Canadian Telecommunications Association
Policy on the Collection, Use and Disclosure of Personal Information
1. Objective & Scope of Policy
The Canadian Telecommunications Association is committed to respecting your privacy and has prepared this Policy Statement to inform you of our policy and practices concerning the collection, use and disclosure of Personal Information.
This Policy Statement governs Personal Information collected from and about individuals who are or may become Members of the Canadian Telecommunications Association and those other individuals outside of the Canadian Telecommunications Association with whom we work with or who may provide Personal Information to the Canadian Telecommunications Association. This policy does not cover business contact information, corporate information or aggregated data from which the identity of an individual cannot be determined. The Canadian Telecommunications Association retains the right to use aggregated data in any way that it determines appropriate.
2. The Collection, Use & Disclosure of Personal Information
For the purposes of this Policy:
“Breach of security safeguards” means the loss of, unauthorized access to or unauthorized disclosure of personal information resulting from a breach of an organization’s security safeguards or from a failure to establish those safeguards.
“Business transaction” includes:
(a) the purchase, sale or other acquisition or disposition of an organization or a part of an organization, or any of its assets;
(b) the merger or amalgamation of two or more organizations;
(c) the making of a loan or provision of other financing to an organization or a part of an organization;
(d) the creating of a charge on, or the taking of a security interest in or a security on, any assets or securities of an organization;
(e) the lease or licensing of any of an organization’s assets; and
(f) any other prescribed arrangement between two or more organizations to conduct a business activity.
“Member” means a corporate entity that seeks to become a member of the Canadian Telecommunications Association or has been accepted for membership in the Canadian Telecommunications Association.
“Personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred or determined from such information but does not include business contact information.
The Canadian Telecommunications Association uses the Personal Information you provided verbally or in writing in order to:
- Process membership applications;
- Process registration to courses and seminars;
- Provide subscriptions to various publications;
- Manage our relationship with Members;
- Process Short Code applications;
- Respond to requests for information;
- Create directories or lists, which are made available to other Members and other reputable organizations associated with the Canadian Telecommunications Association;
- Meet any legal or regulatory requirement; and
- Such other purposes consistent with the foregoing and general purposes of the Association.
The Canadian Telecommunications Association’s use of Personal Information is limited to these purposes. Unless permitted by law, no Personal Personal Information is collected, without first obtaining the consent of the individual to the collection, use and dissemination of that information.
Personal Information is collected, to the extent possible, directly from the individual concerned.
The Canadian Telecommunications Association may disclose your Personal Information to organizations or individuals that perform services on behalf of the Canadian Telecommunications Association. Using contractual or other arrangements, the Canadian Telecommunications Association shall ensure that agents, contractors or third party service providers, who may receive Personal Information in the course of providing services to the Canadian Telecommunications Association, agree to use and hold such information solely for the purposes indicated by the Canadian Telecommunications Association.
In some circumstances, the organization or individual retained by the Canadian Telecommunications Association may be located outside of Canada. Therefore, some Personal Information collected by the Canadian Telecommunications Association may be retained in countries other than Canada where privacy laws may offer different levels of protection from those in Canada and Personal Information may be subject to access by and disclosure to law enforcement agencies in those jurisdictions.
Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where the Canadian Telecommunications Association 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 other governmental tribunal;
- Where the Canadian Telecommunications Association 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 fees;
- Where it is necessary to permit the Canadian Telecommunications Association to pursue available remedies or limit any damages that the Canadian Telecommunications Association may sustain;
- Where the information is public;
- Where the information is contained in a witness statement and its collection, use or disclosure is necessary to assess, process or settle an insurance claim;
- Where it is reasonable for the purposes of investigating a breach of an agreement, or actual or suspected illegal activity; or
- Where it is necessary for the purpose of a prospective business transaction if the information is necessary to determine whether to proceed with the transaction or to complete the transaction, or a completed business transaction where the information is necessary to carry on the business or the activity that was the object of the transaction.
Where obliged or permitted to disclose information without consent, the Canadian Telecommunications Association will not disclose more information than is required.
The Canadian Telecommunications Association endeavours to ensure that any Personal Information provided by its Members and in its possession is as accurate, current and complete as necessary for the purposes for which the Canadian Telecommunications Association uses that data.
The Canadian Telecommunications Association keeps 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 product or service 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 Personal Information is no longer required for the Canadian Telecommunications Association’s purposes, we will destroy, delete, erase or convert it into an anonymous form.
The Canadian Telecommunications Association endeavours to maintain adequate 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.
The Canadian Telecommunications Association further protects Personal Information by restricting access to it to those employees that the management of the Canadian Telecommunications Association has determined need to know that information in order that the Canadian Telecommunications Association may provide its services.
In case of a breach of security safeguards involving Personal Information under the Canadian Telecommunications Association’s control, we will notify the affected individual and the Privacy Commissioner of Canada, if it is reasonable in the circumstances to believe that the breach creates a real risk of significant harm to the individual, including physical, financial or reputational harm. We will also notify any other organization or government institution that can reduce the risk or mitigate the harm from the breach.
6. Visiting the Canadian Telecommunications Association Web Sites
“Persistent” cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided (e.g., passwords), helping to determine what areas of the Web Sites visitors find most valuable, and customizing the Web Sites based on your preferences. The Web Sites use persistent cookies.
The Canadian Telecommunications Association does not share Personal Information obtained through cookies with any third parties.
7. Access to Personal Information
The Canadian Telecommunications Association permits the reasonable right of access and review of Personal Information held by us about an individual.
If an individual believes any Personal Information concerning him or her is not correct, that person may request an update of that information by sending a request to the person indicated in Section 1 of this Policy. The Canadian Telecommunications Association reserves the right not to change any Personal Information but will append any alternative reasonable text the individual concerned believes appropriate. An individual may also request that the Canadian Telecommunications Association delete an individual’s Personal Information from the Canadian Telecommunications Association’s system and records. However, due to technical constraints and the fact that the Canadian Telecommunications Association backs up its systems, Personal Information may continue to reside in the Canadian Telecommunications Association’s systems after deletion. Individuals, therefore, should not expect that their Personal Information would be completely removed from the Canadian Telecommunications Association systems in response to an accepted request for deletion.
The Canadian Telecommunications Association reserves the right to decline access to Personal Information where the information requested:
(a) 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 the Canadian Telecommunications Association or the competitive position of a third party or interfere with contractual or other negotiations of the Canadian Telecommunications Association or a third party;
(b) Is subject to solicitor-client or litigation privilege;
(c) Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information;
(d) Does not exist, is not held, or cannot be found by the Canadian Telecommunications Association;
(e) Could reasonably result in (i) serious harm to the treatment or recovery of the individual concerned, (ii) serious emotional harm to the individual or another individual, or (iii) serious bodily harm to another individual;
(f) 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
(g) Any other grounds 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.
Where information will be disclosed, the Canadian Telecommunications Association will endeavor to provide the information in question within a reasonable time and no later than 30 days following the request.
The Canadian Telecommunications Association will not respond to repetitious or vexatious requests for access. In determining whether a request is repetitious or vexatious, it will consider such factors as the frequency with which information is updated, the purpose for which the information is used, and the nature of the information.
To guard against fraudulent requests for access, the Canadian Telecommunications Association will require sufficient information to allow it to confirm the identity of the person making the request before granting access or making corrections.
8. Resolving Your Privacy Concerns
In the event of questions about: (i) access to your Personal Information; (ii) the Canadian Telecommunications Association’s collection, use, management or disclosure of Personal Information; or (iii) this Policy Statement; please contact the Canadian Telecommunications Association’s Privacy Officer at [email protected].
The Canadian Telecommunications Association will investigate all complaints and if a complaint is justified, we will take all reasonable steps to resolve the issue. If we are unable to resolve your concerns to your satisfaction you may contact the Privacy Commissioner of Canada by writing to:
Office of the Privacy Commissioner of Canada
30 Victoria Street
9. Amendment of Canadian Telecommunications Association Practices and This Policy
This statement is in effect as of January 1, 2004. The Canadian Telecommunications Association will from time to time review and revise its privacy practices and this Policy Statement. In the event of any amendment, an appropriate notice will be communicated to Members and others in an appropriate manner. Policy changes will apply to the information collected from the date of the revised Policy Statement as well as to existing information held by the Canadian Telecommunications Association. This Policy was last revised on October 11, 2018.