Personal Information & Privacy Protection Policy
At SHIFT Magazine, we are committed to providing our subscribers, readers, and clients with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our subscribers, readers, and clients, protecting their personal information is one of our highest priorities.
Reflecting our commitment to our subscribers’, readers’, and clients’ privacy and safeguarding their personal information, we have strengthened our commitment to protecting personal and corporate information as a result of the Personal Information Protection and Electronic Documents Act (PIPEDA). PIPEDA, which came into effect on April 13, 2000, sets out the ground rules for how Canadian businesses in participating provincial jurisdictions, including Ontario, may collect, use, and disclose personal information.
We will inform our subscribers, readers, and clients of why and how we collect, use and disclose their personal information and corporate, 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 & Privacy Protection Policy, in compliance with PIPEDA, outlines the principles and practices we will follow in protecting subscriber, reader, and client personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our subscribers’, readers’, and clients’ personal information and allowing our subscribers, readers, and clients to request access to, and correction of, their personal information.
Scope of this Policy
This Personal Information & Privacy Protection Policy applies to SHIFT Magazine and its various divisions, including SHIFT TV.
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of SHIFT Magazine.
Subscriber – means persons who purchase an annual subscription of SHIFT Magazine.
Reader – means persons who purchase a single issue of SHIFT Magazine.
Readership – means both subscribers and readers of SHIFT Magazine.
Clients – means non-subscriber/reader clients, including persons attending SHIFT Magazine events and persons purchasing consulting or contracted services from SHIFT Magazine.
Personal Information – means information about an identifiable individual, including name, age, home address and home phone number, social insurance number, marital status, income, education, and 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 or PIPEDA.
Privacy Officer– means the individual designated responsibility for ensuring that SHIFT Magazine complies with this policy and PIPEDA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the subscriber or reader 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 reader information that is necessary to fulfill the following purposes:
• To verify identity;
• To identify the preferences of our readership;
• To deliver requested products and services;
• To process subscriptions and payments;
• To contact our readership about contests, events and special promotions;
• To ensure a high standard of service to our readers;
• To meet regulatory requirements.
Policy 2 – Consent
2.1 We will obtain subscriber, reader, or client 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 in writing or electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the subscriber, reader, or clients voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a subscriber, reader, or client 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, fundraising and the subscriber, reader, or client 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), subscribers, readers, and clients can withhold or withdraw their consent for SHIFT Magazine to use their personal information in certain ways. A subscriber’s, reader’s, or client’s 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 subscriber, reader, or client in making the decision.
2.5 According to PIPEDA, we may collect, use or disclose personal information without the subscribers’, reader’s, or client’s knowledge or consent in the following limited circumstances:
• For the purposes of collecting a debt;
• When the collection, use or disclosure of personal information is permitted or required by law or for the purpose of court proceedings;
• For the purpose of national security, the defence of Canada or the conduct of international affairs;
• To a government institution with the lawful authority to obtain that information, for the purpose of enforcing or administering a law of Canada;
• In an emergency that threatens an individual’s life, health, or personal security;
• For statistical, or scholarly study or research, purposes that cannot be achieved without disclosing the information;
• When the personal information is available from a public source (e.g., a telephone directory);
• When we require legal advice from a lawyer;
• 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 subscriber, reader, or client 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 readership surveys in order to enhance the provision of our services;
• To contact our readers directly about products and services that may be of interest.
3.2 We will not use or disclose subscribers’, readers’, or clients’ personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell readership or client lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use subscribers’, readers’, or clients’ personal information to make a decision that directly affects the readership or clients, we will retain that personal information for at least one year so that subscribers, readers, and clients have a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain subscribers’, readers’, and clients’ 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 subscriber, reader, and client personal information is accurate and complete where it may be used to make a decision about the subscriber, reader or client or disclosed to another organization.
5.2 Subscribers, readers, and clients 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.
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 subscribers’, readers’, or clients’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of subscriber, reader, or client 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 subscriber, reader, and client personal information is appropriately protected:
• Password protected computers;
• Restricting employee access to personal information as appropriate (i.e., only those that need to know will have access).
6.3 We will use appropriate security measures when destroying subscriber’s, reader’s, and client’s 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 Subscriber, Reader, and Client Access to Personal Information
7.1 Subscribers, Readers, and Clients have a right to access their personal information, subject to limited exceptions, including:
• To do so would likely reveal personal information about a third party.
• The information is protected by solicitor-client privilege;
• To do so would reveal confidential commercial information;
• To do so could reasonably be expected to threaten the life or security of another individual.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell subscribers, readers, and clients 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 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the subscriber, reader, or client of the cost and request further direction from the subscriber, reader, or client on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the subscriber, reader, or client in writing, providing the reasons for refusal and the recourse available to the subscriber, reader, or client.
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 SHIFT Magazine’s compliance with this policy and the Personal Information Protection and Electronic Documents Act (PIPEDA).
8.2 Subscribers, readers, and clients should direct any complaints, concerns or questions regarding SHIFT Magazine’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the subscriber, reader, or client may also write to the Information and Privacy Commissioner of Ontario.
Contact information for SHIFT Magazine’s Privacy Officer:
Dominion Outreach Centre
8A, 2016 Ogilvie Road
Ottawa ON, K1J 7N9