ACCOUNTABILITY
Pearson Bus Sales Limited (Pearson) is responsible for personal information under its control and has a designated company manager who is accountable for the company's compliance with the following principles:
- Accountability for Pearson compliance with the PIPEDA is that of the Director of Operations or the Director of Human Resources, even though other persons within the company may be responsible for the day to day collection and processing of personal information. In addition, other persons within the company may be delegated to act on behalf of the directors noted above.
- Pearson is responsible for personal information that is in its possession or custody, including information that has been transferred to a third party for processing. Pearson uses contractual and other means to provide a comparable level of protection where information is processed by a third party.
- Pearson has implemented policies and practices to give effect to the principles as set out in Part 1 of the Act, including:
• Implementing procedures to protect personal information
• Establishing procedures to receive and respond to inquiries and complaints
• Training staff and communication to staff about the company's policies and practices, and
• Developing information to explain the Company's policies and procedures.
IDENTIFYING PURPOSE
The purposes for which personal information is collected shall be identified by Pearson at or before the information is collected.
- Pearson documents the purposes for which personal information is collected. These purposes are limited to the following
• To develop and market transportation products tailored to the interests of our customers
• To provide safe and cost efficient transportation products
• To ensure the comfort and safety of passengers
• To resolve customer concerns and complaint
• To recruit, train and retain a highly motivated workforce, including the administration of compensation
• As required by law
- Pearson will specify the identified purpose in writing at or before the time of collection to the individual from whom the personal information is collected.
- Personal information that has been collected by Pearson will not be used for a purpose not previously identified without further consent, unless the new purpose is required by law.
- Pearson employees collecting personal information will be pleased to explain the purposes for which the information is being collected.
CONSENT
The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate.
• Pearson will seek consent for the collection of personal information wherever possible at the time information is collected.
• Pearson will make a reasonable effort to ensure individuals are advised of the purposes for which information will be used and will state purposes in such a manner that individuals can reasonably understand how the information will be used or disclosed.
• Pearson will not require an individual to consent to the collection, use or disclosure of information beyond that which is required to meet legitimate purposes.
• Where any personal information that might be considered sensitive is collected, only express consent will be used.
COLLECTION LIMITATIONS
The collection of person information shall be limited to that which is necessary for the purposes identified by Pearson. Pearson will specify the type of information collected in its regularly updated Guide to Information Handling (see below).
Pearson will collect personal information only by fair and lawful means.
Pearson's Guide to information handling
Pearson will collect only the following personal information about CUSTOMERS;
• Name, address and telephone number and e-mail
• Details of past sales
• Any other information provided by the customer to assist in planning or providing services to the customer
• Information obtained from the customer or to provide comfort and safety (emergency contacts, age, medical, dietary or similar information)
• Information provided by the customer or by the company required to address a customer concern or complaint
• Information required for billing purposes or payment collection
• Any information required by law
Pearson will only collect the following personal information about EMPLOYEES
• Name, home address and telephone number, emergency contacts, next of kin, dependents
• Age, sex, education, training, experience, driver licensing, trades accreditation licensing, employment history, references
• Years of employment, salary & benefits, performance evaluations
• Information required for the administration of group insurance plans and Workplace Safety & Insurance (workers compensation
• Any information required by law
LIMITING USE, DISCLOSURE & RETENTION
Personal information shall not be used or disclosed for purposes other than for which it was collected, except with the consent of the individual or as required by law. Person information shall be retained only as long as necessary for the fulfillment of those purposes.
• Pearson will document any new purpose for using personal information and obtain further consent before use.
• Pearson will save information for a minimum of one year or for as long as it is relevant to the proper operation of the Company. Personal information that 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.
• When personal information is no longer required to fulfil the identified purpose, it will be destroyed under the quidelines prescribed by the company. (safeguard)
ACCURACY
Person information shall be as accurate, complete and up-to-date as is necessary for the purpose for which it is to be used.
• Pearson will ensure that information is sufficiently accurate, complete and up-to-date to meet required purposes and to minimize that inappropriate information may be used to make a decision about an individual.
• Pearson will not routinely update personal information unless this is necessary to fulfill the purposes for which the information was collected.
SAFEGUARDS
Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
• Pearson will protect all personal information, regardless of format against loss or theft as well as unauthorized access, disclosure, copying, use, or modification. More sensitive information will be safeguarded by a higher level.
• Sensitive Material will be stored in locked filing cabinets, or when stored on computers, pass words will be required. Pearson will make employees aware of the importance of maintaining the confidentiality of personal information.
• Pearson will take care in the disposal or destruction of personal information using shredding machines when possible to prevent unauthorized parties from gaining access to it.
OPENNESS
Pearson will make specific information about its personal information management policies and practices readily available to individuals. Individuals will be able to acquire information about policies and practices without unreasonable effort and in a form that is generally understandable.
This information will include:
• The name or title, and the address, of the person who is accountable for Pearson policies and practices and to whom complaints or inquiries can be forwarded.
• How to gain access to personal information held by the company.
• A description of the type of personal information held by Pearson, including a general account of its use.
• A copy of Pearson's Policy and
• What personal information is made available to related organizations.
Pearson Bus Sales Limited,
157 Queen Street North ,
Tilbury, Ont. NOP 2LO.
Director of Operations: Jim Pearson
Director of Human Resources: Andrea Pearson
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