The Company Privacy and Personal Information Protection, Electronic Documents Policy
In compliance with the present laws of Canada that protect the privacy of individuals (Customers and Employees) with respect to personal information about themselves held by Hector Publishing Company Limited (The Company) established a Company Privacy and Personal Information Protection , Electronic Documents Policy, organized according to the principles of the Canadian Standards Associations Model Code, to ensure that individuals personal information is protected and that The Company practices and procedures are also compliant with Bill C-6 (Personal Information Protection and Electronic Documents Act) as follows:
Limiting Use, Disclosure, and Retention
1. Company Identity
Hector Publishing Company Limited (The Company) is made up of the following companies:
Advocate Media Incorporated.
Advocate Printing and Publishing Company Limited
Flyer Services (1989) Limited
Hector Publishing Company Limited
Metro Guide Publishing Limited
St. Croix Printing & Publishing Company Limited
The Company including owners and all employees is responsible for personal information under its control and complies with the following principles:
3. Identifying Purpose
To prepare and communicate estimated costs to The Company customer for communication products and service deliverables.
To deliver The Company communication products and services to The Company customer.
To maintain customer histories in order to better understand customer communication product needs and preferences.
To invoice, collect and maintain payment record information.
To fulfill The Company subscription requests.
To electronically distribute and mail renewal notices.
To generate awareness and promote The Company Communication Products and Services.
To facilitate navigation of individual information collected from The Company owned electronic devices by use of "cookies".
To conduct readership studies.
To share news, event invitations and promotions regarding products and services.
As required by Bill C-6 The Company will consent as required to individual collection, use and disclosure of personal information.
In obtaining consent, The Company will use reasonable efforts to ensure that the individual is advised of the identified purposes for which personal information will be used or disclosed and explain these purposes in a manner that can be reasonably understood.
The Company may disclose personal information without individual knowledge or consent to a lawyer representing The Company, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law. In the case of debt collection, only the information necessary to collect the debt is turned over (e.g., invoice details and contact information).
In general, the use of The Company products and services by an individual constitutes implied consent for The Company to collect, use and disclose personal information for all identified purposes.
The Company collects electronic information from The Company owned electronic devices about individual navigational preferences. In some cases, digital logs of those preferences known as "cookies" are stored on The Company owned electronic devices. Individual electronic browsers include the option of denying cookies. Acceptance of cookies is assumed to be implied consent.
5. Limiting Collection
The Company limits information we collect to that which is necessary to deliver communication products and services; to meet standard invoicing, accounting and human resource practices and to company news, event invitations and promotions.
The Company maintains individual files, names, addresses, phone and fax numbers as well as individual email addresses electronically and in print. The Company also records whether or not an individual may have given The Company authorization to use individual personal information to promote The Company products and services. The Company collects information from other sources including credit bureaus, references, and third parties who represent that they have the right to disclose the information.
6. Limiting Use, Disclosure, and Retention
The information an individual provides to The Company is used only for the purposes outlined within The Company Privacy and Personal Information Protection, Electronic Documents Policy and The Company does not sell or disclose, other than for which it was collected, information as required by law. Law enforcement agencies have a right under various laws to have access to the information an individual provided to The Company. Legal warrants and lawful instruments will be required before The Company provides individual information.
The Company maintains records of individual communication products and services supplied information in an active file for seven (7) years.
Individual information as provided to The Company by individuals is securely maintained electronically. An Individual may request, in writing, in order for the Company to maintain the Individual information for a specific period of time.
Prior to completing individual work requisitions The Company develops electronic files. The information obtained within electronic files is secured. Individual contact information is electronically displayed or printed on billed invoices or renewal forms. The Company encourages individuals to verify invoice or renewal form information is accurate. Individual information is not altered unless an error is reported by the individual. Individuals that may have concerns about the accuracy of The Company records may contact The Company Finance or Customer Service Departments.
The Company will protect individual personal information by security safeguards appropriate to the sensitivity of the information. The Company will protect personal information against theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of format in which it is held.
The Company will protect individual information disclosed to third parties by contractual agreements stipulating confidentiality of the information and the purposes for which it is to be used.
All Company employees are required to respect the confidentiality of individual information by reading, complying with, acknowledging and signing The Company Privacy and Personal Information Protection, Electronic Documents Policy.
The Company Privacy and Personal Information Protection, Electronic Documents Policy are freely available from The Company website.
Upon written request The Company will provide a description of the type of individual information maintained; in compliance with current legal requirements; within individual files and provide a general account of its use. Written requests and inquiries should be made to:
For competitive reasons, The Company will not provide costing information. Individuals that may believe information on individual files could be inaccurate are invited to contact Company Finance or Customer Service Departments to request possible amendments. In the event that The Company disagrees with individual views of the accuracy of currently maintained information, The Company will be happy to maintain individual comments as received.
11. Challenging Compliance
The Company is committed to comply with the present laws of Canada that protect the privacy of individuals with respect to personal information about themselves held by The Company. The Company Privacy and Personal Information Protection, Electronic Documents Policy, organized according to the principles of the Canadian Standards Associations Model Code, will help ensure that individuals personal information is protected and that all of The Company practices and procedures are also compliant with Bill C-6 (Personal Information Protection and Electronic Documents Act). Further, The Company will ensure that the policy meets individual concerns and responds to written requirements as requested. Written requests and complaints will be investigated and responded by authorized company representatives who will communicate findings within a reasonable amount of time. If a complaint is found to be justified, The Company will take appropriate action to resolve the complaint to be in compliance with individual requirements and within legal requirements.
Individuals that may disagree with the results of The Company’s efforts may contact:
Office of the Federal Privacy Commissioner
112 Kent Street
Scope and Application
The above eleven (11) principles, form the basis of The Company Privacy and Personal Information Protection, Electronic Documents Policy. The Company will adhere to the principles as a whole.
The scope and application is as follows:
The policy applies to personal information about individuals that The Company collects, uses or discloses.
The policy applies to the management of individual information in any form whether oral, electronic or written.
The policy does not impose any limits on the collection, use or disclosure of the following information:
Individual names, addresses, telephone numbers and e-mail addresses, when listed in a directory or available through directory assistance;
Employee names, job titles, business addresses (including e-mail addresses) or Company owned telephone or fax numbers; or,
Other information about the individual that is publicly available and is specified by regulation pursuant to the Personal Information Protection and Electronic Document Act.
Last Revised June 30, 2014