At Agricultural Enterprises Limited, we are committed to providing our employees and customers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our employees and customers protecting their personal information is one of our highest priorities.
While we have always respected our employees and customers privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of Personal Information Protection and Electronic Documents Act). (S.C. 2000, c. 5)
We will inform our employees and customers of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection & Electronic Documents Act , outlines the principles and practices we will follow in protecting employees’ and customers’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our employees’ and customers’ personal information and allowing our employees and customers to request access to, and correction of, their personal information.
Personal Information –means information about an identifiable E.g., including name, age, home address and phone number, social insurance number, marital status, religion, income, credit history, medical information, education, employment information. Personal information does not include contact information (described below).
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy.
Privacy Officer – means the individual designated responsibility for ensuring that Agricultural Enterprises Limited complies with this policy.
Policy 1 – Collecting Personal Information
- Unless the purposes for collecting personal information are obvious and the employee and customer voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect employee and customer information that is necessary to fulfill the following purposes:
- To verify identity;
- To verify creditworthiness;
- To identify employee and customer preferences;
- To open and manage an account;
- To deliver requested products and services
- To guarantee a travel or hotel reservation;
- To send out association membership information;
- To ensure a high standard of service to our employees and customers;
- To meet regulatory requirements;
Policy 2 – Consent
2.1 We will obtain employee and customer consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided, orally, in writing, electronically, through an authorized representative] or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the employee and customer voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a employee and customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, and the employee and customer does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), employees and customers can withhold or withdraw their consent for Agricultural Enterprises Limited to use their personal information in certain ways. A employees and customers decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the employees and customers in making the decision.
2.5 We may collect, use or disclose personal information without the employees and customers knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- In an emergency that threatens an individual’s life, health, or personal security;
- When the personal information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose employees and customers personal information where necessary to fulfill the purposes identified at the time of collection [or for a purpose reasonably related to those purposes such as:
- To conduct client, customer, member surveys in order to enhance the provision of our services;
- To contact our employees and customers directly about products and services that may be of interest;
3.2 We will not use or disclose employees and customers personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell employees and customers lists or personal information to other parties [unless we have consent to do so].
Policy 4 – Retaining Personal Information
4.1 If we use employees and customers personal information to make a decision that directly affects the employees and customers, we will retain that personal information for at least one year so that the employees and customers has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain employees and customers personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that employees and customers personal information is accurate and complete where it may be used to make a decision about the employees and customers or disclosed to another organization.
5.2 Employees and customers may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
A request to correct personal information should be forwarded to the Privacy Officer or designated individual.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’, customers’, members’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of employees and customers personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that employees and customers personal information is appropriately protected:
- Locked file cabinets will be used to store information
- Restricting employee access to personal information as appropriate
- The use of user IDs, passwords
6.3 We will use appropriate security measures when destroying employees and customers personal information such as:
- Shredding documents,
- Deleting electronically stored information
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Employees and customers Access to Personal Information
7.1 Employees and customers have a right to access their personal information, subject to limited exceptions.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer or designated individual
7.3 Upon request, we will also tell employees and customers how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 If a request is refused in full or in part, we will notify the employees and customers in writing, providing the reasons for refusal and the recourse available to the employees and customers.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer or designated individual is responsible for ensuring Agricultural Enterprises Limited compliance with this policy and the Personal Information Protection and Electronic Documents Act.
8.2 Employees and customers should direct any complaints, concerns or questions regarding Agricultural Enterprises Limited’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the employees and customers may also write to the The Office of the Privacy Commissioner of Canada (OPC)
Office of the Privacy Commissioner of Canada
30 Victoria Street
Contact information for Agricultural Enterprises Limited Privacy Officer or designated individual:
Privacy Officer: Glen MacKenzie – 55 Industrial Avenue , Truro, NS B2N 6V1