PURPOSE
1.1) Where the Company and its group of radio stations are
engaged in Commercial Activities that sometimes involve the collection of
personal and private information from customers, suppliers and the general
public; and
1.2) Where the Company and its group of radio stations are sensitive
to the collection and use of that information because of its importance to the
individual from whom it was collected; and
1.3) Where the Company and its group
of radio stations wish to be in compliance with certain federal legislation as
it relates to the collection and use of personal private information; THE
COMPANY HEREBY ENACTS THIS POLICY ON THE COLLECTION AND RETENTION OF PERSONAL
PRIVATE INFORMATION.
SCOPE
2.1) This policy is intended to address the collection and use
of information that is both personal and identifiable to an individual. Personal
and Identifiable Information includes personal characteristics such as home
address, telephone number, social insurance number and financial information.
2.2) For clarity, this policy is not meant to capture the collection of
corporate information from other companies or businesses.
2.3) This policy shall also apply to any consultant such as lawyers and accountants that the Company
may engage in the regular course of business.
SOURCE OF INFORMATION
Clients 3.1) The Media Industry is driven primarily by
advertising. Private individuals often purchase ad time, which necessitates the
collection of contact information and financial information for proper contract
maintenance and collection.
3.2) Further, the collection of contact information
allows the company to follow up with clients to offer future advertising time as
it becomes available. General Public
3.3) The Radio Business is interactive in
nature and engages its audience. As a result, listeners will often be invited to
“call-in” for reasons such as contests or making requests.
3.4) The contact
information of the caller will be recorded in order to ensure the proper
collection of prizes. Upon claiming a prize, photo identification is recorded
for accounting purposes.
3.5) In the past few years, Radio has expanded onto the
internet to allow for more personalized listening. Information gathered through
the use of our web-site on cookies can NOT identify users and is beyond the
scope of this policy. Identifiable information is voluntarily provided by
listeners in order to join fan clubs, participate in surveys or contests and to
provide feed-back. We may use this information to provide listeners with
promotional material of general interest. A listener may “opt-out” at any time
and the Personal Information is removed from our data-base.
3.6) Occasionally,
listeners may take offence to an item they heard, or thought they heard, on our
stations and may file a complaint with the Canadian Broadcast Standards Council
(CBSC). Under CBSC guidelines, we are required to respond to the complainant
directly and will receive their contact information in order to comply with the
regulations.
3.7) Our stations are continuously updating our talent-banks. As a
result, we are provided with resumes and demos from members of the public. As a
result, we require contact information in order to conduct interviews, etc.
Although we do not require certain information, some individuals may also
provide us with birthdates and Social Insurance Numbers which are held in the
strictest confidence. Employees/Independent Contractors
3.8) To ensure proper
payment and accounting of staff and contractors, we are required to collect
Identifiable Information from individuals such as contact information, banking
information, legal status to work in Canada, Social Insurance Numbers.
3.9) To
ensure the safety of Employees and Contractors, we also collect family
information to be used in the case of an emergency which occurs during work
hours. Students
3.10) Our stations will often work with Universities and
Colleges through their Co-Operative Education programs and will hire students
for a determined work-term.
3.11) In order to determine we have hired qualified
candidates, the Company will collect academic information including academic
records and student numbers.
3.12) In order to ensure the effectiveness of the
Co-Op program, the Company will continue to collect personal information such as
performance reviews of students throughout the work-term. Students acknowledge
the importance of this collection process to the program and understand that it
will be shared with their academic institution whatever its content.
USE AND DISCLOSURE
4.1) None of the Personal and Identifiable Information
collected shall be used for any purpose other than those outlined in this
policy.
4.2) It is rare that the Company would disclose any Personal and
Identifiable Information without the consent of the individual concerned. There
are certain instances, however, where such consent is not required such as
medical emergencies, debt collection, reporting to federal agencies (such as
Canada Revenue Agency) and the Courts or during the investigation of a criminal
activity.
STORAGE OF PRIVATE INFORMATION
5.1) The Company shall endeavour to keep the information
covered by this Policy secure during the entire time is in the possession of the
company. To that end, information is held and viewable only by employees whose
job requires them to have access to that information.
5.2) As a general rule,
Personal Information shall be maintained for a minimum period of seven (7) years
to satisfy the audit requirements of the Canada Revenue Agency. At the end of
that period, all documents shall be destroyed in a manner that is acceptable to
the tax authorities.
5.3) Employee/Contractor personnel files will be maintained
for the duration of employment and will be kept for the length of any limitation
period in which an employee can bring suit against the Company. 5.4)
Applications received from the general public will be held only as long as
required to staff vacant positions.
ACCESS TO INFORMATION
6.1) Any individual who knows or suspects the Company is in
possession of Personal Information is entitled to know the degree and content of
that information.
6.2) In order to view the Information, an individual must
arrange an appointment with the Privacy Officer in writing and must detail the
nature of the information sought with as much precision as is possible in the
circumstances. No information will be revealed in any manner other than during a
personal meeting with the Privacy Officer.
6.3) We may charge a fee to recover
any expenses incurred in processing your request.
6.4) Not every request to view
personal information will be granted. There are certain legal exceptions to the
disclosure of information to an individual. In the event your request has been
denied, the Privacy Officer will advise you in writing of the detailed reasons
for the refusal.
6.5) upon viewing the information, an individual may request
that the Company correct factual errors. In the event the Company disagrees as
to the accuracy of the information and the correction proposed, a notation shall
be made in the file of your objection and delivered to any individual who has
access to that information.
CONCERNS
7.1) Any concerns regarding this policy or its application may
be directed to the Chief Privacy Officer (CPO): Chief Privacy Officer The Evanov
Radio Group 5302 Dundas St. West Toronto, ON M9B 1B2
7.2) If you wish to make a
formal complaint please address your concerns in writing to the CPO. All
complaints received by the CPO will be investigated and a reporting detailing
the results of that investigation shall be delivered to you within 60 days.
7.3) For general inquiries regarding privacy legislation in Canada, please address
your questions to: The Information and Privacy Commissioner of Canada 112 Kent
Street Ottawa, ON K1A 1H3
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