4 Grey Walls Agency Inc.
At 4 Grey Walls Agency Inc., we are committed to providing our clients and customers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients and customers, protecting their personal information is one of our highest priorities.
We will inform our clients and customers of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
Scope of this Policy
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of 4 Grey Walls Agency Inc.
Personal Information – means information about an identifiable individual, without limitation, name, age, physical and/or mailing address, phone number, email address, medical information and credit card information. Personal information does not include contact information (described below).
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that 4 Grey Walls Agency Inc. complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the client or customer voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect customers and members information that is necessary to fulfill the following purposes:
• To verify identity;
• To verify creditworthiness;
• To identify client or customer preferences;
• To deliver requested products and services;
• To enrol the client in a program;
• To ensure a high standard of service to our clients and customers;
• To meet regulatory requirements;
Policy 2 – Consent
2.1 We will obtain clients and/or customers consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client, customer and/or member voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client and/or customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs and the marketing of new services or products and the customers and/or clients does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients, and/or customers can withhold or withdraw their consent for 4 Grey Walls Agency Inc. to use their personal information in certain ways. A client’s or customer’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the customer and/or client in making the decision.
2.5 We may collect, use or disclose personal information without the client and customer knowledge or consent in any of the limited circumstances permitted by PIPA.
Policy 3 – Using and Disclosing Personal Information
3.1 Subject to policy 3.3, we will only use or disclose client or customer personal information where necessary to fulfill the purposes identified at the time of collection.
3.2 We will not use or disclose client or customer personal information for any additional purpose unless we obtain consent to do so.
3.3 We may from time to time use third party services to store, manage and analyze your personal information to fulfill the purposes described in this policy or such other purposes to which you have consented.
Policy 4 – Retaining Personal Information
4.1 If we use client or customer personal information to make a decision that directly affects the client or customer, we will retain that personal information for at least one year so that the client or customer has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client or customer personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that client or customer personal information is accurate and complete where it may be used to make a decision about the client, customer and/or members or disclosed to another organization.
5.2 Clients or customers may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’ or customers’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client and customer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that client, customer and/or members personal information is appropriately protected by SSL technology.
6.3 We will use appropriate security measures when destroying client, customer and/or members personal information.
Policy 7 – Providing Clients, Customers, Members Access to Personal Information
7.1 Clients and customers have a right to access their personal information, subject to limited exceptions provided for in PIPA.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell client or customer how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client or customer of the cost and request further direction from the client or customer on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the client or customer in writing, providing the reasons for refusal and the recourse available to the client or customer.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer, Tanya Wallace, is responsible for ensuring 4 Grey Walls Agency Inc.’s compliance with this policy and the Personal Information Protection Act.
8.2 Clients and customers should direct any complaints, concerns or questions regarding 4 Grey Walls Agency Inc.’s compliance in writing to the Privacy Officer.
Contact information for 4 Grey Walls Agency Inc.’s Privacy Officer: