Agri-Food Innovation Council (AIC) recognizes that an individual’s right to privacy is an essential right to be protected. We understand the importance in maintaining anonymity and protecting personal information in our care and control. Our relationships with those that contribute to the activities of AIC and those that participate in the services offered by AIC are founded on trust and we are committed to maintaining that trust.
What This Policy Covers
- personal information that is aggregated in such a manner that it cannot be connected to a person; therefore any personal information that has been anonymized will not fall under the protection of the PIPEDA;
- personal information consisting of the name, address and telephone number of a subscriber that appears in a telephone directory that is available to the public, where the subscriber can refuse to have the personal information appear in the directory;
- the name, title, business address, e-mail address or telephone number of an employee of an organization; or
- information that is publicly available and is specified by regulation pursuant to the PIPEDA.
Collection of Personal Information
Personal information that may be collected, used or disclosed by AIC includes but is not limited to the following:
- E-mail addresses
- Credit Card Information
- Name of Employer or Business
- Payment and Banking Information
Guidelines for Internet/Website Users
AIC does not collect identifying information about visitors to our website. We may collect non-identifying information about our visitors in order to create summary statistics and to determine the level of interest in information available on our site. This information would include such items as the date and time our site was accessed and the web browser used. AIC collects information about user’s site usage through our server log files, including IP Addresses. Our website does not link IP Addresses to any personally identifiable information. In some cases, users’ non-personal information may be automatically collected through the standard operation of AIC’s Internet servers.
Please be advised that information voluntarily disclosed online in discussion areas or other public areas of our website can be collected, used and disclosed by third parties. Any submissions made to discussion areas or other public areas on our website are done at the user’s risk and on the understanding that such information may be accessible to third parties. AIC will not be liable or held responsible for any damages that may result from such user activity.
How Personal Information is Maintained
AIC does not sell, barter, trade or give away personal information to third parties. For example, we do not provide our mailing lists to other organizations regardless of how worthwhile their causes may be.
AIC stores, maintains and discloses personal information in conformity with the requirements of the PIPEDA as described bellow.
Collection: obtaining personal information from any source, including third parties, by any means.
Consent: the granting of voluntary permission regarding the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied.
Disclosure: to make known personal information to a third party.
Personal Information: information about an identifiable individual, but does not include the name, title, or business address or telephone number of an employee of an organization.
Use: the treatment, handling and management of personal information by and within AIC.
Application of the Code
AIC applies the ten principles of the Code as follows:
- developed procedures to protect personal information;
- developed procedures to receive and respond to complaints and inquiries;
- trained our staff about our policies and practices respecting personal information; and
- developed and distributed information to our staff and others explaining our policies and procedures respecting personal information.
While AIC infrequently transfers personal information to third parties, when it does so on the consent of its stakeholders, AIC ensures that all personal information that is transferred is protected by entering into legal agreements with such third parties. These legal agreements seek to ensure that these third parties employ comparable levels of control over this personal information.
AIC is always clear and open with stakeholders regarding the intended purpose and use of information, whether at the time of collection or any time afterwards. AIC will specify either orally, electronically or in writing the identified purposes to stakeholders, at or before the time personal information is collected. Upon request, persons collecting personal information will explain these identified purposes or refer the individuals to AIC’s Membership and Subscription Coordinator who will explain the purposes.
AIC will generally only collect personal information for the following limited purposes:
- to establish and maintain our membership lists;Personal information about AIC members is recorded in order that we may contact members concerning AIC business and as required by the Canada Corporations Act.The personal information contained in our member lists assists us in reaching previous members to ask for their ongoing support and to inform them of upcoming events of interest.
We may also provide personal information concerning members to the Bank of Montreal BMO with respect to an Affinity Card program in which AIC is taking part. However, a member may opt out of participation in this program in which case, no personal information concerning the member will be provided by AIC to the Bank of Montreal.
- to establish and maintain AIC’s mailing lists:AIC’s mailing lists are used to keep individuals listed on them advised of opportunities and upcoming events such as conferences in which they may be interested.In addition, from time to time, AIC may contact stakeholders to request additional personal information. However, if a stakeholder does not wish to provide such information, there is no obligation to do so and this will not affect their relationship with us.
- to effectively provide services to our stakeholders:AIC will use personal information in order to provide products and services to stakeholders. AIC obtains and maintains sufficient personal information in order to provide these services. At any time, stakeholders are free to request that their information not be used for such marketing by providing written instruction to AIC’s Membership and Subscription Coordinator.
AIC shall not use or disclose for any new purposes, personal information that has been collected from stakeholders without first identifying and documenting the new purposes and obtaining the prior consent of the stakeholder, unless required by law.
Furthermore, if a stakeholder wishes to be advised of the personal information we have related to them, they can contact us at the address set out below.
AIC will only collect, use or disclose information with the full knowledge and consent of our stakeholders, or as otherwise permitted by the Act. Consent may be given verbally, in writing or electronically, depending on the nature of the product or service. We will make reasonable efforts to ensure that the stakeholders understand how their information will be used.
- In obtaining consent, AIC will use reasonable efforts to ensure that a stakeholder is advised of the identified purposes for which personal information collected will be used or disclosed. AIC will state the identified purposes in a manner that can be reasonably understood by the stakeholder.
- AIC will seek consent to use and disclose personal information at the same time it collects the information. However, if AIC decides to use personal information of a stakeholder for a new purpose, AIC will obtain consent from the stakeholder before the personal information is used or disclosed for a new purpose.
- AIC will only require stakeholders to consent to the collection, use or disclosure of personal information as a condition to AIC providing products or services to stakeholders, if such collection, use or disclosure is required in order to fulfill the identified purposes.
- As well, we may periodically request written confirmation from stakeholders to ensure that the personal information collected and maintained by us is up-to-date and accurate. We also may ensure that we have stakeholders continuing consent to the use and retention of their personal information.
- AIC may collect personal information without the knowledge and consent of a stakeholder under the following circumstances:
- where such collection is clearly in the interests of an individual, and consent cannot be obtained in a timely manner;
- where it is reasonable to expect that collection of the personal information with the knowledge or consent of the individual would compromise the availability or the accuracy of the information, and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province; where such collection is solely for journalistic, artistic or literary purposes; or
- such personal information being collected is publicly available and is specified by the regulations.
- AIC may use personal information without the knowledge and consent of stakeholders under the following circumstances:
- where in the course of its activities, AIC becomes aware of information that it has reasonable grounds to believe could be useful in the investigation of a contravention of the laws of Canada, a province or a foreign jurisdiction that has been, is being or is about to be committed, and the information is used for the purpose of investigating that contravention;
- where the personal information is used for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual;
- where the personal information is used for statistical or scholarly study or research – purposes that cannot be achieved without using the information; the information is used in a manner that will ensure its confidentiality; it is impracticable to obtain consent; and the organization informs the Privacy Commissioner of the use before the information is used;
- where the personal information being collected is publicly available and is specified by the regulations; or
- where the personal information was collected under 1) or 2) of the paragraph relating to collection without consent.
- AIC may disclose personal information without the knowledge and consent of stakeholders under the following circumstances:
- where the disclosure is being made to, in the Province of Quebec, an advocate or notary or, in any other province, a barrister or solicitor who is representing AIC;
- for the purpose of collecting a debt owed by the individual to AIC;
- where the disclosure is required to comply with a subpoena or warrant issued or an order made by a court, person or body with jurisdiction to compel production of information, or where the disclosure is required to comply with rules of court relating to the production of records;
- where the disclosure is being made to a government institution or part of a government institution that has made a request for the information and identified its lawful authority to obtain the information.
- A stakeholder may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Stakeholders may contact AIC at the address below for more information.
- Please be advised that at no time does a stakeholder’s relationship with AIC require that they provide us with their personal information if they do not wish to do so.
Note: In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of individuals. 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. For example, seeking consent may be impractical for a charity or a direct marketing firm that wishes to acquire a mailing list from another organization. In such cases, the organization providing the list would be expected to obtain consent before disclosing personal information. (Clause 4.3 of Schedule 1 of the Act)
AIC stakeholders can be assured that any information AIC collects will be limited to the details necessary for the purposes identified. Our standardized application forms ensure that only information that is required is collected.
Limiting Use, Disclosure and Retention
AIC does not use personal information for purposes other than those for which it was originally collected, unless it has first obtained the consent of the person from whom such information was received or if required to do so by law. AIC will only retain such information for as long as it is needed and only for the fulfillment of the purposes for which it was originally collected or as required by law. AIC does not sell or share mailing lists or other member information with third parties. The following policies shall apply:
- Only those AIC staff and employees whose duties reasonably so require, are granted access to personal information about stakeholders.
- AIC will only keep personal information as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances where personal information has been used to make a decision about a stakeholder, AIC shall retain, for a period of time that is reasonably sufficient to allow for access by the stakeholder, either the actual information or the rationale for making the decision.
- AIC will destroy, erase or make anonymous any personal information that is no longer necessary or relevant for the identified purposes or required to be retained by law. Nevertheless, AIC will maintain reasonable and systematic controls, schedules and practices for the retention and destruction of personal information.
- AIC will destroy or erase personal information at the written request of the stakeholder to whom the information relates.
AIC will make reasonable efforts to ensure that a stakeholder’s information is kept accurate, current and complete, updating it as necessary for the information’s original purpose. In the case of a discrepancy, we will respect a stakeholder’s right to provide us with the most current information. It is, however, a stakeholder’s responsibility to promptly inform AIC of any changes to their personal information. Stakeholders may check and correct their personal information by contacting the Membership and Subscription Coordinator at the address below.
Safeguarding Stakeholder Information
At AIC, we take the security of stakeholder information seriously, and make every effort to safeguard personal information:
- AIC will implement security safeguards to protect personal information against such risks as theft or loss, unauthorized access, copying, use, modification or destruction.
- AIC will protect personal information with physical security measures, such as locked cabinet storage and restricted access to areas where personal information is stored.
- AIC will protect personal information with internal employee security measures, including restricted computer access, employee confidentiality agreements, and limited access to where personal information is stored. AIC will also ensure that any of our employees who deal with personal information are properly trained and are aware of the necessary and appropriate measures required to protect personal information.
- AIC will use security safeguards, including password and encryption security measures, to prevent unauthorized access to personal information stored on computer systems.
- Any personal information kept by AIC is disposed of or destroyed once it is no longer needed to meet the purposes for which it was collected. AIC will ensure appropriate measures regarding the destruction or disposal of personal information so as to prevent unauthorized parties from gaining access to the personal information.
AIC stakeholders can be assured that information about our policies and practices with the respect to the management of information is readily available. If you have any concerns, please contact AIC’s Membership and Subscription Coordinator, so that we can address the issue or explain the policies in further detail.
At any time, AIC stakeholders can request to be informed of the existence, use, disclosure of their personal information, and, subject to applicable prohibitions or exemptions stipulated by the Act, will be given access to information.
When an individual has inquired as to whether personal information concerning him or her has been collected, used or disclosed, AIC may require that the individual provide sufficient information to allow AIC to provide an account of the existence, use and disclosure of personal information. However, the information provided in response to AIC’s request shall only be used for the purpose of providing the account. A request in writing or e-mail to AIC’s Membership and Subscription Coordinator at the address below must be made.
Upon written request, we will inform the individual if we have any of their personal information in our care and control, as well as providing them with the details of such personal information. In responding to requests, AIC may charge a nominal fee. If we are unable to provide an individual with access to all of their personal information, then the reasons for the denial of access will be provided.
Upon request, AIC will provide an account of the use and disclosure of personal information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, AIC will provide a list of organizations to which it may have disclosed personal information.
We are also committed to ensuring that the personal information that is collected and maintained by us is correct, accurate and complete.
In certain situations, AIC may not be able to provide access to all of the personal information that it holds of a stakeholder. Exceptions include but are not limited to personal information that is prohibitively costly to provide, information that contains references or identifies the personal information of other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons or information that is subject to solicitor-client or litigation privilege. AIC will provide the reasons for denying access upon request.
As well, stakeholders can challenge the completeness of their personal information under our care and control. Where a stakeholder can successfully demonstrate that an error in the accuracy or completeness of their personal information exists, we will amend their personal information appropriately. Any unresolved differences to accuracy or completeness shall be noted in their file. Where appropriate, AIC will transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.
As noted above, AIC has designated its Membership and Subscription Coordinator as the officer who is responsible for the day-to-day care and control of personal information. The Membership and Subscription Coordinator will receive and respond to all information requests regarding our privacy policies or about stakeholder inquiries regarding their personal information under our care and control. Equally, if a stakeholder wishes to be added or removed from any of the lists that AIC maintains, please write or email a request to the Membership and Subscription Coordinator.
- AIC will put procedures in place to receive and respond to complaints or inquiries about its policies and practices relating to the handling of personal information.
- AIC will inform individuals about the existence of these procedures as well as the existence of relevant complaint procedures.
- AIC will investigate all complaints received and will respond in writing in a timely manner. If a complaint is found to be justified, then we will take appropriate measures to resolve the matter including, if necessary, amending our policies and proceedings.
HOW TO ADD, REMOVE OR AMEND PERSONAL INFORMATION If, at any time, stakeholders wish to amend their personal information with us or have their information removed from our records, simply inform us in writing at:
Agri-Food Innovation Council
70 George Street, 3rd Floor
Ottawa, Ontario K1N 5V9
Please note that further information can be obtained as well as a copy of the PIPEDA through the Privacy Commissioner of Canada’s web site at www.priv.gc.ca