PRIVACY POLICY

Accolade Consulting Group, Inc.

OUR POLICY RESPECTING YOUR PRIVACY AND THE PROTECTION OF PERSONAL INFORMATION

Introduction

Accolade Consulting Group Inc.’s (ACGI’s) ongoing commitment to protect the privacy and confidentiality of your personal information is addressed in this Privacy Policy. Our policy complies with the requirements of the Personal Information Protection and Electronic Documents Act of Canada (PIPEDA), and the Canadian Standards Association Model Code for the Protection of Personal Information.

This Privacy Policy explains our commitment to respect and protect your personal information. We want you to know why we need your personal information, how the confidentiality of this information is protected, and how you can find out what information concerning you is recorded. Accolade Consulting Group Inc. (ACGI) respects the privacy rights of our clients, partners and employees, and has always been committed to protecting any personal information in our possession or control. We have adapted our Privacy Policy to guide how we collect, use, disclose, and safeguard the personal information we require in the course of fulfilling our professional responsibilities and operating our business.

While ACGI has always taken the privacy and confidentiality of our clients and our partners and employees very seriously, we have developed this Privacy Policy to clearly define our ongoing commitment to protecting privacy rights. Certain practices discussed in the Policy reflect requirements set out in both federal and provincial privacy legislation that came into effect on January 1, 2004. Our goal is to respond to the requirements of the law and to be responsive to our clients, partners and employees - who expect us to demonstrate a commitment to respecting their privacy and protecting their personal information.

Principle 1 – Accountability for personal information in our possession

ACGI is accountable for all personal information in our possession or control. This includes any personal information that we receive directly (from individual clients, partners and employees), as well as personal information that we may receive indirectly (through corporate and government clients). We have established policies and procedures aimed at protecting personal information. We have educated our employees about our Privacy Policy, and their role in protecting your personal information. ACGI is responsible for your personal information under its control. We have appointed a Privacy Officer who is accountable for ACGI’s compliance to this Privacy Policy. If you have questions about our privacy practices, feel free to contact our Privacy Officer (Bill Panopoulos) at bill@acgi.ca or 1.519.281.2455.

Principle 2 – ACGI will inform you why we are collecting your personal information when the information is collected

We ask you for your personal information so that we can:

understand your needs
determine if our products and services meet your needs
inform you about our products and services
comply with the law

Of course, you can choose not to provide us with some or all of your personal information. However, this choice may not enable us to provide you with the product, service, or information that you requested or that could otherwise be offered to you.

Client Information

In most instances, ACGI will collect, use or disclose personal information only to provide professional services to clients. Each professional services agreement includes an explanation of why we require information, what use will be made of it and with whom it may be shared in order to provide our professional services.

Employee Information

We collect personal information from our partners in order to comply with laws, provide them with benefits, and to improve on programs, policies and employee relations.

We also collect personal information from individuals seeking to work with ACGI.

When we collect personal information, we inform you of the reasons why we require such information, what use will be made of it and with whom it may be shared.

Principle 3 – ACGI will collect, use or disclose personal information about you only with your informed consent

Consent

Your knowledge and consent are required for the collection, use, or disclosure of your personal information. We only collect, use, or disclose personal information for purposes we believe you would consider appropriate under the circumstances. When you become a client of ACGI, we may use your name and address for general mailing purposes. We believe you would also expect us to contact you to advise you of new and existing services that may be of interest to you. From time to time, we will inform you of such services via direct marketing. Direct marketing material is usually delivered to you by mail, telephone or electronic means. You may choose to not receive these offers and have your name deleted from our direct marketing lists.

How Will We Ask for Consent?

Client Personal Information

The Terms and Conditions of every professional services agreement include a discussion about how ACGI may use and disclose your personal information. By signing the agreement, you will be providing your consent to the collection, use and disclosure described in the Terms and Conditions.

Partner and Employee Information

Forms and applications used to provide human resources-related services to partners or employees will describe the purposes for which personal information is required and with whom it will be shared, and will allow for you to consent to the collection, use and disclosure as described.
Employment candidates will also be advised of the purposes for which their personal information is being collected and you will be provided an opportunity to consent to the collection, use and disclosure as described.

What happens if you choose not to give us your consent? What if you withdraw your consent at a later date?

You always have the option not to provide your consent to the collection, use and distribution of your personal information, or to withdraw your consent at a later stage. Where a client chooses not to provide us with permission to collect, use or disclose personal information, we may not have sufficient information to provide you with our services. Where a partner, employee or candidate for employment chooses not to provide us with permission to collect, use or disclose personal information - we may not be able to employ you or to provide you with benefits.

Principle 4 – ACGI limits the amount and type of personal information we collect.

When possible, we will limit the collection of client and employee personal information to that which is required to provide our services or operate our business.

Principle 5 – ACGI will use and disclose your personal information only for the purposes for which we have your consent. We will keep personal information only as long as necessary to accomplish these purposes.

Use of Personal Information

Except as set out in this policy, or as required by law, ACGI does not sell or disclose any of your personal information to any other organization, and ACGI will not transmit personal information to third parties without first obtaining your written consent to do so. ACGI may, however, disclose information in the following cases:

to our lawyer
to a police force, if required by law
to comply with a subpoena, a warrant, or an order made by a court or other body with appropriate jurisdiction or to comply with rules of conduct required by regulatory bodies
to a person authorised by a law or collective agreement
to a government agency which can oblige us to do so
in emergency situations in which the life, health or safety of a customer is in danger
to all other persons authorized by law
to an authorized contractor providing service to you
to an agent retained by ACGI in connection with the collection of the your account
to credit grantors and reporting agencies
to investigative bodies or government institutions on our initiative when we believe the information concerns a breach of an agreement, or a contravention of a federal, provincial, or foreign law, or we suspect the information relates to national security or the conduct of international affairs
to a government institution that has requested the information, identified its’ lawful authority, and indicates that disclosure is for the purpose of enforcing, carrying out an investigation, or gathering intelligence relating to any federal, provincial or foreign law, or
to a third party or parties, where the client consents to such disclosure

If we intend to use your personal information for a purpose not previously identified to you, we will obtain your prior consent.

Limiting Use, Disclosure, and Retention

We do not use or disclose your personal information for any purposes other than those for which it was collected, except with your consent or as required by law.

In compliance with professional standards, we keep a record of the work performed by us. These records, or “working papers” may include personal information. Working papers are safeguarded against inappropriate access, as discussed under Principle “7”.

Personal information collected from individuals seeking employment with ACGI will be retained by ACGI indefinitely, so that ACGI may contact you about positions that may also be of interest to you.

Principle 6 – ACGI will endeavour to keep the personal information in our possession or control highly accurate.

In order to provide you with a professional level of service and with appropriate benefits, the personal information that we collect about you must be accurate, complete and current. From time to time, you may be asked to update your personal information. You are encouraged to advise us of any changes to your personal information that may be relevant to the services we are providing to you.

Employees and candidates should contact ACGI should they need to update their personal information.

Principle 7 – ACGI protects your personal information with safeguards appropriate to the sensitivity of the information.

Your personal information is secure within ACGI. We have comprehensive security controls to protect against non-authorised access, use, alteration, duplication, destruction, or disclosure. We protect your personal information by using physically secure facilities, industry standard security tools and practices, and clearly defined internal policies and practices. Security measures are in place to protect the loss, misuse and alteration of the information under our control. Personal information collected is stored in a secure operating environment that is not available to the public (e.g., restricted access premises, locked rooms and filing cabinets). To prevent unauthorized electronic access to personal information, we maintain collected information in a secure environment.

Principle 8 – ACGI will be open about the procedures used to manage your personal information.

The most up-to-date version of our privacy policy is available in its entirety at www.acgi.ca or by contacting our Privacy Officer (Bill Panopoulos) at bill@acgi.ca or 1.519.281.2455.

Principle 9 – At your request, ACGI will advise you of what personal information we have in our possession or control about you, what it is being used for, and to whom and why it has been disclosed.

As a client, you have the right to review and obtain a copy of your personal information on record in our individual offices by contacting us.

As a partner or employee, you also have the right to review and obtain copies of your personal information on record by contacting us.

In most instances, you will receive a response to your request within 30 days. If you have any concerns about the access provided to you, you are encouraged to contact our Privacy Officer (Bill Panopoulos) at bill@acgi.ca or 1.519.281.2455.

Principle 10 – You may challenge ACGI’s compliance with this Privacy Policy.

ACGI will respond to individual complaints and questions relating to privacy. We will investigate and attempt to resolve all complaints.

To challenge compliance with this Policy, please forward your concerns in writing to our Privacy Officer. We will ensure that a complete investigation of your complaint has been undertaken and will report our findings to you in most instances within 30 days.

INTERNET RELATED POLICIES

When you visit www.acgi.ca without interacting with the site, your personal information and e-mail address are not recorded. As a visitor, you do not have to submit any personal information in order to use our company website.

We do not send unsolicited e-mail. However, we will require personal information when you request information on the products and services offered by ACGI. If you add your name to an e-mail subscriber's list on our website, you authorize ACGI to send to you personalized messages from time to time. These messages contain information about services offered by ACGI that we think may be of interest to you. At no time do ACGI or any third parties have access to your confidential information. You may cancel your subscription to these e-mail messages at any time.

The site collects only personally identifiable information that is specifically and voluntarily provided by visitors. Such information may consist of, but is not limited to - your name, current job title, company address, email address, telephone and fax numbers.

We do not usually seek sensitive information (e.g., data relating to race or ethnic origin, religious beliefs, criminal record, physical or mental health, or sexual orientation) from visitors. We will, where necessary, obtain visitors' explicit consent to collect and use such information.

We use standard Web server log files, to help us count visitors and evaluate our site's technical capacity. We use this information to find out how many people visit our web site and to make our pages more useful to our visitors.

When you leave our web site: This policy discloses the privacy practices for our Web site. Once you link to another site, you are then subject to the privacy and security policies of the new site. We encourage you to read the Privacy Policies of all Web sites you visit, especially if you share any personal information.

We know that protecting your privacy is important to you. That is why it is so important to us.
If you have any questions or concerns about your privacy and our role in protecting it,
please contact our Privacy Officer (Bill Panopoulos) at bill@acgi.ca or 1. 519.281.2455.