Bruce Municipal Telephone System (hereinafter referred to as Bruce Telecom) is covered by the Personal Information Protection And Electronics Documents Act which governs how an individual’s personal information is collected, stored, used and disclosed.
Bruce Telecom must obtain an individual’s consent when collecting, using or disclosing the individual’s personal information.
Individuals have the right to access their personal information held by an organization and to challenge its accuracy, if need be. Personal information can only be used for the purposes for which it was collected. If an organization is going to use it for another purpose, consent must be obtained again.
Personal information includes any of the following:
factual or subjective information, recorded or not, about an identifiable individual including but not limited to:
- ID numbers
- Ethnic origin
- Blood type
- Social status
- Disciplinary actions
- Employee files
- Credit records
- Loan records
- Medical records
- Existence of a dispute between a consumer and a merchant
- Intentions (eg to acquire goods or services or change jobs
Personal information does not include the name, title, business address or telephone number of an employee of an organization.
BRUCE TELECOM RESPONSIBILITIES
Bruce Telecom is responsible for the protection of personal information and the fair handling of it at all times, throughout the organization and in dealings with third parties. Care in collecting, using and disclosing personal information is essential to continued consumer confidence and good will.
Bruce Telecom is required to follow ten (10) principles under the Act:
- Identifying purposes
- Limiting Collection
- Limiting use, disclosure and retention
- Individual access
- Challenging compliance
This manual will set out how Bruce Telecom will comply with the above ten (10) principles.
PRINCIPAL 1 – ACCOUNTABILITY
The designated privacy official for Bruce Telecom is the Human Resources officer, with authority to intervene on privacy issues relating to any of the organizations operations.
Personal Information collected by Bruce Telecom includes, but is not limited to the following:
- Address residential and mailing
- Email Address
- Telephone Number
- Date of Birth
- How Name is to appear on Call Display
- Place of Employment and Position
- Drivers License Number
- Social insurance Number
- Alternative Contact Number
- Spouse or Co-users Name and Place of Employment or Contact
- Rent or Own residence
We collect personal information from customers in order to:
- Identify customer and location for service
- Assist in determining amount of credit to be extended to the customer
- Verification of identity (eg drivers license)
- Alternative method to contact customer if necessary
- Determine if customer has authority to add jacks or lines to the location (rent or own)
- Send customer information on new products/services and/or company surveys
- Provide information to third party supplier in order to have services activated for a customer (eg cellular)
We use the following methods to collect personal information from customers:
- Over the telephone
- Written applications
- Email applications
We use personal information collected for the following purposes. Note that this is not an all inclusive list and may be added to at any time:
- Service Records
- Identification of authorized individuals to make changes to an account
- Security of customer services
- Collection of unpaid accounts
- Company surveys
- Marketing surveys
- Applications for various services such as Internet, Cellular, phone services
Personal Information is kept in the following methods:
Electronically in the billing system in customer accounts or on service orders. In paper format in filing cabinets at the Administration Centre
Personal Information is secured in a variety of ways including:
- Password and employee identification required to access programs
- Secure servers located at the Administration Centre are behind firewalls
- General public is not allowed into areas of the building where paper information is filed
The following have access to customers Personal Information:
- All employees of Bruce Telecom
- Bruce Telecom Agents
- Third parties as required (for example billing purposes)
Personal Information is disclosed only to individuals or companies that Bruce Telecom must provide it to, in order for the customer to have various services. Example : In order to set up cellular service.
Personal Information is kept on file by Bruce Telecom for an undetermined length of time.
When transferring personal information to third parties, Bruce Telecom will:
- Name a person to handle all privacy aspects of the contract.
- Limit use of the personal information for the purposes specified to fulfil the contract.
- Limit disclosure of the information to what is authorized by your organization or required by law.
- Advise third party to refer any people looking for access to their personal information to Bruce Telecom.
- Ensure the return or disposal of the transferred information upon completion of the contract.
- Ensure that the third party uses appropriate security measures to protect the personal information.
- Ensure Bruce Telecom is allowed to audit the third party’s compliance with the contract as necessary.
PRINCIPAL 2 – IDENTIFYING THE PURPOSE
Bruce Telecom must identify the reasons for collecting personal information before or at the time of collection.
When a customer applies for a product or service, Bruce Telecom will make sure the customer is made aware of:
- why Bruce Telecom needs the personal information it is requesting
- how the personal information may be used with customer consent for other purposes
- the fact that the customer can refuse at any time permission for Bruce Telecom to use personal information for these other purposes.
Bruce Telecom will collect and use personal information for only the following purposes:
- to understand the customers needs
- to analyze the suitability of our products or services for the customer
- to determine the customers eligibility for our products and services
- to set up, manage and offer products and services that meet the customers needs
- to provide ongoing service
- to meet legal and regulatory requirements.
Employees must identify, either orally, in writing, in person or electronically why the personal information is being collected and how it will be used and record all the identified purposes and that consent was obtained. All employees will use words that customers can easily understand when explaining why information is being collected and how it will be used.
Bruce Telecom will distinguish the purposes from other information so that customers will be made aware of them. For example, on an application form, Bruce Telecom may identify the purpose(s) using bolder type, or a box, or a separate form or a letter. Over the telephone, Bruce Telecom will identify the purpose(s) as a distinct part of the application.
Bruce Telecom staff who collect personal information will be able to explain the purpose(s) to customers. Customers will also be able to ask for information about the purposes when they phone or write to Bruce Telecom or visit a store or its Administration Centre having possession of the personal information.
Bruce Telecom will take care to explain all the purposes for which personal information is collected by that individual, including any purposes which may not appear to be as obvious as others.
If personal information is to be used for anything other than the specified reasons, the customer must give consent for the new use.
PRINCIPAL 3 – OBTAINING CONSENT
It is the responsibility of Bruce Telecom to inform the individual of the purpose for the collection, use and/or disclosure of personal information. The individuals consent must be obtained before or at the time of collection, or whenever a new use is identified.
Consent must be recorded (eg note to the file, copy of email or copy of a checkoff box). A customers consent can be express, implied, or given through an authorized representative. A customer can withdraw consent at any time, with certain exceptions.
Consent cannot be made a condition of supplying a product or service, unless the information requested is required to fulfill an explicitly specified and legitimate purpose.
A Bruce Telecom employee, may however, collect, use or disclose personal information without the customers knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or as required by law.
Consent cannot be obtained by deceptive means.
PRINCIPAL 4 – LIMITING COLLECTION OF PERSONAL INFORMATION
Bruce Telecom will limit the amount and type of information gathered to what is necessary for the identified purposes.
The kind of personal information collected will be identified in the information-handling policies and practices.
PRINCIPAL 5 – LIMIT USE, DISCLOSURE AND RETENTION OF PERSONAL INFORMATION
Bruce Telecom will only use or disclose personal information for the purpose(s) for which it was collected, unless the customer consents, or the use or disclosure is authorized by the Act.
Bruce Telecom will keep personal information only as long as necessary to satisfy the purposes for which it was collected.
Bruce Telecom will destroy or remove from its system a customers personal information under the following guidelines:
a) Electronic Information
- electronic information (eg billing system information) will be kept while the individual is a customer of Bruce Telecom and may be kept in the system for an indefinite length of time after disconnection
- cellular applications are kept on file indefinitely
- Internet/Cheetah applications are kept indefinitely
- all other records are destroyed on a schedule between four years and seven years
Bruce Telecom will ensure destruction of personal information in a method that prevents improper access.
Customers of Bruce Telecom are expected to provide the following information when it changes:
- customer name
- customer address
Bruce Telecom may disclose personal information without consent when required by law. For example:
- search warrants
- other court and government orders
- demands from other parties who have a legal right to personal information
In these circumstances, Bruce Telecom will protect the interests of its customers by making reasonable efforts to ensure that:
- orders or demands appear to comply with the laws under which they were issued
- it discloses only the personal information that is legally required and nothing more
- it does not comply with casual requests for personal information from government or law enforcement authorities
Bruce Telecom may notify customers that an order has been received, if the law allows it. Notification of such orders may be done by telephone, electronic mail or by letter to the customers last known address.
PRINCIPAL 6 – ACCURACY OF RECORDS
Bruce Telecom will keep personal information as accurate, complete and up to date as necessary, taking into account its use and the interests of the individual.
Bruce Telecom will make reasonable efforts to minimize the possibility of using inaccurate, incomplete or outdated personal information to make a decision about the customer.
Bruce Telecom will update personal information only if it is necessary for the purposes for which it was collected.
Bruce Telecom will rely on customers for keeping certain personal information (such as addresses) accurate, complete and current.
If a customer shows that personal information is inaccurate, incomplete, out of date, or irrelevant, Bruce Telecom will revise the personal information. If necessary Bruce Telecom will disclose the revised personal information to third parties which were provided with the wrong information, to revise their records.
If Bruce Telecom does not agree to revise personal information as requested by the customer, the customer may challenge Bruce Telecom decision. Bruce Telecom will make a record of this challenge, and if necessary, disclose the challenge to the third parties who also possess the personal information, and advise the customer of the relevant complaint procedures.
PRINCIPAL 7- USE OF APPROPRIATE SAFEGUARDS
It is the responsibility of Bruce Telecom to protect customers personal information against loss, theft, unauthorized access, disclosure, copying, use or modification, regardless of the format in which it is held.
These safeguards vary depending on the sensitivity, amount, distribution, format and storage of the personal information.
Controls in place to maintain security of Bruce Telecom operations, computer and information systems include:
- physical security such as locks on filing cabinets and restricted access to offices
- electronic security such as passwords, PIN numbers and encryption
- controlled access to areas where information is kept.
These controls are reviewed on an ongoing basis to ensure compliance with our security and compliance policies.
Bruce Telecom informs its staff regularly about its policies and procedures for protecting customers personal information and emphasizes the importance of complying with them. As a condition of employment, employees are required to conform to Bruce Telecom policies and procedures.
Bruce Telecom uses care when disposing of or destroying personal information, to prevent unauthorized access to the information.
PRINCIPAL 8 – ACCESS TO OUR POLICIES AND PRIVACY OFFICER
Bruce Telecom will provide information about its privacy policies and practices to customers in person, in writing, by telephone, in publications and on our website. The information will be made available in a manner that is generally easy to understand.
Bruce Telecom makes available to customers information about the policies and procedures it uses to manage personal information. It also makes available copies of this code.
Information about Bruce Telecom policies and procedures and code has been written so that it is generally easy to understand and it is readily available to customers. Through brochures or other documents, customers will be able to find out:
- title and office address of the representative of Bruce Telecom who is responsible for protecting the privacy of customerspersonal information, so customers know where to address complaints and questions
- how to access personal information held by Bruce Telecom
- what type of personal information is held by Bruce Telecom and for what purpose it is used.
The Privacy Officer for Bruce Telecom is the management team member responsible for Human Resources.
The Privacy Officer can be reached at:
The Privacy Officer
Box 80, R. R. # 3
or emailed at: Click to e-mail
Customers may access their information by completing a Request for Personal Information form and submitting the same to the Privacy Officer at Bruce Telecom. Requests must be in writing with appropriate identification provided.
Customers wishing to complain to Bruce Telecom may submit their complaints in writing to the Privacy Officer at the following address:
The Privacy Officer
Box 80, R. R. # 3
or emailed at: Click to e-mail
The following information may be made available to other organizations to facilitate the provision of various services:
- phone number
- personal identification code
PRINCIPAL 9 – ACCESSING AND AMENDING PERSONAL INFORMATION
When customers make a request in writing, Bruce Telecom will, within a reasonable amount of time, advise them as to what personal information Bruce Telecom has, what it is being used for, and to whom it has been disclosed.
The customer has a right to know, by written request, what personal information is held by Bruce Telecom and, by written request, to access that personal information and to know which third parties the information has been disclosed to.
Bruce Telecom has policies and procedures for responding to customers requests for access to personal information. When customers ask, Bruce Telecom will make these policies and procedures known to the customers. To respond to a customers request, certain information may be required, for example, customers have to be specific about the type of personal information that may be held by Bruce Telecom.
Bruce Telecom will attempt to be as specific as possible about the person(s) from whom it collected the personal information, to whom it has disclosed the personal information, and how and when the information was disclosed. Bruce Telecom will take this information from its records and will provide it to the customer in a form that is generally easy to understand, providing explanations for abbreviations and codes. Bruce Telecom will provide the personal information to the customer within a reasonable time, and for a cost commensurate with the effort to retrieve the information, or at no cost.
Bruce Telecom will not charge the customer without first informing the customer of the cost of providing the personal information and giving the customer the option to withdraw the request.
On request, Bruce Telecom will give a customer, who has a sensory disability, access to personal information to which the customer is entitled, in an alternative format if a version of the information already exists in the alternative format, or if conversion into that format is reasonable and necessary in order for the customer to access the personal information.
Customers may access their information by completing a Request for Personal Information form and submitting the same to the Privacy Officer at Bruce Telecom. Requests must be in writing with appropriate identification provided and forwarded to:
The Privacy Officer
Box 80, R. R. # 3
Bruce Telecom has implemented policies and procedures for responding to customersrequests for access to personal information. These policies and procedures will be communicated to customers requesting access to personal information.
Bruce Telecom will not provide the personal information that it is in its control if:
a) in doing so it would reveal personal information about a third party and such personal information is not severable from the requesting individuals personal information;
b) it is subject to solicitor-client or litigation privileges;
c) it contains Bruce Telecom own confidential commercial information and such confidential commercial information is not severable from the requesting individuals personal information for example a collection recommendation that is confidential to Bruce Telecom;
d) it would reveal information that would reasonably be expected to threaten the life or security of another individual and such information is not severable from the requesting individuals personal information;
e) it is information that was generated in the course of a formal dispute resolution process;
f) it cannot be disclosed for legal reasons. Bruce Telecom may not legally be able to provide the customer with information relating to disclosures to lawful authorities for law enforcement or crime prevention purposes.
g) it is used for the detection and prevention of criminal activity and dealings in proceeds of crime.
Bruce Telecom will not record in customers individual files when personal information was disclosed to third parties for routine purposes. For example:
i) regular updating of credit information to credit bureaus;
ii) indicating to third parties when cheques are returned for NSF (not sufficient funds);
iii) preparation and mailing of customer statements.
If Bruce Telecom denies the customers request for access to personal information, the Bruce Telecom representative will advise the customer why, except where prohibited by law.
The customer may challenge the Bruce Telecom decision. See Principle 10.
The customer may challenge the reasonableness of the cost of providing personal information.
To assist us in keeping your personal information up-to-date customers are encouraged to amend inaccuracies and make corrections as often as necessary. Should you identify any incorrect or out-of-date information in your file, we will make the proper changes and provide you with a copy of the corrected information. Where appropriate, we will communicate these changes to other parties who may have unintentionally incorrect information from Bruce Telecom.
To make a change to the personal contact information contained in your file call us at 368-2000 or 1-866-517-2000, or visit one of our three locations in Tiverton, Kincardine and Port Elgin or email changes to Click to e-mail
PRINCIPAL 10 – HANDLING COMPLAINTS AND QUESTIONS
Customers may challenge Bruce Telecom compliance with this Code. Bruce Telecom has policies and procedures to receive, investigate and respond to customers complaints and questions relating to privacy. Bruce Telecom will inform customers of these policies and procedures, which are generally easy to understand and use. The complaint resolution process and the person whom customers should contact are part of these policies and procedures.
Bruce Telecom will investigate all complaints and if it finds a complaint justified will try to resolve it. If necessary Bruce Telecom will take appropriate measures, including changing its policies or procedures to ensure that other customers will not experience the same problem.
If a customer is not satisfied with the way Bruce Telecom has responded to a complaint concerning their personal information, there are a variety of resources available for pursuing the customers concerns. A list of resources, pertinent to Bruce Telecom or the product or service about which the customer has a complaint, can be obtained from any Bruce Telecom facility.
If a customer is not satisfied that Bruce Telecom is operating in compliance with the requirements of this code, the customer may file a written complaint with the Commissioner at the following address:
Federal Privacy Commissioner
112 Kent St.
Toll Free: 1-800-282-1376