Canadian Produce Marketing Association’s Privacy Policy
The privacy of our members and customers is of great importance to the Canadian Produce Marketing Association (CPMA). CPMA is committed to maintaining the privacy of its members and customers, in accordance with all applicable legislative requirements. This Policy outlines CPMA’s practices and procedures with regard to privacy.
This Policy applies to all Personal Information collected, used, or disclosed by CPMA during the course of its business activities. This Policy applies to all CPMA staff, employees, contractors, and agents.
With respect to members and customers, personal information may be collected primarily in connection with services and products provided by CPMA. In all instances, CPMA is committed to protecting the privacy of individuals by ensuring that their personal information is accurate, confidential and secure.
Should you have any questions about this Policy or CPMA’s commitment to the protection of Personal Information, please contact the Chief Privacy Officer: Tracy Todd.
Definitions
In this Policy, the following terms will have the following meanings:
Personal Information: information about an identifiable individual, recorded in any form. It includes, but is not limited to: employment or financial history; address and telephone number; birth date; medical history; numerical identifiers such as Social Insurance Number; and personal views or opinions.
Consent: freely given, specific, informed and unambiguous indication of an individual’s wishes by which he or she, by a statement or by clear affirmative action, signifies agreement to the processing of Personal Information relating to him or her.
Processing: any operation or set of operations performed on Personal Information, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure, dissemination, or otherwise making available, alignment or combination, restriction, erasure or destruction.
Collection: the act of gathering, acquiring, or obtaining Personal Information from any source, including third parties, by any means.
Use: the treatment and handling of Personal Information by CPMA.
Disclosure: making Personal Information available to others outside CPMA.
Policy
To protect the privacy of members, customers, and others, CPMA will adhere to the following principles:
1. Accountability
CPMA is accountable for all Personal Information it processes or that is in CPMA’s possession including any Personal Information disclosed to third parties for processing.
CPMA has designated a Chief Privacy Officer who is accountable for the CPMA’s compliance with PIPEDA and this Policy.
1.1 CPMA’s Chief Privacy Officer and senior management are ultimately accountable for compliance with this policy and all applicable privacy legislation, however day-to-day compliance is delegated to all CPMA employees.
1.2 Personal Information that is transferred to third parties for processing will be safeguarded by way of contracts or agreements with the third parties to ensure that the third parties are also safeguarding this information.
1.3 CPMA has established policies and procedures to comply with this Policy and the applicable privacy legislation. CPMA will make every reasonable effort to periodically update this Policy to ensure that it is compliant with the governing privacy legislation, and is in general conformity with best practices.
2. Identifying Purposes for Collection of Personal Information
CPMA will identify the purpose for which Personal Information is collected at or before the time the information is collected. Any Personal Information collected will be will be used only for the original purpose for which it was collected. Any secondary or optional uses CPMA may make of any Personal Information will be identified and individuals will be provided with an opportunity to reject or accept such uses. CPMA will only collect information that is necessary for the identified purpose(s).
2.1 CPMA collects Personal Information from you with your knowledge and consent for purposes reasonably consistent with the following only:
a) to communicate industry information
b) to communicate information about and to promote CPMA events
c) to produce our annual membership directory
d) to reserve hotel rooms for our annual convention and other meetings
e) to develop, enhance, market or provide products or services
f) to manage and develop the association
g) to meet legal and regulatory requirements
3. Obtaining Consent for Processing Personal Information
CPMA will not collect, use or disclose an individual’s Personal Information without their knowledge and consent except in certain instances where permitted by law.
3.1 CPMA will seek to obtain consent for the collection and subsequent use and disclosure of Personal Information at the time of collection of the information.In certain circumstances, consent for the use and disclosure of Personal Information will be sought after the information has been collected, but before it is used, in particular if CPMA wants to use the information for a purpose not previously identified.
3.2 CPMA will ensure that meaningful consent is obtained for the collection, use and disclosure of Personal Information.To attain this, the purpose for which the information will be used will be stated in such a manner that the individual can reasonably understand how the information will be used or disclosed.
3.3 CPMA will require individuals to provide consent to the processing of Personal Information as a condition of the supply of product or service only if such processing is required to fulfill the identified purpose.
3.4 CPMA will determine the type of consent required based on the type of information collected, its intended use and the sensitivity of the information.
3.5 Consent may be expressed or implied, given orally, electronically or in writing.
3.6 An individual may withdraw consent at any time by contacting CPMA and indicating their desire to do so. The individual will be notified by CPMA of the implications of this withdrawal. Withdrawal of consent will not affect the lawfulness of Personal Information processed prior to the individual withdrawing consent.
4. Limiting Collection of Personal Information
CPMA will limit the collection of Personal Information to that which is necessary for the purposes identified by CPMA. This information will be collected by fair and lawful means at all times.
4.1 CPMA primarily collects Personal Information from its members, customers and employees but may also collect Personal Information from other sources, with the consent of the individual.
5. Limiting Processing of Personal Information
Personal Information will not be used or disclosed by CPMA for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal Information will be retained only as long as reasonably necessary for the fulfillment of those purposes or as required by law.
6. Accuracy of Personal Information
CPMA will make reasonable efforts to ensure that Personal Information of individuals is kept accurate, complete and up-to-date as is necessary for the purpose for which it is to be used.
6.1 CPMA will make reasonable efforts to obtain information from individuals in order to update information on hand if required to fulfill the purpose for which the information was collected.If CPMA is informed that the information that they hold for an individual is incorrect, CPMA will update the information as soon as possible.
6.2 Personal Information will not be updated without the consent of the individual.
7. Safeguards
CPMA will protect Personal Information by using appropriate technical and organizational security safeguards.
7.1 CPMA will use security safeguards to protect Personal Information against loss or theft, unauthorized access, disclosure, copying, use, modification, damage or destruction, regardless of the format in which it is held.
7.2 CPMA will make reasonable efforts to ensure that third parties use safeguards comparable to CPMA’s and in compliance with the applicable privacy legislation to protect Personal Information that has been disclosed to them for the purpose of processing.
7.3 CPMA will ensure all employees are aware of the importance of maintaining confidentiality of Personal Information and will be trained as how to safeguard this information.Employees of CPMA are required to abide by this policy.
8. Openness Concerning Policies and Practices
CPMA will make readily available to individuals specific information about its policies and practices relating to the management of Personal Information.
8.1 CPMA will make this specific information readily available to individuals in a form that is generally understandable.
8.2 CPMA will provide information about its policies and practices in various ways.
9. Individual Access
Upon the receipt by CPMA of a written request, an individual will be informed, within a reasonable period of time following such request, of the existence, use and disclosure of his or her Personal Information and will be given access to that information. In certain limited circumstances, as permitted or required by law, certain information will not be disclosed to the individual.
9.1 Subject to applicable laws, upon receipt of a written request from an individual, CPMA will inform him or her whether or not CPMA holds Personal Information about the individual and make reasonable efforts to indicate the source of the information as well as a summary of the use of the information.
9.2 An individual may be required to provide sufficient information to permit CPMA to provide an account of the existence, use and disclosure of personal information.The information provided will be used only for this purpose.
9.3 CPMA may charge a reasonable fee to cover its cost of providing the information.CPMA will notify the individual of the estimated cost of providing the information prior to doing so and will afford the individual the opportunity to withdraw his or her request.
9.4 Upon receipt of written request, CPMA will provide an individual a list of third parties to which it may have disclosed personal information about the individual and the purpose for which the information may have been disclosed.
9.5 When an individual successfully demonstrates the inaccuracy or incompleteness of personal information held by CPMA, CPMA will amend the information as required.
9.6 CPMA may decline to provide an individual access to his or her personal information in accordance with applicable laws
9.7 Where an individual requests to port his or her Personal Information to another controller, CPMA will take reasonable steps to ensure that the individual’s Personal Information is erased without undue delay.
10. Challenging Compliance
CPMA will take the necessary steps to comply with all applicable privacy legislation.
An individual can address a challenge concerning CPMA’s compliance with the above principles to CPMA’s Chief Privacy Officer.
10.1 CPMA has procedures in place to receive and respond to inquiries or complaints about this policy and its handling of Personal Information.
10.2 Questions and complaints regarding CPMA’s compliance with this policy may be made in writing to:
By mail:
Chief Privacy Officer
Canadian Produce Marketing Association
162 Cleopatra Drive
Ottawa, Ontario
K2G 5X2
By e-mail: [email protected]
By fax: 1-613-226-2984
10.3 If an individual is not satisfied that CPMA is operating in compliance with requirements of PIPEDA, the individual may file a written complaint with the Commissioner at the following address:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec
K1A 1H3
Telephone: 1-819-994-5444
Toll free: 1-800-282-1376
Fax: 1-819-994-5424
E-mail: [email protected]