PERSONAL INFORMATION PROTECTION POLICY
Excela Associates Inc. collects very little personal information, mostly limited to business contact information for our clients and associates. When we do, though, Excela is committed to safeguarding the personal information entrusted to us by our clients. 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 Excela Associates Inc. and its individual associates when they are conducting business as our associates. This policy also applies to any other individual under contract to provide services on our behalf. It does not apply to corporate associates of Excela Associates Inc., which operate in accordance with their own privacy policies.
WHAT IS PERSONAL INFORMATION?
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:
deliver requested services
communicate with clients via mail, telephone, e-mail, videoconference, or in person
contact clients about appointments and meetings
follow up with clients to determine satisfaction with our services
notify clients of new services, changes to our services, or events of interest
recruit, hire, train, and manage employees
identify potential associates and manage associate relationships
We normally collect client information directly from our clients. On rare occasions we may collect personal information from other persons with consent or as authorized by law.
We ask for consent to collect, use or disclose client 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 may 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 clients to provide their consent in writing (by signing a consent form), by checking a box on a form, or electronically (by clicking a button or responding to a registered email).
In cases that do not involve sensitive personal information, we may rely on “opt-out” consent. For example, we may disclose your business contact information to other organizations as part of the services we deliver, or for reference purposes, unless you request that we do not disclose your information. You can do this by writing to us at the address provided below, by sending us an email to email@example.com, or by telephoning 780-945-0123.
A client may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfil our legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary personal information.
We may collect, use or disclose client 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 client personal information only for the purposes for which the information was collected, except as authorized by law. For example, we may use client contact information to deliver goods. 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 client information is accurate and complete. We rely on our clients 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 client 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 use appropriate security measures when destroying client personal information, including encrypting and securely deleting electronic records and shredding paper records.
We retain client personal information only as long as is reasonable to fulfil the purposes for which the information was collected or for legal or business purposes.
LOCATION OF PERSONAL INFORMATION
Some personal information contained in email correspondence to or from Excela may be stored outside Canada. In particular, email addresses ending in excela.ca are hosted by Google in the United States. If you want to send email to Excela for storage only in Canada, please telephone us for a secure email address.
All other records in Excela's custody are stored in Canada. Some backups may be located outside Canada, but they are fully encrypted with private keys.
ACCESS TO RECORDS CONTAINING PERSONAL INFORMATION
Clients of Excela have a right of access to 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 your personal information by writing to the address provided below. 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 an 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 Excela Associates Inc., or about a request for access to your own personal information, please contact the address below. (For your own privacy, we recommend that you include sensitive personal information in your e-mail only if it is contained in an encrypted attachment. You may send the password for any such attachment by phone or text message to the number below.)
Alec Campbell, President
Excela Associates Inc.
943 110A Street NW
Edmonton, AB, Canada
If your commercial interaction with Excela occurred in Alberta and you are not satisfied with the response you receive from us, you may contact the Information and Privacy Commissioner of Alberta:
If your commercial interaction with Excela occurred in a province or territory other than Alberta and you are not satisfied with the response you receive from us, you may contact the Privacy Commissioner of Canada:
Privacy Commissioner of Canada
Place de Ville, 112 Kent Street
Tower B, 3rd Floor
Phone: (613) 995-8210 Toll-free: 1-800-282-1376
Fax: (613) 947-6850 TTY: (613) 992-9190