Jacques Whitford is committed to respecting and protecting the privacy and confidentiality of the personal information of our clients. Jacques Whitford recognizes the important principles for the protection of personal information set out in the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”) and the legislation recognized as “substantially similar” to PIPEDA, enacted in the various provinces. This policy outlines how Jacques Whitford manages our client’s personal information and safeguards our client’s privacy, in accordance with these principles.

Personal Information
Personal information is any information about an identifiable individual. Personal information does not include the name, title, business address, business email, business telephone number, or business fax number of an employee of an organization.

Jacques Whitford collects and uses personal information from our clients and potential clients for the purpose of providing them with consulting and engineering services. Jacques Whitford may also collect and use information to bill our clients and to ensure their satisfaction with our services. We also may collect and use personal information for the purpose of providing marketing materials about our services. The type of personal information that Jacques Whitford collects and uses depends on the services being requested.

Wherever possible we collect information directly from the individual but sometimes we may obtain information for other sources such as: insurance companies, government agencies or registries, the individual’s employer, medical professionals or from other third parties where permitted law. In order to assist us in making credit decisions about clients we may also request information about them from consumer reporting agencies.

Jacques Whitford shall generally only disclose client information to a third party:

• in order to provide services on the client’s behalf and in accordance with client instructions;

• for the purposes of collecting fees owed to Jacques Whitford;
• in order to conform to obligations imposed by law or statutes;
• to meet an emergency requirement;
• to subcontractors and agents in the course if a contract of services for us;
• in connection with a reorganization, merger or amalgamation with another entity, provided that the information disclosed continues to be used for the purposes stated above by the entity acquiring that personal information; and
• where the client has consented to such disclosure or as permitted by law. 

Consent
Jacques Whitford is committed to obtaining consent where required by law, for the collection, use and disclosure of personal information. In obtaining consent, Jacques Whitford shall consider the principles of PIPEDA and shall obtain express consent where the personal information is of a sensitive nature. Jacques Whitford will notify the client, at the time of or before the collection of personal information, of the purposes for which Jacques Whitford will be using and disclosing the information. Further, we understand that consent may be given by an individual or an authorized individual.

It should be noted that in certain circumstances Jacques Whitford will not be required to obtain consent to collect, use and disclose personal information. Examples of such exceptions are:

• when the collection or use is in the interest of the individual and consent cannot be obtained in a timely manner;
• in emergencies;
• where the information is publicly available as specified by the regulations of PIPEDA;
• if knowledge or consent would compromise the availability or accuracy of the information and collection is required to investigate a breach of an agreement or contravention of a federal or provincial law;
• to collect a debt;
• to comply with the rules of court relating to the production of information; and
• in other circumstances where permitted or required by law.

Subject to any contractual, legal or other limitations, an individual may contact the Privacy Officer at any time to withdraw their consent.

Accountability
Jacques Whitford takes responsibility for all personal information under our control. We have designated a Privacy Officer to be accountable for Jacques Whitford’s compliance with the principles in this Privacy Policy, whose contact information is set out below. Further, we have developed policies and practices to protect our client’s personal information that is in our care and have trained our staff about such policies and practices.

Limiting Collection, Use, Disclosure and Retention
Jacques Whitford collects personal information only for the purposes stated in this Privacy Policy and in accordance with the legislation. We do not use or disclose personal information for purposes other than those for which it was originally collected unless we first obtain consent to do so. Jacques Whitford retains personal information only for as long as necessary for the fulfillment of those purposes for which it was collected.

Accuracy
Jacques Whitford is committed to maintaining accurate, up-to-date and complete personal information. If an individual becomes aware of any changes to their personal information, they should inform Jacques Whitford and we will update this information in our records. An individual may contact our Privacy Officer, at the address set out below, to check and correct personal information.

Safeguards
Jacques Whitford has created and implemented appropriate physical, organizational and technical measures to protect the personal information that we collect and retain. The nature of the security measures we use varies depending on the sensitivity of the personal information that we have collected. With regard to the disposal and destruction of personal information, we take precautions to prevent any unauthorized parties from gaining access to an individual’s personal information in our care, including the shredding of such information.

Openness
Jacques Whitford is committed to making information about our policies and practices relating to the management of personal information, understandable and readily available. Should any questions arise regarding Jacques Whitford’s collection, use and maintenance of personal information please contact our Privacy Officer at the address set out below.

Individual Access
Upon request, we will inform individuals of the existence, use and disclosure of their personal information and we will give them access to such information within a reasonable amount of time. Jacques Whitford reserves the right to confirm the identity of the person seeking access before complying with the request and may charge a client a reasonable fee for responding to such a request. An individual is also able to contact the Privacy Officer to challenge the accuracy and completeness of the personal information in our records and Jacques Whitford will amend the records in a timely manner.

Challenging Compliance
If an individual wishes to challenge our compliance with this Privacy Policy or make a privacy complaint generally, please contact our Privacy Office at address set out below. We will investigate complaints received by us and respond in a timely manner. If the complaint is found to be warranted, then we will take appropriate measures to resolve the matter.

Privacy Officer
jacqueswhitford.com