CANADIAN CONSUMER SPECIALTY PRODUCTS ASSOCIATION
POLICY CONCERNING THE PROTECTION OF PERSONAL INFORMATION
The Canadian Consumer Specialty Products Association (“CCSPA”) is a national trade association representing the consumer, industrial and institutional specialty products industry. CCSPA may collect Personal Information in the course of its activities and has prepared this policy to inform you about our ongoing commitment to ensuring that the Personal Information obtained remains accurate and confidential.
What is Personal Information?
We consider “Personal Information” to mean any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information, other than business contact information (e.g. name, title, business address). This Policy does not cover business contact information or aggregated data from which the identity of an individual cannot be determined. CCSPA retains the right to use business contact information and aggregated data in any way that it determines appropriate.
Why CCSPA May Collect Personal Information
CCSPA may use the Personal Information you provide verbally or in writing (including via electronic media) in order to:
- Establish a commercial relationship with you;
- Provide you with our products and services;
- Provide you with ongoing customer service;
- Provide you with information about our products and services (including by means of direct marketing);
- Process payments for products and services;
- For ongoing administration of memberships;
- Meet legal and regulatory requirements; and
- Such other purposes consistent with these purposes.
The personal information we ask for will depend upon which products or services you may obtain.
How CCSPA Collects and Uses Personal Information
CCSPA only collects, uses and discloses Personal Information for purposes that would be considered reasonable in the circumstances and only such information as is required for the purposes of providing products or services to our clients. We use only fair and lawful methods to collect Personal Information.
Our use of Personal Information is limited to the purposes described in this Policy and CCSPA does not otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information it has obtained.
When CCSPA May Disclose Your Personal Information
CCSPA may disclose your Personal Information to:
- Individuals or organizations who are our advisers or service providers; and
- Individuals or organizations who are, or may be, involved in maintaining, reviewing and developing our business systems, procedures and infrastructure including testing or upgrading our computer systems
In the event sensitive Personal Information is provided to CCSPA, we will not disclose such Personal Information unless it is required in order to provide you with our products or services.
Where CCSPA discloses Personal Information to organizations that perform services on its behalf, we will require those service providers to use such information solely for the purposes of providing services to CCSPA, our clients or the person concerned and to have appropriate safeguards for the protection of that Personal Information.
CCSPA may disclose personal information to a service provider which is located in the United States where privacy laws may offer different levels of protection from those in Canada. Your personal information may also be subject to access by and disclosure to law enforcement agencies under American legislation such as the USA Patriot Act.
Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where CCSPA is obliged to disclose information without consent. Such circumstances may include:
- Where required by law or by order or requirement of a court, administrative agency or governmental tribunal;
- Where CCSPA believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
- Where it is necessary to establish or collect monies owing to CCSPA;
- Where it is necessary to permit CCSPA to pursue available remedies or limit any damages that we may sustain; or
- Where the information is public.
Where obliged or permitted to disclose information without consent, CCSPA will not disclose more information than is required.
Unless permitted by law, no Personal Information is collected, without first obtaining the consent of the individual concerned to the collection, use and dissemination of that information. However, we may seek consent to use and disclose Personal Information after it has been collected in those cases where we wish to use the information for a new or different purpose where the individual concerned has not already consented to such a use of their personal information.
By providing Personal Information to CCSPA you agree and consent that we may collect, use and disclose your Personal Information in accordance with this Policy. In addition, where appropriate, specific authorizations or consents may be obtained from time to time.
In most cases and subject to legal and contractual restrictions, you are free to refuse or withdraw your consent at any time upon reasonable, advance notice. It should be noted that in certain circumstances, products or services can only be offered if you provide Personal Information to CCSPA. Consequently, if you choose not provide us with any required Personal Information, we may not be able to offer you the products or services requested. We will inform you of the consequences of the withdrawal of consent.
The Accuracy And Retention Of Personal Information
CCSPA endeavors to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary for the purposes for which we use that information. If we become aware that Personal Information is inaccurate, incomplete or out of date, CCSPA will revise the Personal Information and, if necessary, use its best efforts to inform third parties which were provided with inaccurate information so that those third parties may also correct their records.
We keep your Personal Information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the purpose for which it was collected and the nature of the information. This period may extend beyond the end of your relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date.
When your Personal Information is no longer required for CCSPA’s purposes, we have procedures to destroy, delete, erase or convert it into an anonymous form.
Protection of Personal Information
CCSPA endeavours to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This also applies to our disposal or destruction of Personal Information.
CCSPA further protects Personal Information by restricting access to it to those employees that the management of CCSPA has determined need to know that information in order that we may provide our products.
If any employee of CCSPA misuses Personal Information, this will be considered as a serious offence for which disciplinary action may be taken, up to and including termination of employment. If any individual or organization misuses Personal Information – provided for the purpose of providing services to or for CCSPA – this will be considered a serious issue for which action may be taken, up to and including termination of any agreement between CCSPA and that individual or organization.
Access To Your Personal Information
CCSPA permits the reasonable right of access and review of Personal Information held by us about an individual and will endeavour to provide the information in question within a reasonable time, generally no later than 30 days following the request. To guard against fraudulent requests for access, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or making corrections.
We will provide information from our records in a form that is easy to understand. CCSPA reserves the right not to change any Personal Information but will append any alternative text the individual concerned believes to be appropriate.
CCSPA reserves the right to decline to provide access to Personal Information where the information requested:
- Would disclose (i) Personal Information, including opinions, about another individual or about a deceased individual; or (ii) trade secrets or other business confidential information that may harm CCSPA or the competitive position of a third party;
- Would interfere with contractual or other negotiations of CCSPA or a third party;
- Is subject to solicitor-client, litigation or other legal privilege;
- Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information;
- Does not exist, is not held, or cannot be found by CCSPA;
- May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by law to perform such functions; or
- May be withheld or is requested to be withheld under applicable legislation.
Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.
CCSPA will not charge you for verifying or correcting your information, however, to the extent permitted by applicable law, there may be a minimal charge imposed if you need a copy of records.
Resolving Your Privacy Concerns
In the event of questions about: (i) access to your Personal Information; (ii) our collection, use, management or disclosure of Personal Information; or (iii) this Policy; please contact CCSPA’s Privacy Officer, Nancy Hitchins, by sending an email or by calling 613-232-6616, ext. 12.
CCSPA will investigate all complaints and if a complaint is justified, we will take all reasonable steps to resolve the issue.