Technology Strategies International.
CORPORATE PRIVACY POLICY

Overview

Detailed TSI Corporate Privacy Policy

The Ten Principles of Privacy

Additional Information

Overview

At Technology Strategies International (TSI), respecting privacy is an important part of our commitment to respondents and the general public. 

When you participate in survey research conducted by our organization, you can be confident that any personal information that you share with us will stay with us.

Any time you participate as a respondent in one of our surveys you can be assured that your individual responses will be kept confidential and never linked to your personal identifying information without your express permission. Your personal identifying information will never be sold to anyone. You are free to choose whether or not to participate in a survey, free to choose not to answer any specific questions and free to discontinue participation at any time.

The TSI Privacy Policy is a statement of principles and guidelines describing the level of protection of personal information provided by TSI to respondents and the general public.  The objective of the TSI Privacy Policy is to promote responsible and transparent personal information management practices in a manner consistent with the provisions of the Personal Information Protection and Electronic Documents Act ( Canada ).

TSI will continue to review its Privacy Policy to make sure that it is relevant and remains current with changing industry standards, technologies and laws.

If you have any concerns about how your privacy is protected at TSI, please contact our Privacy Officer by e-mail at privacyofficer@tsiglobalnet.com, or by mail at:

Privacy Officer, Technology Strategies International, 115 George Street, Suite 610, Oakville, Ontario, Canada, L6J 0A2. 

Detailed Corporate Privacy Policy

Scope and Application

The ten principles that form the basis of The TSI Privacy Policy are interrelated and TSI shall adhere to the ten principles as a whole.  Each principle must be read in conjunction with the accompanying commentary.  As permitted by the Personal Information Protection and Electronic Documents Act ( Canada ), the commentary in The TSI Privacy Policy has been drafted to reflect personal information issues specific to TSI.

The scope and application of The TSI Privacy Policy are as follows:

-           The TSI Privacy Policy applies to personal information collected, used, or disclosed by TSI in the course of commercial activities.

(a)  non-personally identifiable information; 

(b)  the name, title, business address and/or telephone number of an employee of an organization;

(c)  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 ).

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 TSI. 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 TSI.

personal information:  Information about an identifiable individual, but does not include the name, title, business address or telephone number of 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 TSI  in the course of a survey conducted by TSI. For example, a respondent is an individual who discloses personal information to TSI in the course of quantitative or qualitative mark eting or social research.

third party: An individual or organization outside of TSI.

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

The Ten Principles of Privacy

Principle 1 - Accountability

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

Responsibility for compliance with the provisions of the TSI Privacy Policy rests with the TSI Privacy Officer who can be reached by e-mail at privacyofficer@tsiglobalnet.com, or by mail at Privacy Officer, Technology Strategies International, 115 George Street, Suite 610, Oakville, Ontario, Canada, L6J 0A2. Other individuals within TSI 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.

TSI 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

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

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

(a)  to conduct quantitative or qualitative marketing and social research;

(b)  to understand respondent opinions to establish suitability for further quantitative and qualitative marketing and social research; and

(c)  to meet legal and regulatory requirements.

Further reference to “identified purposes” mean the purposes identified in this Principle.

TSI 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.  Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within TSI 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.

TSI 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, TSI always 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 free to choose whether or not to participate in a survey, free to choose not to answer any specific questions and free to discontinue participation at any time.

In obtaining consent, TSI shall 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, TSI shall seek consent to use and disclose personal information at the same time it collects the information.  However, TSI 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, TSI shall 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 marketing or social research study may constitute implied consent for TSI to collect, use and disclose personal information for the identified purposes.

Principle 4 - Limiting Collection of Personal Information

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

In conducting surveys, TSI 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.

TSI collects personal information about an individual primarily from that individual or a member of that individual’s household.  Except as permitted by law, TSI 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

TSI 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.

TSI may disclose a respondent’s personal information to:

(a)  a client of TSI where the respondent has consented to such disclosure;

(b)  a third party engaged by TSI to perform functions on its behalf;

(c)  a public authority or agent of a public authority if, in the reasonable judgment of TSI, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or

(d)  a third party or parties, where the respondent consents to such disclosure or disclosure is required or permitted by law.

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

TSI 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, TSI shall retain the personal information for a period of time that is reasonably sufficient to allow this re-contact.

TSI 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 TSI 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.

TSI 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

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

TSI 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.

TSI 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 TSI’s employees with access to personal information shall be required to respect the confidentiality of that information.

Principle 8 - Openness Concerning Policies and Procedures

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

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

(a)  the title and address of the person or persons accountable for TSI’s compliance with its Privacy Policy and to whom inquiries and/or complaints can be forwarded;

(b)  the means of gaining access to personal information held by TSI; 

 (c)  a description of the type of personal information held by TSI, including a general account of its use; and

 (d)  a description of what personal information is made available to related organizations (e.g. subsidiaries).

Principle 9 – Individual Access to Personal Information

Upon request, TSI 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 Privacy Officer, TSI 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, TSI may not be able to provide access to all the personal information that it holds about a respondent.  For example, TSI 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, TSI 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 TSI 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.

TSI 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, TSI 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 TSI 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 TSI’s compliance with the TSI Privacy Policy.

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

TSI 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 TSI Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

TSI shall investigate all complaints concerning compliance with its  Privacy Policy.  If a complaint is found to be justified, TSI 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 the TSI Privacy Policy, please contact the TSI Privacy Officer by e-mail at privacyofficer@tsiglobalnet.com, or by mail at Privacy Officer, Technology Strategies International, 115 George Street, Suite 610, Oakville, Ontario, Canada, L6J 0A2.

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