- Identifying Purpose
PLB is responsible for all Personal Information under its control.
PLB is responsible for all Personal Information in its possession or custody, including information that has been transferred to a third party for processing. It will use contractual or other means to provide a comparable level of protection for information being processed by a third party.
PLB will identify and document the purposes for which it collects, uses, or discloses Personal Information at or before the time of collection.
PLB collects, uses, and discloses Personal Information concerning its partners, clients and consumers for the following purposes:
- Providing products, services and information of interest to customers;
- Distributing documents or material containing information interest to customers;
PLB will make a reasonable effort to specify the identified purposes, orally or in writing, to the individual from whom the Personal Information is collected, either at the time of collection or after collection, but before use. PLB will state the identified purposes in such a manner that an individual can reasonably understand how the information will be used or disclosed.
PLB will identify any new purposes which may arise for the collection, use or disclosure of Personal Information at or before the time the Personal Information is collected.
If a new purpose arises in respect of Personal Information already collected, PLB will identify the new purpose prior to the use or disclosure of the Personal Information.
PLB collects and uses Personal Information concerning its employees to provide them with information which is relevant to their work, terms of employment, or other employment-related activities. PLB only discloses Personal Information concerning its employees for employment-related activities.
Personal Information will only be collected, used, or disclosed with the knowledge and consent of the individual, except in emergencies and on other occasions permitted or required by law.
The way in which PLB seeks consent, including whether express or implied consent, may vary depending upon the sensitivity of the information and the reasonable expectations of the individual.
PLB will seek consent for the use or disclosure of information at the time of collection. In certain circumstances, PLB may seek consent after the information has been collected but before use.
PLB will not require an individual, as a condition for supplying its services, to consent to the collection, use or disclosure of Personal Information beyond that required to fulfill legitimate purposes.
In certain circumstances, as permitted or required by law, PLB may collect, use or disclose Personal Information without an individual’s knowledge or consent. These circumstances include Personal Information:
- Which is publicly available;
- Where collection or use is clearly in the individual’s interests and consent cannot be obtained in a timely manner;
- Which is required to investigate the breach of an agreement or the violation of a law;
- Required to act in an emergency that threatens the life, health or safety of an individual;
- Which may be useful for debt collection;
- To comply with a subpoena, warrant or court order.
PLB will limit the amount and type of Personal Information collected to that which is necessary for identified purposes and will only collect Personal Information by fair and lawful means.
Personal Information will 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 will only be retained for as long as necessary to fulfil the identified purposes.
Personal Information which has been used to make a decision about an individual will be retained long enough to allow the individual access to the information after the decision has been made and, in the event of an access request or a challenge, long enough to exhaust any recourse an individual may have under the law. Where Personal Information is no longer required to fulfill the identified purposes, it will be destroyed, deleted, or kept anonymous.
PLB will use its best efforts to ensure that Personal Information is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
PLB will use its best efforts to protect personal information through security measures appropriate to the sensitivity of the information.
PLB will protect Personal Information with measures appropriate to the sensitivity of the information.
PLB will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification regardless of the format in which the information is held. PLB will make its employees aware of the importance of maintaining the confidentiality of Personal Information, and will exercise care in the disposal or destruction of Personal Information to prevent unauthorized parties from gaining access to the information.
Depending on the format of the Personal Information, security measures may include physical precautions such as locking file cabinets and restricting access to cabinets, offices and files, organizational measures such as security clearances and limiting access on a need-to-know basis, and technological measures such as passwords and encryption.
PLB will respond to all individual written requests within a reasonable period of time, usually about ten (10) business days, following the complexity of the request and the information, and will assist any individual who informs PLB that he/she needs assistance in preparing a request. PLB may require an individual to provide additional information which will assist it in providing an account of the existence, use, and disclosure of Personal Information.
PLB will usually provide the requested information without charge. However, PLB reserves the right to impose a charge, following the scope of the request and the measures needed to retrieve information. PLB will inform the individual of the approximate amount of the charges for responding to the request and will not retrieve the information until payment is made. Requested information will be provided in a form that is generally understandable. Where possible, PLB will indicate the source of the information.
If an individual successfully demonstrates the inaccuracy or incompleteness of Personal Information, PLB will amend the information as required. If a challenge is not resolved to the satisfaction of the individual, PLB will record the substance of the unresolved challenge. Where applicable, PLB will advise third parties having access to the information of any amendments or unresolved challenges.
In certain situations, PLB may refuse a request or restrict access to all the Personal Information it holds about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law. The reasons for denying or restricting access will be provided to the individual upon request, where permitted by law. These may include:
- Information containing references to other individuals;
- Confidential commercial information;
- Information which, by its nature, must remain confidential;
- Information collected in the course of investigating a breach of an agreement;
- Information collected in the course of a dispute resolution process;
- Information that is subject to client-attorney privilege; or
- Any portion of information which for, one or more of these reasons, may not be readily severable from the information as a whole.
PLB International inc.
1361, rue Graham-Bell
Attn: Chief Privacy Officer
PLB will investigate all written complaints. Should it find that a complaint is justified, PLB will take all appropriate steps to correct the information and amend the policy or practice as required.