CREDO CONSULTING INC.’S PRIVACY POLICY

Scope and Application

The principles that form the basis of Credo Consulting Inc.’s privacy policy are interrelated. Credo will adhere to the principles as a whole. Each principle should be read in conjunction with the commentary below. As permitted by the PIPEDA (Personal Information Protection and Electronic Documents Act), the commentary in our privacy policy reflects personal information issues specific to Credo.
The scope and application of Credo’s privacy policy are as follows:

• Credo’s privacy policy applies to personal information collected, used, or disclosed in the course of our commercial activities.
• Credo’s privacy policy applies to the management of personal information in any form whether oral, electronic or written.
• Credo’s privacy policy does not impose upon Credo any limits on the collection, use or disclosure of the following information by our firm:
  1. non-personally identifiable information;
  2. the name, title, business address and/or telephone number of an employee of an organization or of an individual who is actively carrying on a business. Such information appears regularly on an individual’s business card and as such constituted tombstone information that falls outside of the realm on information that is characterized as personal;
  3. other information about an individual that is publicly available and is specified by regulation pursuant to the Personal Information Protection and Electronic Documents Act (Canada).
• The application of Credo’s privacy policy is subject to the requirements and provisions of the Personal Information Protection and Electronic Documents Act (Canada), the regulations enacted thereunder, and any other applicable legislation or regulation.

Definitions

collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.

consent: Voluntary agreement for the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of Credo. Implied consent is consent that can reasonably be inferred from an individual's action or inaction.

disclosure:Making personal information available to a third party.

employee: An employee of or independent contractor to Credo.

personal information:Information about an identifiable individual, but does not include the name, title, business address or telephone number of a person carrying on commercial activity or an employee of an organization, and does not include descriptive, factual information about an organization.

respondent: A member of the public who provides personal information to Credo in the course of a survey conducted by Credo. For example, a respondent is an individual who discloses personal information to Credo in the course of quantitative or qualitative marketing or social research.

third party: An individual or organization outside of Credo.

use: The treatment, handling, and management of personal information by and within Credo or by a third party with the knowledge and approval of Credo.

The Principles of Privacy

Principle 1 - Accountability

Credo is responsible for personal information under its control and shall designate one or more persons who are accountable for Credo's compliance with the following principles.

Responsibility for compliance with the provisions of Credo’s privacy policy rests with the Credo’s privacy officer who can be reached by e-mail at privacy@credoconsulting.ca or by mail at 2625 Benedet Drive, Mississauga, Ontario, L5J 4H6. Other individuals within Credo may be delegated to act on behalf of the Privacy Officer or to take responsibility for the day-to-day collection and/or processing of personal information.

Credo is responsible for personal information in its possession or control and shall use contractual or other means to provide a comparable level of protection while information is being processed or used by a third party.

Principle 2 - Identifying Purposes for Collection of Personal Information

Credo shall identify the purposes for which personal information is collected at or before the time the information is collected.

Credo collects personal information from the public only for the following purposes:

1. to conduct quantitative or qualitative research;
2. to understand respondent opinions to establish suitability for further quantitative and qualitative research; and,
3. to meet legal and regulatory requirements.

Further reference to "identified purposes" mean the purposes identified in this Principle.

Credo shall specify orally, electronically or in writing the identified purposes to the respondent at or before the time personal information is collected in a survey or other research study. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated Credo representative who can explain the purposes.

When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is permitted or required by law, the consent of the respondent will be acquired before the information will be used or disclosed for the new purpose.

Credo may provide clients or other third parties with information from any survey, in aggregate form; in aggregate form it is impossible to identify an individual respondent's personal information.

Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of an individual are required for the collection, use, or disclosure of personal information, except where inappropriate.

Participation by respondents in survey research is always voluntary. When a respondent agrees to participate in a survey, he/she gives consent to the interview by participating.

Generally, any personal information collected in the course of an interview is not disclosed to third parties. However, occasionally, a client sponsoring a research project may want to contact respondents directly. In these cases, Credo explains the reason for the disclosure to the respondent and obtains express permission from the respondent before making any such disclosure.

A respondent is always: 1) free to choose whether or not to participate in a survey; 2) free to choose not to answer any specific questions; and, 3) free to discontinue participation at any time.

In obtaining consent, Credo will use reasonable efforts to ensure that a respondent is advised of the identified purposes for which personal information will be used or disclosed. The identified purposes shall be stated in a manner that can be reasonably understood by the respondent.

Generally, Credo will seek consent to use and disclose personal information at the same time it collects the information. However, Credo may seek consent to use and/or disclose personal information after it has been collected, but before it is used and/or disclosed for a new purpose.

In determining the appropriate form of consent, Credo will take into account the sensitivity of the personal information and the reasonable expectations of its respondents.

The participation of a respondent in a quantitative or qualitative study may constitute implied consent for Credo to collect, use and disclose personal information for the identified purposes.

Principle 4 - Limiting Collection of Personal Information

Credo shall limit the collection of personal information to that which is necessary for the purposes identified by Credo. Credo shall collect personal information by fair and lawful means.

In conducting surveys, Credo limits the amount and type of personal information it collects. We collect only the amount and type of information needed for the purposes identified to individuals.

Credo collects personal information about an individual primarily from that individual or a member of that individual's household. Except as permitted by law, Credo will only collect personal information from external sources (such as client organizations) if individuals have consented to such collection.

Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information

Credo shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

Credo may disclose a respondent's personal information to:

1. a client where the respondent has consented to such disclosure;
2. third party engaged by Credo to perform functions on its behalf;
3. a public authority or agent of a public authority if, in the reasonable judgment of Credo, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or
4. a third party or parties, where the respondent consents to such disclosure or disclosure is required or permitted by law.

Only Credo’s team members with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about respondents.

Credo shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where a respondent may have to be re-contacted for purposes of clarifying responses to a survey, or to seek additional responses, Credo shall retain the personal information for a period of time that is reasonably sufficient to allow this re-contact.

Credo shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.

Principle 6 - Accuracy of Personal Information

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Personal information used by Credo shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a respondent.

Credo shall update personal information about respondents and employees as necessary to fulfill the identified purposes or upon notification by the individual.

Principle 7 - Security Safeguards

Credo shall protect personal information by security safeguards appropriate to the sensitivity of the information.

Credo shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held.

Credo shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

All of Credo’s team members with access to personal information shall be required to respect the confidentiality of that information.

Principle 8 - Openness Concerning Policies and Procedures

Credo shall make readily available to individuals specific information about its policies and procedures relating to the management of personal information.

Credo shall make information about its policies and procedures easy to understand, including:

• the title and address of the person or persons accountable for Credo's compliance with its privacy policy and to whom inquiries and/or complaints can be forwarded;
• the means of gaining access to personal information held by Credo;
• a description of the type of personal information held by Credo, including a general account of its use; and
• a description of what personal information is made available to related organizations (e.g. Credo’s parent company, Bellatore or sister company Pareto).

Principle 9 - Individual Access to Personal Information

Upon request, Credo shall inform an individual of the existence, use, and disclosure of his or her personal information and shall give the individual access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Upon written request to the Credo’s privacy officer, Credo will inform an individual of the existence, use and disclosure of his/her personal information and shall be given access to that information.

In certain situations, Credo may not be able to provide access to all the personal information that it holds about a respondent. For example, Credo may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, Credo may not provide access to information if disclosure would reveal confidential commercial information.

In order to safeguard personal information, a respondent may be required to provide sufficient identification information to permit Credo to account for the existence, use and disclosure of personal information and to authorize access to the individual's file. Any such information shall be used only for this purpose.

Credo shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual's file. Where appropriate, Credo shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.

Respondents and employees can obtain information or seek access to their individual files by contacting the Credo’s privacy officer.

Principle 10 - Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Credo's compliance with its privacy policy.

Credo shall maintain procedures for addressing and responding to all inquiries or complaints from its respondents regarding Credo's handling of personal information.

Credo shall, on written request, inform its respondents about the existence of these procedures as well as the availability of complaint procedures.

The person or persons accountable for compliance with the Credo privacy policy may seek external advice where appropriate before providing a final response to individual complaints.

Credo shall investigate all complaints concerning compliance with its Privacy Policy. If a complaint is found to be justified, Credo shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. The respondent shall be informed of the outcome of the investigation regarding his or her complaint.

Additional Information

For more information regarding Credo’s privacy policy, please contact Credo’s privacy officer by e-mail at privacy@credoconsulting.ca or by mail at 2625 Benedet Drive, Mississauga, Ontario, Canada, L5J 4H6

Please visit the Privacy Commissioner of Canada's website at www.privcom.gc.ca.