WCD Privacy Policy

Purpose

This Privacy Policy provides direction to WCD Individuals on collection, storage, and use of personal information.

As an Alberta-based business and employer, WCD is obligated to comply with the Alberta Personal Information Protection Act (PIPA). As a contracted services provider, WCD may also be obligated on certain projects to comply with elements of other privacy laws governing our clients, such as the Alberta Freedom of Information and Protection of Privacy Act (FOIP), the Alberta Health Information Act (HIA), the Personal Information Protection and Electronic Documents Act (PIPEDA) or similar legislation applicable in the client’s jurisdiction.

WCD is committed to protecting all personal information entrusted to the Company. It is the responsibility of every WCD Individual to conduct activities in accordance with this policy.

Applicability/Scope

This policy applies to all employees, contractors, temporary employees, consultants, and authorized agents of WCD.

This policy applies to all personal information collected, stored, and used for WCD business. Personal information is any information about an identifiable individual such as an individual’s name, home address, personal phone number, age, sex, marital or family status, financial information, medical information, educational history, and any identifying number such as social insurance number, driver’s license number and employee number.

Information available in the public domain is not covered in this policy.

Compliance

All Individuals are required to report suspected breaches of policy immediately to the Company’s designated Privacy Officer at privacyofficer@wcdconnect.com for investigation.

When in doubt about compliance, it is the Individual’s responsibility to explicitly request advice and confirm compliance prior to taking any potentially non-compliant action.

WCD uses systems and/or procedures to track information handling (e.g., custody transfer transactions, record format changes, creation / access / change / deletion of records) which it may monitor, audit, search, record and/or archive at any time and for any reason.

Failure to comply with this policy may result in suspension, termination of employment or contractual relationship, and/or legal action. Information may be provided to applicable law enforcement authorities to the extent required or permitted by law.

Consent

WCD shall ask for consent to collect, use, or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized (e.g., employer-employee relationship) or required by law. WCD may infer consent in cases where the individual volunteer’s personal information for an obvious purpose.

Collection

WCD collects personal information to facilitate the management of the employer- employee relationship, including the hiring process.

As a service provider WCD collects only that personal information required to provide services to individual clients or as provided in client contracts and statements of work.

Use and Disclosure

WCD shall use and disclose personal information only for the purpose for which the information was collected, except as authorized by law (e.g., to provide service, deliver documents, conduct payroll transactions).

Information Security

Security and retention of personal information shall be in accordance with WCD’s Information Governance Policy and the Information Security Policy. Unless otherwise agreed, WCD retains personal information only as long as is required to fulfil the purposes for which the information was collected, or as legally required.

Access to Personal Information

Individuals and clients of WCD have the right to access to one’s own personal information held in WCD’s custody, subject to some exceptions as allowed in PIPA. WCD will respond to requests as per time limit and other expectations set out in PIPA.

Personal information may be requested by emailing WCD’s Privacy Officer at privacyofficer@wcdconnect.com. WCD will advise the requestor of any fees that may apply before processing the request.

WCD makes reasonable effort to ensure that personal information is accurate and complete.

WCD relies on Individuals and clients to notify of changes to personal information that may affect the relationship with WCD. WCD may require that requests for correction be made in writing.

Privacy Breach

WCD is committed to protecting all personal information entrusted to the Company. In the unlikely event of a privacy breach, action shall be in accordance with WCD’s Privacy Breach and Response Plan.

Contact Information

Questions or concerns about WCD’s Privacy Policy should be directed to the Company’s designated Privacy Officer at privacyofficer@wcdconnect.com.

Individuals may also contact the Office of Information and Privacy Commissioner of Alberta directly as outlined at www.oipc.ab.ca, by email at generalinfo@oipc.ab.ca, or by phone (Calgary: 403-297-2728, Edmonton: 780-422-6860, toll free: 1-888-878-4044).

Related Documents

This policy applies in conjunction with WCD’s Information Governance Policy and the Information Security Policy.

The Privacy Breach and Response Plan outlines the actions to be taken in the event of a privacy breach.

Procedural documents provide further guidance and clarity to those groups responsible for the implementation of policy controls.