
Ltd. in the circumstances. Generally, the
definitions will be the following.
Where
the Applicable Law is the Personal Information
Protection and Electronic Documents Act
(Canada), "Protected Individual"
will generally include:
- an
individual who is a customer of Intersoft
Technologies Ltd.; and
- an
individual whose personal information
is collected, used or disclosed by Intersoft
Technologies Ltd. in the course of commercial
activity.
Where
the Applicable Law is the Personal Information
Protection Act (British Columbia), "Protected
Individual" will generally include:
- an
individual who is a customer of Intersoft
Technologies Ltd.; and
- an
individual whose personal information
is collected, used or disclosed by Intersoft
Technologies Ltd.; and
- an
employee of Intersoft Technologies Ltd..
“third party”: an individual
or organization outside Intersoft Technologies
Ltd. .
“use”: the treatment, handling
and management of personal information by
and within Intersoft Technologies Ltd..
OUR DETAILED PRIVACY POLICY
The following sections provide more detail
on the summary of principles outlined above.
1. Accountability
1.1 The management of Intersoft Technologies
Ltd. is responsible for ensuring compliance
with this privacy policy and with Applicable
Law. Intersoft Technologies Ltd. shall designate
one or more persons to be accountable for
compliance with this policy and with Applicable
Law. Other individuals may be delegated
to act on behalf of the designated person(s)
or to take responsibility for the day-to-day
collection and processing of personal information.
1.2
Intersoft Technologies Ltd. shall make known,
upon request, the name of the person or
persons who have been designated to take
responsibility for compliance with this
policy and with Applicable Law.
1.3
Intersoft Technologies Ltd. is responsible
for personal information in its possession
or control. Intersoft Technologies Ltd.
shall use appropriate means to provide a
comparable level of protection while information
is being processed by a third party.
1.4
Intersoft Technologies Ltd. shall implement
policies and procedures to give effect to
this privacy policy.
2.
Identifying Purposes for the Collection
of Personal Information
2.1 Intersoft Technologies Ltd. collects
personal information only for the following
purposes ("identified purposes"):
-
to establish and maintain responsible
commercial relations with customers and
to provide ongoing service;
- to
understand customer needs and preferences
and to provide customers with information
related to those needs and preferences;
- to
develop, enhance, market or provide products
and services to customers including contacting
customers for these purposes using any
contact information that was provided
to Intersoft Technologies Ltd.;
- to
manage and develop Intersoft Technologies
Ltd.' business and operations, including
personnel and employment matters; and
- to
meet legal and regulatory requirements.
2.2
When required by Applicable Law, Intersoft
Technologies Ltd. shall specify orally,
electronically or in writing the identified
purposes to the Protected Individual at
or before the time personal information
is collected. Upon request, persons collecting
personal information shall explain these
identified purposes or refer the Protected
Individual to a designated person who shall
explain the purposes.
2.3
Unless permitted by Applicable Law or required
by other laws, Intersoft Technologies Ltd.
shall not use or disclose for any new purpose
personal information that has been collected
without first identifying and documenting
the new purpose and obtaining the consent
of the Protected Individual.
3. Consent for the Collection, Use
or Disclosure of Personal Information
3.1 In obtaining consent and when required
by Applicable Law, Intersoft Technologies
Ltd. shall use reasonable efforts to ensure
that a Protected Individual is advised of
the identified purposes for which personal
information will be used or disclosed. Purposes
shall be stated in a manner that can be
reasonably understood by the Protected Individual.
3.2
Generally, and when required by Applicable
Law, Intersoft Technologies Ltd. shall seek
consent to use and disclose personal information
at the same time it collects the information.
However, the Intersoft Technologies Ltd.
may seek consent to use and disclose personal
information after it has been collected,
but before it is used or disclosed for a
new purpose.
3.3
Intersoft Technologies Ltd. will require
customers to consent to the collection,
use or disclosure of personal information
as a condition of the supply of a product
or service only if such collection, use
of disclosure is required to fulfill the
identified purposes.
3.4
In determining, the appropriate form of
consent, Intersoft Technologies Ltd. shall
take into account the sensitivity of the
personal information and the reasonable
expectations of Protected Individuals.
3.5
In general, the use of products and services
or the acceptance of employment or benefits
by a Protected Individual, constitutes implied
consent for Intersoft Technologies Ltd.
to collect, use and disclose personal information
for all identified purposes.
3.6
A Protected Individual may withdraw consent
at any time, subject to legal or contractual
restrictions and reasonable notice. Depending
upon the circumstances, the withdrawal of
consent may affect Intersoft Technologies
Ltd.' ability to provide products, services
or employment to the Protected Individual
. Protected Individuals should contact Intersoft
Technologies Ltd. for more information regarding
the implications of withdrawing consent.
4. Limiting Collection of Personal
Information
4.1 Intersoft Technologies Ltd. collects
personal information primarily from its
customers and employees but may collect
personal information in appropriate circumstances
from other Protected Individuals.
4.2
Intersoft Technologies Ltd. may also collect
personal information from other sources
including credit bureaus, employers or personal
references, or other third parties who represent
that they have the right to disclose the
information.
5. Limiting Use, Disclosure, and
Retention of Personal Information
5.1 Where Protected Individuals include
customers, Intersoft Technologies Ltd. may
disclose a customer's personal information
to:
- a
person who in the reasonable judgment
of Intersoft Technologies Ltd. is seeking
the information as an agent of the customer;
- another
company involved in supplying the customer
with services related to the services
provided by Intersoft Technologies Ltd.
(including the developers of real estate
projects for which Intersoft Technologies
Ltd. is providing marketing services);
- a
company or individual employed by Intersoft
Technologies Ltd. to perform functions
on its behalf, such as research or data
processing;
- another
company or individual for the development,
enhancement, marketing or provision of
any of Intersoft Technologies Ltd.' products
or services;
- an
agent used by Intersoft Technologies Ltd.
to evaluate the customer's creditworthiness
or to collect the customer's account;
- a
credit reporting agency;
- a
public authority or agent of a public
authority, if in the reasonable judgment
of Intersoft Technologies Ltd., it appears
that there is imminent danger to life
or property which could be avoided or
minimized by disclosure of the information;
and
- a
third party or parties, where the customer
consents to such disclosure, or where
disclosure is permitted by Applicable
Law, or where disclosure is required by
other laws.
5.2
Where Protected Individuals include employees,
Intersoft Technologies Ltd. may disclose
personal information about its employees:
- for
normal personnel and benefits administration;
- in
the context of providing references regarding
current or former employees in response
to requests from prospective employers;
or
- where
the employee consents to such disclosure
or where disclosure is permitted by Applicable
Law, or where disclosure is required by
other laws.
5.3
Only Intersoft Technologies Ltd.' employees
with a business need to know, or whose duties
reasonably so require, are granted access
to personal information about Protected
Individuals.
5.4
Intersoft Technologies Ltd. shall keep personal
information only as long as it remains necessary
or relevant for the identified purposes
or as required by law. Depending on the
circumstances, where personal information
has been used to make a decision about a
Protected Individual, Intersoft Technologies
Ltd. shall retain, for a period of time
that is reasonably sufficient to allow access
by the Protected Individual, either the
actual information or the rationale for
making the decision.
5.5
Intersoft Technologies Ltd. shall maintain
reasonable and systematic controls, schedules
and practices for information and records
retention and destruction which apply to
personal information that is no longer necessary
or relevant for the identified purposes
or required by law to be retained. Such
information shall be destroyed, erased or
made anonymous.
6. Accuracy of Personal Information
6.1. Personal information used by Intersoft
Technologies Ltd. shall be sufficiently
accurate, complete and up-to-date to minimize
the possibility that inappropriate information
may be used to make a decision about a Protected
Individual.
6.2
Intersoft Technologies Ltd. shall update
personal information about Protected Individuals
as and when necessary to fulfill the identified
purposes or upon notification by the Protected
Individual.
7. Security Safeguards
7.1 Intersoft Technologies Ltd. shall protect
personal information against such risks
as loss or theft, unauthorized access, disclosure,
copying, use, modification or destruction,
through appropriate security measures. Intersoft
Technologies Ltd. shall protect the information
regardless of the format in which it is
held.
7.2
Intersoft Technologies Ltd. shall protect
personal information disclosed to third
parties by contractual agreements stipulating
the confidentiality of the information and
the purposes for which it is to be used.
7.3
All of Intersoft Technologies Ltd.' employees
with access to personal information shall
be required to respect the confidentiality
of that information.
8. Openness Concerning Policies
and Practices
8.1 Intersoft Technologies Ltd. shall make
information about its policies and practices
easy to understand, including:
* the title and address of the person or
persons accountable for Intersoft Technologies
Ltd.' compliance with Intersoft Technologies
Ltd.' privacy policy and to whom inquiries
or complaints can be forwarded;
* the means of gaining access to personal
information held by Intersoft Technologies
Ltd.; and
* a description of the type of personal
information held by Intersoft Technologies
Ltd., including a general account of its
use.
9. Customer and Employee Access
to Personal Information
9.1 Upon request and as required by Applicable
Law, Intersoft Technologies Ltd. shall allow
Protected Individuals a reasonable opportunity
to review the personal information held
by Intersoft Technologies Ltd.. Personal
information shall be provided within a reasonable
time, and, if there is a charge for providing
the information, the charge shall be a reasonable
charge permitted by Applicable Law.
9.2
In certain situations, Intersoft Technologies
Ltd. may not be able to provide access to
all the personal information that it holds
about a Protected Individual. For example,
Intersoft Technologies Ltd. may not provide
access to information if doing so would
likely reveal personal information about
a third party or could reasonably be expected
to threaten the life or security of another
individual. Also, Intersoft Technologies
Ltd. may not provide access to information
if disclosure would reveal confidential
commercial information, if the information
is protected by solicitor-client privilege,
if the information was generated in the
course of a formal dispute resolution process,
or if the information was collected in relation
to the investigation of a breach of an agreement
or a contravention of a federal or provincial
law. If access to personal information cannot
be provided, Intersoft Technologies Ltd.
shall provide the reasons for denying access
upon request.
9.3
Upon request, Intersoft Technologies Ltd.
shall provide an account of the use and
disclosure of personal information and,
where reasonably possible, shall state the
source of the information. In providing
an account of disclosure, Intersoft Technologies
Ltd. shall provide a list of organizations
to which it may have disclosed personal
information about the Protected Individual
when it is not possible to provide an actual
list.
9.4
In order to safeguard personal information,
a Protected Individual may be required to
provide sufficient identification information
to permit Intersoft Technologies Ltd. to
account for the existence, use and disclosure
of personal information and to authorize
access to the Protected Individual's information.
Any such information shall be used only
for this purpose.
9.5
Intersoft Technologies Ltd. shall promptly
correct or complete any personal information
found to be inaccurate or incomplete. Any
unresolved differences as to accuracy or
completeness shall be noted in the Protected
Individual's file. Where appropriate, Intersoft
Technologies Ltd. shall transmit to third
parties having access to the personal information
in question any amended information or the
existence of any unresolved differences.
9.6
Protected Individuals can seek access to
their personal information by contacting
our Privacy Officer whose contact information
is listed below.
10. Challenging Compliance
10.1 Intersoft Technologies Ltd. shall maintain
procedures for addressing and responding
to all inquiries or complaints from Protected
Individuals about the handling of personal
information.
10.2
Intersoft Technologies Ltd. shall inform
Protected Individuals about the existence
of these procedures as well as the availability
of complaint procedures.
10.3
The person or persons accountable for compliance
with Intersoft Technologies Ltd.' privacy
policy may seek external advice where appropriate
before providing a final response to individual
complaints.
10.4
Intersoft Technologies Ltd. shall investigate
all complaints concerning compliance with
Intersoft Technologies Ltd. 's privacy policy.
If a complaint is found to be justified,
Intersoft Technologies Ltd. shall take appropriate
measures to resolve the complaint including,
if necessary, amending its policies and
procedures. A Protected Individual shall
be informed of the outcome of the investigation
regarding his or her complaint.
10.5
A Protected Individual may seek advice from
the Office of the Privacy Commissioner (British
Columbia) at 1 250 387 5629 and, if appropriate,
file a written complaint with that office.
However, the Protected Individual is encouraged
to use Intersoft Technologies Ltd.' internal
information and complaint procedures first.
11. Additional Provisions
Our privacy policy is based on the ten principles
of the Canadian Standards Association (CSA)
Model Code for the protection of personal
information which was published in 1996
as a National Standard of Canada.
If
you have questions about our privacy policy,
please submit them to our Privacy Officer
whose contact information is as follows:
Ken
Hopkins, Privacy Officer
Telephone: 604.801.7007
Email: privacy@intersoft.ca
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