Privacy Policy |
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The purpose of this document is to outline the privacy policies of WSM Information Systems Inc. ("WSM"), in order to promote privacy and protect the personal information of all individuals who interact with WSM. The Policy reflects our commitment to comply with all applicable regulatory requirements and to demonstrate leadership in privacy and data protection. "Personal information" means information about an identifiable individual, i.e., any information that relates to a natural person or allows that person to be identified. |
The WSM Information Systems Privacy Policy applies to the operations of WSM with respect to the collection, use, and disclosure of personal information.
This document sets out policies and procedures to support compliance with all relevant legislation, particularly the Personal Information Protection and Electronic Documents Act of Canada, compliance with the OECD Guidelines on the Protection of Privacy and Transborder Flows of Personal Data, and the European Union Directive (95/46/EC) on the Protection of Individuals with regard to the Processing of Personal Data and on the Free Movement of such Data.
3. Principles of Fair Information Practices
In developing this Privacy Policy, WSM strives to conform to the following principles found in the Personal Information Protection and Electronic Documents Act of Canada and Alberta.
Accountability - The Chief Privacy Officer is responsible for complying with measures that give effect to the principles stated in this Policy. The means of contacting the Chief Privacy Officer in connection with this Policy is posted on our Internet web site.
The Privacy Office maintains documentation and materials related to the policies and administrative procedures.
Identifying Purposes – The purposes for which personal information are collected shall be specified at the time of collection. Where personal information is required at WSM, the purposes, primary uses, accessibility, storage and retention periods shall be documented and the information accessible by the Chief Privacy Officer.
Consent – Personal information will be collected with the knowledge and consent of the person concerned, and directly from them, in accordance with applicable law. On such rare occasions when it is necessary to collect information without knowledge and consent, a note will be posted in the subject file to that purpose, and efforts will be made to communicate with the individual to advise them of the information collection. No information will be communicated to third parties without the consent of the subject, except as required or permitted by law.
Limiting Collection – WSM will only collect information that is necessary for the explicitly stated purpose. Any personal information provided to WSM in excess of what is necessary is not retained for any purpose.
Limiting Use, Disclosure and Retention – Personal information will not be used, made available or otherwise disclosed for purposes other than those specified, unless the consent of the individual is obtained or where WSM is compelled by law to do otherwise. WSM may use personal information if it has reasonable grounds to believe that the information could be useful in the investigation of a contravention of the laws of Canada, a province or a foreign jurisdiction. WSM may also use the information when acting in an emergency situation that threatens the life, health or security of an individual or the protection of property. Such special uses of personal information without consent will be documented and accessible to the individual in accordance with the privacy laws of Canada and Alberta.
Personal information must not be kept for periods longer than are necessary to fulfill the identified purposes.
Accuracy – WSM will ensure that the personal information it holds is as accurate as is necessary for the purposes stated. With respect to information that may not be current, we will corroborate with the person concerned, the personal information used in relation to a decision affecting the rights, benefits or status of an individual, before reaching any decision.
Safeguards – WSM will put in place appropriate safeguards to protect against unauthorized access to personal information, as well as use, destruction and modification of data.
Openness – The policies and procedures of WSM with respect to the management of personal information are described in this document and accessible to the public through our corporate web site.
Individual Access – Individuals have the right to obtain confirmation of whether or not WSM has personal information relating to them, subject to applicable law. Individuals may request access to their own personal information, and WSM will respond to the request no later than thirty days, in the format requested, subject to reasonable availability. While it is our policy not to charge for personal information, WSM reserves the right to charge reasonable fees for onerous requests.
Challenging Compliance – Any individual may challenge the compliance of WSM to any of the principles set forth in this Policy, and to its privacy procedures. The Chief Privacy Officer will investigate all challenges and attempt to resolve them. Individuals will be made aware of possible recourse that they might also have under applicable law and policy.
4. Accountability and Organization
The Chief Privacy Officer (CPO) is accountable for this Privacy Policy and for its implementation in WSM Information Systems Inc. The CPO is accountable to the Chief Executive Officer of the Company and his delegate.
5. Access
WSM encourages informal access to information by the concerned person in the regular course of business, but in no way wishes to substitute informal procedures in a manner that would deprive an individual of their rights under relevant law and policy. When an individual wishes to access the personal information about them that is held by WSM Information Systems Inc., they may either contact privacy@kisekaeworld.com, or write Kisekae World
If an individual obtains personal information and wishes to contest its accuracy, he or she may request a change or deletion of certain items. This request will be routed to the office of the Chief Privacy Officer. All reasonable requests will be honored.
Requests by individuals for their own personal information will be honored at no cost. WSM does reserve the right, in exceptional circumstances where extensive information has been requested and which requires excessive time and effort, to charge the same rates as are charged under the Access to Information Act of Canada, and shall so inform the data subject before completing the request.
6. Complaints
If an individual is not satisfied with the results of an information request, or if the individual is unsatisfied in any way with the WSM Privacy Policy, with WSM compliance with this Policy or with law, he or she may complain to the Chief Privacy Officer for a review of the issue. The Chief Privacy Officer will investigate all cases, conduct a review of the findings, and establish a dialogue with the individual to resolve the complaint.