At The Traveller Inc., respecting privacy is an important part of our commitment to our clients, employees and the general public.
If you have any concerns about how your privacy is protected at The Traveller Inc., please contact our Privacy Officer by e-mail at: email@example.com by phone at: 416-304-1223 or 1.866.440.8926 or by mail at: 40 University Ave., Suite 710, Toronto, ON M5J 1T1.
Collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.
Consent: Voluntary agreement for the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of The Traveller Inc. Implied consent is consent that can reasonably be inferred from an individual's action or inaction.
Disclosure: Making personal information available to a third party.
Employee: An employee of or independent contractor to The Traveller Inc.
Personal Information: Information about an identifiable individual, but does not include, where excluded by applicable law, the name, title, business address or telephone number of an employee of an organization, and does not include descriptive, factual information about an organization.
Respondent: A member of the public who provides personal information to The Traveller Inc. in the course of a survey conducted by The Traveller Inc. For example, a respondent is an individual who discloses personal information to The Traveller Inc. in the course of quantitative or qualitative marketing or social research.
Third Party: An individual or organization outside of The Traveller Inc.
Use: The treatment, handling, and management of personal information by and within The Traveller Inc. or by a third party with the knowledge and approval of The Traveller Inc.
Principle 1 - Accountability
Principle 2 - Identifying Purposes for Collection of Personal Information
The Traveller Inc. shall identify the purposes for which personal information is collected at or before the time the information is collected. The Traveller Inc. collects personal information from the public only for the following purposes: i. to conduct quantitative or qualitative marketing and social research ii. to understand respondent opinions to establish suitability for further quantitative and qualitative marketing and social research; and iii. to meet legal and regulatory requirements. Further reference to identified purposes mean the purposes identified in this Principle. The Traveller Inc. shall specify orally, electronically or in writing the identified purposes to the respondent at or before the time personal information is collected in a survey. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within The Traveller Inc. who can explain the purposes. When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is permitted or required by law, the consent of the respondent will be acquired before the information will be used or disclosed for the new purpose.
Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of an individual are required for the collection, use, or disclosure of personal information, except where inappropriate. Participation by respondents in survey research is always voluntary. When a respondent agrees to participate in a survey, he/she gives consent to the interview by participating. Generally, any personal information collected in the course of an interview is not disclosed to third parties. However, occasionally, a client sponsoring a research project may want to contact respondents directly. Therefore, respondents may receive a follow-up communication to gain more understanding of their experience with their organization A respondent is always free to choose whether or not to participate in a survey, free to choose not to answer any specific questions and free to discontinue participation at any time. In obtaining consent, The Traveller Inc. shall use reasonable efforts to ensure that a respondent is advised of the identified purposes for which personal information will be used or disclosed. The identified purposes shall be stated in a manner that can be reasonably understood by the respondent. Generally, The Traveller Inc. shall seek consent to use and disclose personal information at the same time it collects the information. However, The Traveller Inc. may seek consent to use and/or disclose personal information after it has been collected, but before it is used and/or disclosed for a new purpose. In determining the appropriate form of consent, The Traveller Inc. shall take into account the sensitivity of the personal information and the reasonable expectations of its respondents. The participation of a respondent in a quantitative or qualitative marketing or social research study may constitute implied consent for The Traveller Inc. to collect, use and disclose personal information for the identified purposes.
Principle 4 - Limiting Collection of Personal Information
The Traveller Inc. shall limit the collection of personal information to that which is necessary for the purposes identified by The Traveller Inc. The Traveller Inc. shall collect personal information by fair and lawful means. In conducting surveys, The Traveller Inc. limits the amount and type of personal information it collects. We collect only the amount and type of information needed for the purposes identified to individuals. The Traveller Inc. collects personal information about an individual primarily from that individual or a member of that individual's household. Except as permitted by law, The Traveller Inc. will only collect personal information from external sources, such as client organizations, if individuals have consented to such collection.
Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information
The Traveller Inc. shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes. The Traveller Inc. may disclose a respondent's personal information to: i. a client of The Traveller Inc. where the respondent has consented to such disclosure; such consent is given upon participation in the study ii. a third party engaged by The Traveller Inc. to perform functions on its behalf; iii. a public authority or agent of a public authority if, in the reasonable judgment of The Traveller Inc., it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or iv. a third party or parties, where the respondent consents to such disclosure or disclosure is required or permitted by law. Only The Traveller Inc.'s employees with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about respondents. The Traveller Inc. shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where a respondent may have to be re-contacted for purposes of clarifying responses to a survey, or to seek additional responses, The Traveller Inc. shall retain the personal information for a period of time that is reasonably sufficient to allow this re-contact. The Traveller Inc. shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous. The Traveller Inc. shall not use, and shall use reasonable efforts to ensure third parties to whom it discloses your personal information do not use, your personal information in a manner that contravenes CASL.
Principle 6 - Accuracy of Personal Information
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. Personal information used by The Traveller Inc. shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a respondent. The Traveller Inc. shall update personal information about respondents and employees as necessary to fulfill the identified purposes or upon notification by the individual.
Principle 7 - Security Safeguards
The Traveller Inc. shall protect personal information by security safeguards appropriate to the sensitivity of the information. The Traveller Inc. shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held. The Traveller Inc. shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used. All of The Traveller Inc.'s employees with access to personal information shall be required to respect the confidentiality of that information.
Principle 8 - Openness Concerning Policies and Procedures
Principle 9 - Individual Access to Personal Information
Upon request, The Traveller Inc. shall inform an individual of the existence, use, and disclosure of his or her personal information and shall give the individual access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate. Upon written or electronic request to the Privacy Officer, The Traveller Inc. will inform an individual of the existence, use and disclosure of his/her personal information and shall be given access to that information In certain situations, The Traveller Inc. may not be able to provide access to all the personal information that it holds about a respondent. For example, The Traveller Inc. may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, The Traveller Inc. may not provide access to information if disclosure would reveal confidential commercial information. In order to safeguard personal information, a respondent may be required to provide sufficient identification information to permit The Traveller Inc. to account for the existence, use and disclosure of personal information and to authorize access to the individual's file. Any such information shall be used only for this purpose. The Traveller Inc. shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual's file. Where appropriate, The Traveller Inc. shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences. Respondents and employees can obtain information or seek access to their individual files by contacting The Traveller Inc. Privacy Officer.
Principle 10 - Challenging Compliance
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