PERSONAL INFORMATION PROTECTION POLICY

Last updated Nov 2017

The Compassion Network Inc. is committed to safeguarding the personal information entrusted to us by our customers. We manage your personal  information  in  accordance  with  Alberta's Personal  Information  Protection  Act  and  other applicable laws. This policy outlines the principles and practices we follow in protecting your personal information. This policy applies to The Compassion Network Inc. and its subsidiaries. The policy also applies to any person providing services on our behalf.

What is personal information?

Personal  information  means  information  about an identifiable individual.  This includes an individual's name, home address and phone number, age, sex, marital or family status, an identifying number, financial information, medical history, etc.

What personal information do we collect?

We collect only the personal information that we need for the purposes of providing services to our 
clients, including personal information needed to:

  • open and manage accounts
  • deliver requested services
  • assess suitability of customer for our services
  • ensure the safety of customers and employees
  • provide warranties for services
  • contact customers about appointments and schedules
  • follow up with customers for feedback of services
  • notify customers of upcoming events of interest
  • administer our loyalty program
  • grant credit and reimbursements
  • meet regulatory requirements
  • research and develop new services
We normally collect customer information directly from our customers. We may collect your information from other persons with your consent or as authorized by law.


We inform our customers, before or at the time of collecting personal information, of the purposes for which we are collecting the information. However, we do not provide this notification when a customer volunteers information for an obvious purpose (for example, producing a credit card for a service charge when the information will only be used to process the payment).

Consent

We ask for consent to collect, use, or disclose customer personal information, except in specific circumstances where collection, use, or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose. 

We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to  provide  consent  to  the  collection,  use,  or  disclosure  of  certain personal  information.  Where  express  consent  is needed, we will normally ask customers to provide their consent orally (in person, by telephone), in writing (by signing a consent form, by checking a box or form), or electronically (by clicking a button).

We  may  collect,  use,  or  disclose  customer  personal  information  without  consent  only  as authorized  by  law.  For example, we may not request consent when the collection, use, or disclosure is reasonable for an investigation or legal proceeding, to collect a debt owed to our organization, in an emergency that threatens life, health or safety, or when the personal information is from a public telephone directory.

How do we use and disclose personal information?

We  use  and  disclose  customer  personal  information  only  for  the  purposes  for  which  the information was  collected, except as authorized by law. For example, we may use customer contact information to deliver goods and services. The law also allows us to use that contact information for the purpose of collecting a debt owed to our organization, should that be necessary. If we wish to use or disclose your personal information for any new business purpose, we will ask for your consent.

How do we safeguard personal information?

We make every reasonable effort to ensure that customer information is accurate and complete.  We rely on our customers to notify us if there is a change to their personal information that may affect their relationship with our organization. If you are aware of an error 
in our information about you, please let us know and we will correct it on request wherever possible. In some cases we may ask for a written request for correction.

We protect customer personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure, or modification of personal information, as well as any unauthorized access to personal information.

We will notify the Office of the Information and Privacy Commissioner of Alberta, without delay, of a security breach affecting personal information if it creates a real risk of significant harm to individuals.

We retain customer personal information only as long as is reasonable to fulfill the purposes for which the information was collected or for legal or business purposes.

We render customer personal information non-identifying, or destroy records containing personal information once the information is no longer needed.

We use appropriate security measures when destroying customer personal information, including shredding  paper records and permanently deleting electronic records.

Access to records containing personal information

Customers of The Compassion Network Inc. have a right to access their own personal information in a record that is in our custody or under  our control, subject to some exceptions.  For example, organizations are required under the Personal Information Protection Act to refuse to 
provide access to information that would reveal personal information about another individual.  

Organizations are authorized under the Act to refuse access to personal information if disclosure would reveal confidential business information. Access may also be refused if the information is privileged or contained in mediation records.

If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record.

You may make a request for access to personal information by writing to the General Manager. You must provide sufficient information in your request to allow us to identify the information you are seeking.

You may also request information about our use of your personal information and any disclosure of that information to persons outside our organization.

You may also request a correction of any error or omission in your personal information.

We will respond to your request within 45 calendar days, unless an extension is granted. We may charge a reasonable fee  to  provide  information, but not to make a correction. We will advise you of any fees that may apply before beginning to process your request.

Questions and complaints

If you have a question or concern about any collection, use, or disclosure of personal information by The Compassion Network Inc., or about a request for access to your own personal information, please contact the General Manager in the first instance:

The Compassion Network Inc.
ATTN: General Manager 
PO Box 67035 
Edmonton, Alberta T5R 5Y3

Or call us at (780) 432-1676
Or email gm@compassionnetwork.ca

If you are not satisfied with the response you receive, you should contact the information and Privacy Commissioner of Alberta:

Office of the Information and Privacy Commissioner of Alberta
Suite 2460, 801 - 6 Avenue SW
Calgary, Alberta T2P 3W2

Phone: (403) 297-2728 | Toll Free: 1-888-878-4044
Email: generalinfo@oipc.ab.ca | Website: www.oipc.ab.ca