WHO IS ALBERTA PRINTED CIRCUITS LTD.
Alberta Printed Circuits Ltd., AP Circuits, is a privately-owned Canadian company. This policy applies to Alberta Printed Circuits Ltd. and any related companies.
The technology underlying the information economy provides a number of benefits that improve the quality of our lives. This technology also gives rise to concerns about the protection of privacy rights and the individual's right to control the use and exchange of personal information. By implementing a policy for personal information, AP Circuits demonstrates their commitment to the protection of personal information. This document is a voluntary policy for the protection of personal information. The policy addresses two broad issues: the way AP Circuits collects, uses, discloses, and protects personal information; and the right of individuals to have access to personal information about themselves, and, if necessary, to have the information corrected.
PRINCIPALS IN SUMMARY
An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization's compliance with the following principles.
Accountability for AP Circuits’ compliance with the principles rests with the designated individual(s), even though other individuals within AP Circuits may be responsible for the day-to-day collection and processing of personal information. In addition, other individuals within AP Circuits may be delegated to act on behalf of the designated individual(s).
The identity of the individual(s) designated by AP Circuits to oversee its compliance with the principles are the President, Vice-President, and the Accounts Supervisor.
AP Circuits is responsible for personal information in its possession or custody, including information that has been transferred to a third party for processing. AP Circuits uses contractual or other means to provide a comparable level of protection while the information is being processed by a third party.
AP Circuits shall implement policies and practices to give effect to the principles, including (a) implementing procedures to protect personal information; (b) establishing procedures to receive and respond to complaints and inquiries; (c) training staff and communicating to staff information about the organization's policies and practices; and (d) developing information to explain the organization's policies and procedures.
The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate. Note: In certain circumstances personal information can be collected, used, or disclosed without the knowledge and consent of the individual. For example, legal, medical, or security reasons may make it impossible or impractical to seek consent. When information is being collected for the detection and prevention of fraud or for law enforcement, seeking the consent of the individual might defeat the purpose of collecting the information. Seeking consent may be impossible or inappropriate when the individual is a minor, seriously ill, or mentally incapacitated. In addition, organizations that do not have a direct relationship with the individual may not always be able to seek consent.
Consent is required for the collection of personal information and the subsequent use or disclosure of this information. Typically, AP Circuits will seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when AP Circuits wants to use information for a purpose not previously identified).
The principle requires "knowledge and consent". AP Circuits shall make a reasonable effort to ensure that the individual is advised of the purposes for which the information will be used. To make the consent meaningful, the purposes must be stated in such a manner that the individual can reasonably understand how the information will be used or disclosed.
AP Circuits may not, as a condition of the supply of a product or service, require an individual to consent to the collection, use, or disclosure of information beyond that required to fulfill the explicitly specified, and legitimate purposes.
The form of the consent sought by AP Circuits may vary, depending upon the circumstances and the type of information. In determining the form of consent to use, AP Circuits shall take into account the sensitivity of the information. Although some information (for example, medical records and income records) is almost always considered to be sensitive, any information can be sensitive, depending on the context.
In obtaining consent, the reasonable expectations of the individual are also relevant. Consent shall not be obtained through deception.
The way in which AP Circuits seeks consent may vary, depending on the circumstances and the type of information collected. AP Circuits will generally seek express consent when the information is likely to be considered sensitive. Implied consent would be appropriate when the information is less sensitive. Consent can also be given by an authorized representative (such as a legal guardian or a person having power of attorney).
Individuals can give consent in many ways. For example: (a) an application form may be used to seek consent, collect information, and inform the individual of the use that will be made of the information. By completing and signing the form, the individual is giving consent to the collection and the specified uses; (b) a checkoff box may be used to allow individuals to request that their names and addresses not be given to other organizations. Individuals who do not check the box are assumed to consent to the transfer of this information to third parties; (c) consent may be given orally when information is collected over the telephone; or (d) consent may be given at the time that individuals use a product or service.
An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. AP Circuits will inform the individual of the implications of such withdrawal.
Limiting Use, Disclosure, and Retention
Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfilment of those purposes.
Personal information that has been used to make a decision about an individual shall be retained long enough to allow the individual access to the information after the decision has been made. AP Circuits may be subject to legislative requirements with respect to retention periods.
Personal information that is no longer required to fulfill the identified purposes shall be destroyed, erased, or made anonymous.
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
The extent to which personal information shall be accurate, complete, and up-to-date will depend upon the use of the information, taking into account the interests of the individual. Information shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about the individual.
AP Circuits shall not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected.
Personal information that is used on an ongoing basis, including information that is disclosed to third parties, should generally be accurate and up-to-date.
Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
The security safeguards shall protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. AP Circuits shall protect personal information regardless of the format in which it is held.
The nature of the safeguards will vary depending on the sensitivity of the information that has been collected, the amount, distribution, and format of the information, and the method of storage. More sensitive information shall be safeguarded by a higher level of protection. The methods of protection shall include (a) physical measures, for example, locked filing cabinets and restricted access to offices; (b) organizational measures, for example, security clearances and limiting access on a "need-to-know" basis; and (c) technological measures, for example, the use of passwords, encryption, and firewalls.
AP Circuits shall make their employees aware of the importance of maintaining the confidentiality of personal information and protecting their passwords.
Care shall be used in the disposal or destruction of personal information, to prevent unauthorized parties from gaining access to the information.
AP Circuits shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.
AP Circuits shall be open about its policies and practices with respect to the management of personal information. Individuals shall be able to acquire information about AP Circuits’ policies and practices without unreasonable effort. This information shall be made available in a form that is generally understandable.
The information made available shall include (a) the name/title and address of the person who is accountable for the organization's policies and practices and to whom complaints or inquiries can be forwarded; (b) the means of gaining access to personal information held by the organization; (c) a description of the type of personal information held by the organization, including a general account of its use; (d) a copy of any brochures or other information that explain the organization's policies, standards, or codes; and (e) what personal information is made available to related organizations.
AP Circuits may make information on its policies and practices available in a variety of ways. The method chosen depends on the nature of its business and other considerations. For example, AP Circuits may choose to make brochures available in its place of business, mail information to its customers, provide online access, or establish telephone/fax numbers.
Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate. Note: In certain situations, an organization may not be able to provide access to all the personal information it holds about an individual. Exceptions to the access requirement should be limited and specific. The reasons for denying access shall be provided to the individual upon request. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.
Upon request, AP Circuits shall inform an individual whether or not it holds personal information about the individual. AP Circuits shall indicate the source of this information wherever possible. AP Circuits shall allow the individual access to this information. However, AP Circuits may choose to make sensitive medical information available through a medical practitioner. In addition, AP Circuits shall provide an account of the use that has been made or is being made of this information and an account of the third parties to which it has been disclosed.
An individual may be required to provide sufficient information to permit an organization to provide an account of the existence, use, and disclosure of personal information. The information provided shall only be used for this purpose.
In providing an account of third parties to which it has disclosed personal information about an individual, AP Circuits shall attempt to be as specific as possible. When it is not possible to provide a list of the organizations to which it has actually disclosed information about an individual, AP Circuits shall provide a list of organizations to which it may have disclosed information about the individual.
AP Circuits shall respond to an individual's request within a reasonable time and at minimal or no cost to the individual. The requested information shall be provided or made available in a form that is generally understandable. For example, if AP Circuits uses abbreviations or codes to record information, an explanation shall be provided.
When an individual successfully demonstrates the inaccuracy or incompleteness of personal information, AP Circuits shall amend the information as required. Depending upon the nature of the information challenged, amendment involves the correction, deletion, or addition of information. Where appropriate, the amended information shall be transmitted to third parties having access to the information in question.
When a challenge is not resolved to the satisfaction of the individual, the substance of the unresolved challenge shall be recorded by AP Circuits. When appropriate, the existence of the unresolved challenge should be transmitted to third parties having access to the information in question.
An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization's compliance.
The individual(s) accountable for AP Circuits’ compliance is discussed in Principles are the President, Vice-President, and the Accounts Supervisor.
AP Circuits shall put procedures in place to receive and respond to complaints or inquiries about their policies and practices relating to the handling of personal information. The complaint process shall be easily accessible and simple to use.
AP Circuits shall inform individuals who make inquiries or lodge complaints of the existence of relevant complaint mechanisms. A range of these mechanisms may exist. For example, some regulatory bodies accept complaints about the personal-information handling practices of the companies they regulate.
AP Circuits shall investigate all complaints. If a complaint is found to be justified through either the internal or external complaint review process, AP Circuits shall take appropriate measures, including, if necessary, amending its policies and practices.
INFORMATION AP CIRCUITS COLLECTS AS AN EMPLOYER
Through the employment hiring process, AP Circuits shall have either or both a personal resume or application form for an individual. The information contained therein may be but not be limited to the individual’s name, address, telephone number, email address, previous employment and education history, SIN, and references. Unsuccessful applications will either be returned to the applicant or retained for a period of six months for future possible openings at the applicant’s request. After six months, the application will be destroyed through shredding.
Upon hiring, the information may be used for the staff directory – the individual’s name, home address, and home telephone number. The staff directory is provided to each person in AP Circuits’ employ for contact purposes only.
As well, the individual may be required to provide banking information to facilitate payroll processing. The individual’s name and address, TD1 information, and SIN must be provided to AP Circuits’ payroll provider to process semi-monthly payroll and provide the individual with annual T4 forms for income tax filing. The payroll provider is not at liberty to disclose any personal information without the express consent of the individual except where required by law or legislation.
After six month’s employment, individuals are eligible to participate in AP Circuits’ Health and Wellness Program. This requires the completion of an application form. The information contained therein is given to our benefits provider to facilitate handling of health claims. The information may not be disclosed by the benefits provider without the express consent of the individual except where required by law or legislation.
Other personal information collected may include performance reviews, disciplinary or reprimand notices, salary, and attendance records.
Performance reviews are conducted semi-annually. The review consists of the individual’s self-assessment and comments and their supervisor’s assessment and comments. Previous reviews are kept for a maximum of eighteen months after which time the forms are destroyed through shredding. The reviews are available to management, the individual’s supervisor, and the individual. This information will not be disclosed to any other party except with the express consent of the individual.
Should disciplinary action be required, a written summary of the meeting between the individual and supervisor or management will be recorded and kept in the individual’s personnel file. Minor actions require only anecdotal notes. More severe infractions or continual reprimands require a written summary to be signed by the individual and the supervisor or management. These documents become a permanent part of the individual’s personnel file.
Current salary, salary increases, and bonus amounts received are recorded in the individual’s permanent personnel file.
Attendance records including absences, sick days, vacation entitlement taken, and holidays are maintained and become a part of the individual’s permanent personnel file.
All information contained in an individual’s permanent personnel file shall be retained for a minimum of six months after termination of employment, but no longer than one year after termination of employment. At that time the contents of the file shall be destroyed through shredding.
Most information collected in the employment relationship will be in the written form and received by AP Circuits during the application process or upon hiring. This information is maintained in individual personnel files in a locked drawer in an office with restricted access.
AP Circuits may also maintain some records such as the Company directory, birth dates, attendance records, and salary information in electronic form. This information has restricted access and password protection.
AP Circuits will not disclose any personal information to any other individuals or organizations, except its service providers, without the express, written consent of the individual. For example, employment and salary confirmation will only be provided to a lending institution with the written consent of the individual.
The security of your personal information is a high priority for AP Circuits. We maintain appropriate safeguards and current security standards to protect your personal information, whether recorded on paper or captured electronically, against access, disclosure, or misuse.
Although we cannot take responsibility for any theft, misuse, unauthorized disclosure, loss, alteration, or destruction of data by a third party, we take reasonable precautions to prevent such unfortunate occurrences.
HOW CAN IT VERIFY MY INFORMATION?
You can check your information to verify, update, or correct it, and to have any obsolete information removed.
You can also ask to review any information AP Circuits may have retained, how it is used, and to whom it may have been disclosed by either a verbal or written request to the individual(s) responsible for compliance. Subject to certain exceptions prescribed by law, you will be given access to your personal information within a maximum for forty days from the date of the request, and will be entitled to challenge the accuracy and completeness of the information and to have it amended as appropriate. A challenge to compliance that is not met satisfactorily will be recorded on the individual’s personnel file. Should you challenge compliance and feel that your concerns have not been met by the internal process, you are eligible to take your concerns to the Alberta Government Privacy Commissioner for resolution.
AP Circuits may disclose your information as permitted or required by law; for example:
INFORMATION AP CIRCUITS COLLECTS AS A PROVIDER OF GOODS AND SERVICES
WHAT INFORMATION DOES AP CIRCUITS COLLECT AND HOW IS IT USED?
At AP Circuits, we collect two types of information: personal information and non-personal information.
Personal information means information about an identifiable individual, but does not include business contact information. Business contact information means an individual’s name, position name or title, business telephone number, business address, business email, business fax number, and other similar business information used to contact an individual in his or her capacity as an employee of an organization.
Collection means gathering, acquiring, recording, photographing, or obtaining personal information from any source, and by any means.
Disclosure means showing, telling, sending, or giving personal information to some other individual or organization, or the public.
With your consent, we may use your personal information for a number of different purposes. For example, to:
We may also collect and summarize customer information in a format that no longer identifies the individual for statistical purposes.
Personal information typically includes your name, address, phone number, credit card information, and e-mail address. You can always choose not to provide us with any of your personal information. However, if you make this choice, we may not be able to provide you with the product, service, or information you requested. For example, we can only deliver your order if you provide us with your address and phone number and a valid method of payment.
Your Implied Consent: In some cases, your consent is implied if we ask you to provide personal information with a stated purpose. For example, we can only deliver the product you have purchased if you provide us with your address and phone number.
Your Express Consent: In other cases, we will ask you to give your express consent to use your personal information to advise you of products or services that may be of interest. You always have the opportunity to “opt out” of having your information used for this purpose.
Withdrawing Your Consent: If you have “opted in”, we will always provide you the opportunity to “opt out”.
INFORMATION AP CIRCUITS COLLECTS FROM YOU
Listed here are some examples of the ways that we collect information about you and how we use it.
On-Line Purchases: When you purchase a product or service, you may need to provide us with contact and payment information (such as credit card information) so that we can process your request. Examples where we need contact information include delivery services, order confirmation, and product servicing. If we collect this information, we will also ask for your consent to use this information to send you promotional information on new products and services.
Our Web Site: With any of the services on our Web Site, we may use your personal information to contact and correspond with you and to respond to your inquiries. With your consent, we may send you, from time to time, email or other communications regarding goods or services we believe will interest you.
Our Order Form/Ordering Process: Where you are representing an organization, the contact information requested on our order form or through our ordering process, would not constitute personal information (please see the statement under What Information Does AP Circuits Collect and How is It Used? – business contact information). If you are an individual not representing an organization, your personal information would only be used to process your order and, with your consent, we may send you, from time to time, email or other communications regarding goods or services we believe will interest you.
INFORMATION AP CIRCUITS COLLECTS AUTOMATICALLY
Like many other Web Sites, we automatically collect certain non-personal information regarding Web Site users that does not identify you. Examples include the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access the Web Site, the Internet address of the Web Site from which you linked directly to our Web Site, the operating system you are using, the sections of the Web Site you visit, the Web Site pages read and images viewed, and the content you download from the Web Site.
This non-personal information is used for Web Site and system administration purposes and to improve the Web Site.
Cookies are not currently implemented on our web site. However, should we choose to implement a cookie program, it would be used to verify a returning user’s identity and would not be used for marketing purposes.
Tracking Information: We may use non-personal information to compile tracking information reports regarding Web Site user demographics and Web Site traffic patterns. We may also link tracking information with personal information voluntarily provided by Web Site users. Once such a link is made, all of the linked information is treated as personal information and will be used and disclosed in accordance with this Policy.
Links to Other Web Sites: Our Web Site may contain links to other Web Sites or Internet resources. When you click on one of those links you are contacting another Web Site or Internet resource. AP Circuits has no responsibility or liability for or control over those other Web Sites or Internet resources or their collection, use, and disclosure of your personal information.
We encourage you to read the privacy policies of those other sites to learn how they collect and use information about you.
Does AP Circuits Disclose the Information it Collects?
AP Circuits does not sell your personal information. However, we may share your information with third parties acting on our behalf or as permitted or required by law.
Disclosure to Service Providers
AP Circuits may share your personal information with certain service providers in order to provide products and services to you, to verify and validate information, and to address customer service matters. Examples of service providers include credit card issuers, delivery or courier services, and affiliates who provide services or products on our behalf. AP Circuits may also verify your personal information, including but not limited to your address and credit card information, with third party service providers.
We will use reasonable efforts to ensure that your personal information is used in a manner that is consistent with this Policy. If you do not wish us to provide your personal information to those service providers, we may be unable to process your transaction.
AP Circuits may disclose your information as permitted or required by law; for example:
How Does AP Circuits Protect My Information?
The security of your personal information is a high priority for AP Circuits. We maintain appropriate safeguards and current security standards to protect your personal information, whether recorded on paper or captured electronically, against unauthorized access, disclosure, or misuse.
Although we cannot take responsibility for any theft, misuse, unauthorized disclosure, loss, alteration or destruction of data by a third party, we take reasonable precautions to prevent such unfortunate occurrences.
How Can I Verify my Information?
You can check your information to verify, update, or correct it, and to have any obsolete information removed.
You can also ask to review any of the information that we have retained, how we use it, and to whom we have disclosed it at any time by contacting us at email@example.com. Subject to certain exceptions prescribed by law, and provided we can authenticate your identity, you will be given reasonable access to your personal information, and will be entitled to challenge the accuracy and completeness of the information and to have it amended as appropriate.
You can also ask us to change your preferences regarding how we use or disclose your information, or let us know that you do not wish to receive any further communication from us.
When is My Information Removed?
We keep your information only as long as we need it for the products and services you have requested and for a reasonable time thereafter or to meet any legal requirements. We have retention standards that meet these requirements. We destroy your information when it is no longer needed, or we remove your personally identifiable information.
You can also request that we remove your information from our records. Subject to our requirements for continued retention of your information, for example, for billing, audit or warranty purposes, we will make every reasonable effort to honour your request.
How Can I Contact AP Circuits?
AP Circuits is responsible for all personal information under its control. Our privacy manager is accountable for AP Circuits’ compliance with the principles described here. If you have any questions, concerns or complaints about the privacy policies stated here, you can:
We will respond to your request or investigate your concern as quickly as possible.
To accommodate changes in our service, technology, and legal developments, this Policy may change over time. We may add, change, or remove portions of this Policy when we feel it is appropriate to do so. Whenever we update this Policy we will change the date on the Policy to indicate when the changes were made.
2004 June 02