WHAT IS PERSONAL INFORMATION?
Personal information is information about an identifiable individual. Personal information includes information such as your name, home address or telephone number, age, gender, income, ethnic background, family status, health history, religious beliefs or political opinions. Personal information, however, does not include business information such as an individual’s business title, address and telephone number.
OUR COLLECTION OF PERSONAL INFORMATION
Like all businesses, we collect, use and disclose personal information in order to serve our customers. For our customers, the primary purpose for collecting personal information is to rent storage units to our customers and to sell ancillary goods to our customers. We also collect personal information to send you insurance flyers, information bulletins, notices of rate changes, and notices of promotions and special offers which relate to the services which you have ordered from us. We also collect personal information in order to identify our customers and to contact our customers in an emergency.
Under no circumstances will the personal information which we collect be communicated or disseminated to third parties, except as provided herein. In the normal course of business, we may disclose some personal information to third party service providers and suppliers as needed to provide the services which you request from us. We must also disclose personal information when required by law to do so. For example, if we are presented with a search warrant or other legal order or if personal information is requested from an investigative body in relation to a breach of the law, personal information may be disclosed
About Members of the General Public (Not Customers)
For members of the general public, our primary purpose for collecting personal information is to provide notice of special events (e.g. promotions or discounts) or to make them aware of our services in general or our company in particular. For example, while we try to collect work contact information where possible, we might collect home addresses, fax numbers and email addresses. We try to obtain consent before collecting any such personal information, but where this is not, for any reason, possible, we will upon request immediately remove any personal information from our distribution list.
On our website, we only collect (with the exception of cookies) the personal information you provide and only use that information for the purpose you gave it to us (e.g. to respond to your email message). Cookies are only used to help you navigate our website and are not used to monitor you. We are committed to protecting the information you give us online and we have implemented appropriate safeguards. Despite our efforts, there is no guarantee that personal information and transactions on our website or on the Internet will be maintained confidential and secure. If you do not wish to submit personal information online, we ask that you contact us by visiting us at one of our locations, or by regular mail, telephone or fax, and we would be pleased to be of service.
About Contract Staff
For people who are contracted to do work for us (e.g. temporary workers), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g. for new assignments) and for necessary work-related communication (e.g. sending out paycheques, year-end tax receipts, tax filings). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of a health emergency or to investigate a possible breach of law.
Like most businesses, we also collect, use and disclose information for other purposes. The most common examples are as follows:
We may invoice customers for goods or services that are not paid for at the time, process credit card payments, collect unpaid accounts or institute auction procedures (which may include publishing customers’ names in an advertisement).
Like all organizations, various government agencies (e.g. Canada Revenue Agency, Information and Privacy Commissioner, Human Rights Commission etc.) have the authority to review our files and interview our staff as a part of their mandate. In these circumstances, we may consult with professionals (e.g. lawyers, accountants) who will investigate the matter and report back to us.
Our company may report information suggesting serious illegal behaviour to the appropriate authorities.
Customers or other individuals we deal with may have questions about our services after the services have been provided. We also provide ongoing services for many of our customers over a period of months or years for which previous records are helpful.
If Cowie Capital Partners Inc. shares or assets were to be sold, the purchaser would want to conduct a review of our records to ensure that we are a viable business. This may involve a review of personal information held by us. Before being provided access to our records, we will ensure that the purchaser or its representative provides written assurances to keep all personal information confidential and to review such information only for the purpose of completing the purchase of shares or assets.
You can choose not to be part of some of these purposes (e.g. by declining special offers or promotions, by paying for our goods and services in advance). We do not, however, have much choice about some other purposes (e.g. regulatory reporting, response to law enforcement agencies or the courts).
PROTECTING PERSONAL INFORMATION
We understand the importance of protecting personal information. For that reason, we have taken the following steps:
Paper information is either under supervision or secured in a locked or restricted area.
Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers.
Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
Electronic information is transmitted either through a direct line or is anonymized or encrypted.
Cowie Capital Partners Inc. uses a number of external consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include computer consultants, office security and maintenance, bookkeepers and accountants, lawyers, temporary workers to cover holidays, credit card companies, website managers, cleaners and our landlord. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.
RETENTION AND DESTRUCTION OF PERSONAL INFORMATION
We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies (e.g. tax purposes). However, we do not want to keep personal information too long in order to protect your privacy.
We keep our customer files and information for several years after the last contact. Our customer and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We keep any personal information relating to our marketing activities for about 6 months after the marketing activity is over.
We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed.
ACCESS TO PERSONAL INFORMATION
With some exceptions, you have the right to see what personal information we hold about you. Often, all you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g. short forms, technical language). Before providing you with this access, we will need to confirm your identity if we do not know you. We reserve the right to charge a nominal fee for such requests.If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.
If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information. We may ask you to provide documentation that proves that the information in our files is wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on this issue and we will forward that statement to anyone else who received the earlier information.
DO YOU HAVE A QUESTION?
Our Information Officer can be reached at:
Cowie Capital Partners Inc.
55 Kelfield Street
Toronto, Ontario M9W 5A3
Attention: Information Officer
The Information Officer will attempt to answer any questions or concerns you may have. If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. The Information Officer will acknowledge receipt of your complaint and will ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.
This policy is made under the Personal Information Protection and Electronic Documents Act. It is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some exceptions to the commitments set out above.
For more general inquiries, the Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Privacy Commissioner can be reached at:
Privacy Commissioner of Canada
112 Kent Street
Ottawa, Ontario K1A 1H3
We reserve our right to amend our privacy policies from time to time and with or without notice.