Pomer and Boccia Professional Corporation Limited
Privacy Policy Personal Information Protection and Electronic Documents Act
The staff and management of Pomer and Boccia Professional
Corporation are committed to respecting the personal privacy of individuals we deal with.
Pomer and Boccia Professional Corporation will comply with (i) Personal Information
Protection and Electronic Document Act (PIPEDA), a federally enacted act which protects
personal information that is collected, used or disclosed; (ii) Collection Agencies Act,
which dictates how we are to perform our services, collection and use of personal
information and any future provincial legislation as it relates to the rights of
consumers. For the purposes of this policy, personal information means information about
an identifiable individual, but does not include the name, title, or business address or
telephone number of an employee of an organization. Any reference to a Consumer within
this policy is in reference to personal information and not business information.
The Canadian Standards Association Mode Code (“code”) for the protection of
personal information is a national standard that was developed by the Canadian Standards
Association. The Code is the central part of PIPEDA. The Code’s ten privacy
principles are identified in PIPEDA as follows:
- Accountability
- Identifying Purpose
- Consent
- Limiting Collection
- Limiting Use, Disclosure & Retention
- Accuracy
- Safeguards
- Openness
- Individual Access
- Challenging Compliance
Pomer and Boccia Professional Corporation has implemented
policies and procedures to give effect to the principles including:
- Implementing procedures to protect information.
- Establishing procedures to receive and respond to
complaints and inquiries in connection with the collection, use and disclosure of personal
information of Pomer and Boccia Professional Corporation.
- Training staff and communicating information to Pomer and
Boccia Professional Corporation staff about our policies and procedures.
- Developing information to explain the policies of and
procedures of Pomer and Boccia Professional Corporation Consumers.
The ten (10) principles are explained in more detail as
follows:
Accountability
Pomer and Boccia Professional Corporation is responsible for the personal
information under its control and has designated two (2) Privacy Officers to be
accountable for Pomer and Boccia Professional Corporation compliance with PIPEDA.
Identifying Purpose
Pomer and Boccia Professional Corporation will identify and document the purpose
for which it collects personal information. Only personal information is necessary for
those identified purpose will be collected.
Pomer and Boccia Professional Corporation shall only collect, use and disclose personal
information about Consumers for the following purpose: a) To sell Consumer lists to other
entities.
Consent
The knowledge and consent of Consumers is required for the collection, use or
disclosure of personal information, except when inappropriate, including where permitted
or required by law.
In certain circumstances, personal information can be collected, used or disclosed without
the knowledge or consent of the Consumer. For example, legal, medical, debt collection or
locating the Consumer for their benefit.
Although information may be publicly available, Pomer and Boccia Professional Corporation
will treat this in accordance with PIPEDA principles. Moreover, Pomer and Boccia
Professional Corporation may provide personal information to its lawyers, agents to
collect a debt, comply with a subpoena, warrant or other court order, to a government
institution requesting the information upon lawful authority, or as may be otherwise
required by law. In all cases, proper internal authorization for disclosure procedures
will be followed.
Limiting Collection
The collection of personal information will be limited to that which is
appropriate in the circumstances.
The Pomer and Boccia Professional Corporation Website does not use or capture cookies; a
technology that installs a small amount of information on a visitor’s computer to
permit the Website to recognize future visits from that computer.
Limiting Use, Disclosure &
Retention
Pomer and Boccia Professional Corporation will not use or disclose personal
information for purpose other than those for which it was collected, except with consent
of the Consumer or as required by law. Personal information cannot be used or passed on in
a manner inconsistent with the identified purpose.
Pomer and Boccia Professional Corporation may disclose a Consumer’s personal
information to third parties retained by Pomer and Boccia Professional Corporation for the
purpose of collecting a debt from a Consumer.
Certain Pomer and Boccia Professional Corporation employees may be given access to a
Consumer’s personal information collected by Pomer and Boccia Professional
Corporation in so far as their duties require access for the purposes outlined. Pomer and
Boccia Professional Corporation employees are governed by a non-disclosure agreement
prohibiting disclosure or use of any confidential or personal information for any purpose
other than the stated purpose.
Personal information that has been used to make a decision about a Consumer will be
retained in accordance with the Pomer and Boccia Professional Corporation document
retention guidelines. Personal information that is no longer required will be destroyed,
erased or made anonymous. Pomer and Boccia Professional Corporation retains personal
information of a consumer only for as long as it is required for Pomer and Boccia
Professional Corporation business purposes or as required by federal and provincial laws.
Accuracy
Pomer and Boccia Professional Corporation will take reasonable steps to ensure
that the personal information under its control is as accurate, complete and up-to-date as
is necessary for the purposes for which it is to be used.
Pomer and Boccia Professional Corporation will not routinely update personal information,
unless such a process is necessary to fulfill the purposes for which the information was
collected. Pomer and Boccia Professional Corporation will take reasonable steps to ensure
that personal information that is used on an ongoing basis, including personal information
that is disclosed to third parties, is as accurate and up-to-date.
Access to a Consumer’s personal information on record with Pomer and Boccia
Professional Corporation may be requested by the Consumer in order to review and amend
their personal information, as appropriate.
Safeguards
Pomer and Boccia Professional Corporation will take responsible steps to protect
personal information through security safeguard as appropriate to the sensitivity of the
personal information. Employees of Pomer and Boccia Professional Corporation who have
access to personal information will be made aware of the importance of maintaining the
confidentiality of personal information. Security safeguards protect against loss or
theft, as well as unauthorized access, disclosure, copying, use or modification.
Openness
Pomer and Boccia Professional Corporation will make availability to any Consumer
specific information about its policy and guidelines relating to the management of
personal information.
Pomer and Boccia Professional Corporation will be open about its policy and procedure with
respect to the management of personal information, and Consumer will be able to acquire
information about these policies. This policy and any related information is available at
all times on Pomer and Boccia Professional Corporation website, www.pomerandboccia.com
under Privacy Act.
Individual Access
Pomer and Boccia Professional Corporation will inform a Consumer of the
existence, use and disclosure of their personal information and will provide access to
that personal information, upon written request. Pomer and Boccia Professional Corporation
will assist a Consumer in the preparation of a request for access when such a Consumer
request assistance. Pomer and Boccia Professional Corporation will inform the Consumer
whether or not it holds personal information about them, and will indicate the source of
any such personal information, when possible.
There may, however be situations in which Pomer and Boccia Professional Corporation will
not be able to provide access to all the personal information that it holds about a
Consumer, although these situations will be limited and specific, and permitted or
required by law. For example, Pomer and Boccia Professional Corporation will not be able
to provide access to Consumer’s personal information where given such access would
likely reveal personal information about a third party, unless that third party’s
personal information can be severed from the Consumer’s personal information. If
Pomer and Boccia Professional Corporation refuse a request for access, the Consumer will
be informed in writing of the refusal, setting out the reasons for the refusal and
informing the Consumer of their recourse.
Pomer and Boccia Professional Corporation will require the Consumer requesting access to
their personal information will provide the appropriate verification information required
to obtain access to such personal information. This information will not be used for any
purpose other than to permit Pomer and Boccia Professional Corporation to provide an
account of the existence, use and disclosure of the Consumer’s personal information.
Pomer and Boccia Professional Corporation will be as specific as possible in providing an
account of third parties to which personal information has been disclosed, and will
provide a list of organizations to which personal information has been disclosed.
Pomer and Boccia Professional Corporation will respond to the Customer's request to access
their personal information within a reasonable time, and not later than 30 days after
receipt of the request. Pomer and Boccia Professional Corporation may be entitled to a 30
day extension to respond, in limited circumstances, in which case the Customer will be
notified of such an extension, the new time limit, the reasons for extending the time
limit, and their right to make a complaint to the Privacy Commissioner with respect to the
extension.
Pomer and Boccia Professional Corporation may charge a reasonable fee for responding to a
request. This fee will be determined based on the request and any request specific
administrative or system costs that may be incurred, and will advise the Customer, in
advance, of the approximate cost. The personal information requested would be provided in
a form that is generally understandable.
A Customer will be able to challenge the accuracy and completeness of the personal
information and have it amended as appropriate. Depending upon the nature of the personal
information challenged, amendment may involve the correction, deletion or additional of
information, and the amended information will be transmitted to third parties having
access to the personal information, where appropriate.
When a Customer's challenge to the accuracy and completeness of their personal information
is not resolved to their satisfaction, Pomer and Boccia Professional Corporation will
record the unresolved challenge and will transmit the existence of the unresolved
challenge to third parties who have access to the personal information, where appropriate.
Challenging Compliance
A Customer will be able to address a challenge concerning compliance with the
above principles to the Privacy Officer. Pomer and Boccia Professional Corporation will
handle all complaints or inquiries about the policies and procedures relating to the
handling of personal information in line with the processes that are in place.
Pomer and Boccia Professional Corporation will inform Customers who make inquiries or
lodge complaints of the existence of the relevant complaint procedures. Pomer and Boccia
Professional Corporation will investigate all complaints, and if a complaint is justified,
Pomer and Boccia Professional Corporation will take appropriate measures, including
amending policies and procedures.
How to contact us
If you have any questions or comments about this Privacy
Policy or you feel that your concerns or complaints have not been resolved to your
satisfaction, please contact us
- by calling our Head Office at 1-888-858-5529
- by email
- by fax to 905-850-9376
- in writing to the Privacy Division:
Pomer and Boccia Professional Corporation
4000 Steeles Ave. West, Suite 215
Woodbridge, Ontario
L4L 4V9
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