Our Commitment to Protecting Your Privacy
At HummingBird Corporate Events, respecting privacy is an important part of our commitment to our clients, our employees, and the general public.
When you participate in programs conducted by our organization, you can be confident that any personal information that you share with us will stay with us.
Any time you participate as a client with our registration forms, whether in person or by telephone, mail, or Internet, you can be assured:
· That your individual responses will be kept confidential.
· That your personal identifying information will never be sold to anyone.
HummingBird Corporate Events maintains strict privacy standards as specified in our Privacy Policy, which are also consistent with the provisions of the Personal Information Protection and Electronic Documents Act (Canada).
HummingBird Corporate Events reviews its Privacy Policy regularly to make sure that it is relevant and remains current with changing industry standards, technologies, and laws.
If you have any concerns about how your privacy is protected at HummingBird Corporate Events, please contact us by e-mail at info@hummingbirdevents.ca.
HummingBird Corporate Events Privacy Policy
Scope and Application
The principles that form the basis of HummingBird Corporate Events’ Privacy Policy are interrelated and HummingBird Corporate Events shall adhere to the principles as a whole. Each principle must be read in conjunction with the accompanying commentary. As permitted by the Personal Information Protection and Electronic Documents Act (Canada), the commentary in HummingBird Corporate Events’ Privacy Policy has been drafted to reflect personal information issues specific to HummingBird Corporate Events.
The scope and application of HummingBird Corporate Events’ Privacy Policy are as follows:
• The Privacy Policy applies to personal information collected, used, or disclosed by HummingBird Corporate Events in the course of commercial activities.
• The Privacy Policy applies to the management of personal information in any form whether oral, electronic, or written.
• The Privacy Policy does not impose any limits on the collection, use, or disclosure of the following information by HummingBird Corporate Events:
• Non-personally identifiable information;
• The name, title, business address and/or telephone number of an employee of an organization;
• Other information about an individual that is publicly available and is specified by regulation pursuant to the Personal Information Protection and Electronic Documents Act (Canada).
• The application of the Privacy Policy is subject to the requirements and provisions of the Personal Information Protection and Electronic Documents Act (Canada), the regulations enacted there under, and any other applicable legislation or regulation.
Definitions
Collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.
Consent: Voluntary agreement for 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 HummingBird Corporate Events. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.
Disclosure: Making personal information available to a third party.
Employee: An employee of or independent contractor to HummingBird Corporate Events.
Personal information: Information about an identifiable individual, but does not include the name, title, business address, or telephone number of an employee of an organization, and does not include descriptive, factual information about an organization.
Client: A member of the public who provides personal information to HummingBird Corporate Events in the course of a registration/program conducted by HummingBird Corporate Events. For example, a client is an individual who discloses personal information to HummingBird Corporate Events in the course of
the program being run by HummingBird Corporate Events that may or may not include registration.
Third-party: An individual or organization outside of HummingBird Corporate Events.
Use: The treatment, handling, and management of personal information by and within HummingBird Corporate Events or by a third party with the knowledge and approval of HummingBird Corporate Events.
Accountability
HummingBird Corporate Events is responsible for personal information under its control and shall designate one or more persons who are accountable for HummingBird Corporate Events’ compliance with the following principles.
Responsibility for compliance with the provisions of HummingBird Corporate Events Privacy Policy rests with HummingBird Corporate Events who can be reached by e-mail at info@hummingbirdevents.ca. Other individuals within HummingBird Corporate Events may be delegated to act on behalf of the Privacy Officer or to take responsibility for the day-to-day collection and/or processing of personal information.
HummingBird Corporate Events is responsible for personal information in its possession or control and shall use contractual or other means to provide a comparable level of protection while information is being processed or used by a third party.
Identifying Purposes for Collection of Personal Information HummingBird Corporate Events shall identify the purposes for which personal information is collected at or before the time the information is collected.
HummingBird Corporate Events collects personal information from the customer only for the purposes of executing the program as requested by the customer.
Upon request, persons collecting personal information shall explain this identified purpose or refer the individual to a designated person within HummingBird Corporate Events who can explain the purpose.
When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is permitted or required by law, the consent of the client will be acquired before the information will be used or disclosed for the new purpose.
HummingBird Corporate Events may provide clients or other third parties with information from any program, in aggregate form. In aggregate form, it is impossible to identify an individual client’s personal information.
Obtaining Consent for Collection, Use or Disclosure of Personal Information The knowledge and consent of an individual are required for the collection, use, or disclosure of personal information, except where inappropriate.
Participation by clients is always voluntary. When a client agrees to participate in a program, he/she gives consent by participating in the registration of the aforementioned program.
Generally, any personal information collected over the course of a program is not disclosed to third parties.
In obtaining consent, HummingBird Corporate Events shall use reasonable efforts to ensure that a client is advised of the identified purposes for which personal information will be used or disclosed. The identified purpose shall be stated in a manner that can be reasonably understood by the client.
Generally, HummingBird Corporate Events shall seek consent to use and disclose personal information at the same time it collects the information. However, HummingBird Corporate Events may seek consent to use and/or disclose personal information after it has been collected, but before it is used and/or disclosed for a new purpose.
In determining the appropriate form of consent, HummingBird Corporate Events shall take into account the sensitivity of the personal information and the reasonable expectations of its clients.
Limiting Collection of Personal Information
HummingBird Corporate Events shall limit the collection of personal information to that which is necessary for the purpose identified by HummingBird Corporate Events. HummingBird Corporate Events shall collect personal information by fair and lawful means.
We collect only the amount and type of information needed for the purpose identified to individuals.
HummingBird Corporate Events will only collect personal information from external sources, such as client organizations if individuals have consented to such collection.
Limiting Use, Disclosure, and Retention of Personal Information HummingBird Corporate Events shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
HummingBird Corporate Events may disclose a client’s personal information to a public authority or agent of a public authority if, in the reasonable judgment of HummingBird Corporate Events, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or to a third party or parties, where the client consents to such disclosure or disclosure is required or permitted by law.
Only HummingBird Corporate Events’ employees with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about clients. HummingBird Corporate Events shall keep personal information only as long as it remains necessary or relevant for the identified purpose or as required by law.
Depending on the circumstances, where a client may have to be re-contacted for purposes of clarifying responses to a registration, or to seek additional responses, HummingBird Corporate Events shall retain the personal information for a period of time that is reasonably sufficient to allow this re-contact.
HummingBird Corporate Events 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.
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.
Personal information used by HummingBird Corporate Events 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 client.
HummingBird Corporate Events shall update personal information about clients and employees as necessary to fulfill the identified purpose or upon notification by the individual.
Security Safeguards
HummingBird Corporate Events shall protect personal information through security safeguards appropriate to the sensitivity of the information.
HummingBird Corporate Events shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held.
HummingBird Corporate Events shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purpose for which it is to be used.
All of HummingBird Corporate Events employees with access to personal information shall be required to respect the confidentiality of that information.
Openness Concerning Policies and Procedures
HummingBird Corporate Events shall make readily available to individuals specific information about its policies and procedures relating to the management of personal information.
HummingBird Corporate Events shall make information about its policies and procedures easy to understand, including:
a) the title and address of the person or persons accountable for HummingBird Corporate Events’ compliance with its Privacy Policy and to whom inquiries and/or complaints can be forwarded;
b) The means of gaining access to personal information held by HummingBird Corporate Events;
c) A description of the type of personal information held by HummingBird Corporate Events, including a general account of its use; and
d) A description of what personal information is made available to related organizations (e.g. subsidiaries).
Individual Access to Personal Information
Upon request, HummingBird Corporate Events shall inform an individual of the existence, use, and disclosure of his or her personal information and shall give the individual access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Upon written request to the Privacy Officer, HummingBird Corporate Events will inform an individual of the existence, use, and disclosure of his/her personal information and shall be given access to that information.
In certain situations, HummingBird Corporate Events may not be able to provide access to all the personal information that it holds about a client. For example, HummingBird Corporate Events 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, HummingBird Corporate Events may not provide access to information if disclosure would reveal confidential commercial information.
In order to safeguard personal information, a client may be required to provide sufficient identification information to permit HummingBird Corporate Events to account for the existence, use and disclosure of personal information and to authorize access to the individual’s file. Any such information shall be used only for this purpose.
HummingBird Corporate Events 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 individual’s file. Where appropriate, HummingBird Corporate Events shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.
Clients and employees can obtain information or seek access to their individual files by contacting us.
Challenging Compliance
An individual shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for HummingBird Corporate Events’ compliance with HummingBird Corporate Events Privacy Policy.
HummingBird Corporate Events shall maintain procedures for addressing and responding to all inquiries or complaints from its clients regarding HummingBird Corporate Events’ handling of personal information.
HummingBird Corporate Events shall, on written request, inform its clients about the existence of these procedures as well as the availability of complaint procedures.
The person or persons accountable for compliance with HummingBird Corporate Events Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.
HummingBird Corporate Events shall investigate all complaints concerning compliance with its Privacy Policy. If a complaint is found to be justified, HummingBird Corporate Events shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. The client shall be informed of the outcome of the investigation regarding his or her complaint.
Additional Information
For more information regarding HummingBird Corporate Events Privacy Policy, please contact us by e-mail info@hummingbirdevents.ca. Please visit the Privacy Commissioner of Canada‘s website at www.privcom.gc.ca.
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