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Customer Privacy Policy
The Advocate Group of Companies has established a customer privacy policy to ensure that your personal information is protected and that all of our practices and procedures are compliant with Bill C-6 (Canada's Personal Information Protection and Electronic Documents Act). The policy below is organized according to the principles of the Canadian Standards Association's Model Code, which forms the basis of the bill.
We invite you to address any questions you may have about personal information and our policies to our privacy officer. The Advocate Group of Companies is comprised of the following companies:
# Advocate Communications Group # Advocate Printing and Publishing # Graphic Advocate # Hector Publishing Company Limited # Maritime Press # OMG Atlantic # Our Place Recreation Centre # Reporter Publishing Limited # St. Croix Printing and Publishing Co. # The Press Room Pub and Grill # Valley Flyer Services # Weekly Press Limited
1. Accountability
Kevin Murphy is responsible for our privacy policies for both customer information and staff information. He trains all our staff in how to handle the personal information of customers. He also will be happy to provide any information about our policy and about your information, including copies of your personal information if we have that information. He can be contacted in any of the following ways:
Kevin Murphy Privacy Officer Advocate Group of Companies Box 1000 Pictou, NS B0K 1H0 Ph: 902-485-1900 Fx: 902-485-6353 Email: k_murphy@advocateprinting.ns.ca
2. Identifying Purposes
Each of the Advocate Group of Companies gathers information for different purposes.
PRINTING
In our Printing and Publishing operations we gather information: # To provide quotations on print jobs. # To deliver our products and services to our customers. # To maintain customer histories to help us better understand your printing needs and preferences. # To bill, collect and maintain payment records.
PUBLISHING
Advocate publishes a wide variety of magazines and newspapers. We gather information for these operations: # To help fulfill our subscription request. # To mail renewal notices. # To generate awareness of our other newspapers and magazines. # To facilitate navigation of our website through the use of "cookies". # To conduct readership studies. # To bill, collect and maintain payment records.
RESEARCH
Our consumer research division conducts interviews with members of the public to assess public opinion. In conducting this research, it gathers publicly available information: # To comply with industry standards on sampling methodology and quality control.
MAIL DISTRIBUTION
The Advocate Group of Companies also provides mail and flyer distribution services. To that end, it is the recipient of mailing lists provided by third parties. The information provided to use is used to process and deliver printed material on behalf of its clients. 3. Consent
The knowledge and consent of our customers are required for the collection, use and disclosure of personal information except where inappropriate.
In obtaining consent, we will use reasonable efforts to ensure that customer is advised of the identified purposes for which personal information will be used or disclosed. Purposes will be stated in a manner that can be reasonably understood.
The Advocate Group of Companies may disclose personal information without customer knowledge or consent to a lawyer representing us, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law. In the case of debt collection, only the information necessary to collect the debt is turned over (e.g., invoice details and contact information).
In general, the use of products and services by a customer constitutes implied consent for the Advocate Group of Companies to collect, use and disclose personal information for all identified purposes.
We also collect electronic information from our websites about your navigational preferences while on our websites. In some cases, digital logs of those preferences known as "cookies" are stored on your computer's website browser. Your browser has the option of denying cookies. Acceptance of cookies is assumed to be implied consent.
4. Limiting Collection
The Advocate Group of Companies limits the information we collect to that which is necessary to deliver goods and services and to meet standard billing, accounting and human resource practices.
We keep on our customer files your name, address, phone and fax numbers as well as your email address. We also record whether or not you have given us your authorization to use your personal information to promote our other products and services. We will assume you have refused this authorization unless you have given it in writing or by email. We also collect information from other sources including credit bureaus, references, and third parties who represent that they have the right to disclose the information.
5. Limiting Use, Disclosure, and Retention
We use the information you have provided to us only for the purposes outlined above, and we do not sell or lend out information to anyone else. Our employees do not have access to your records unless they are providing a service to you. Law enforcement agencies have a right under various laws to have access to the information you provided to us. We require them to provide warrants and lawful instruments before we provide them with your information.
We keep a record of your printing and subscription history in an active file for ten years. If you ask us, we will keep it in perpetuity; otherwise we will purge the files at that time.
The completed paper questionnaires from our public opinion research studies are kept for 12 months. They are then destroyed.
Databases provided to us by our clients are kept electronically on a secure computer. These database files are kept until the client has paid their bill and are then purged from the system. Clients can request that we keep them longer.
6. Accuracy
Prior to completing any work or processing a subscription we open a computerized client file. The information in this file is secure. The personal contact information is also displayed on your invoice or renewal forms. We encourage customers to verify that the information is accurate. It is not altered unless an error is detected or you inform us of a change. If you have concerns about the accuracy of our records, please speak with Kevin Murphy, our privacy officer; he will be happy to assist you.
7. Safeguards
The Advocate Group of Companies will protect your personal information by security safeguards appropriate to the sensitivity of the information. We will protect personal information against theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of format in which it is held.
Advocate will protect 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 our employees with access to personal information are required to respect the confidentiality of that information.
8. Openness
This policy, and our staff policy, are freely available from our privacy officer or from our various websites.
Upon request we will provide a description of the type of information we have in your customer or employee file and provide a general account of its use. Requests and inquiries should be made to:
Kevin Murphy Privacy Officer Advocate Group of Companies B0x 1000 Pictou, NS B0K 1H0 Ph: 902-485-1900 Fx: 902-485-6353 Email: k_murphy@advocateprinting.ns.ca
Our employee and customer privacy policies can be found at the following website addresses:
We will be happy to provide you with copies of all the records we have of your customer relationship with us. For competitive reasons, we will not provide information about our costs. If you feel that the information on your file is inaccurate, you are invited to bring it to the attention of our privacy officer and ask for it to be amended. In the event that we disagree with your view of the accuracy of the data, we will be happy to include your comments about the information into the file.
10. Challenging Compliance
We are anxious to ensure that our privacy policy meets your concerns and responds to your needs. Our privacy officer, Kevin Murphy, is available to receive your inquiries and complaints. He will investigate your request and respond to you with his findings within a reasonable amount of time (generally within 5 business days). If a complaint is found to be justified, the Advocate Group of Companies will take the appropriate measure to resolve the complaint to your satisfaction, including amending our policies and procedures.
If you are unhappy with the results of our efforts, you may complain to:
Office of the Federal Privacy Commissioner 112 Kent Street Ottawa, Ontario K1A 1H3 Toll-free: 1-800-282-1376 info@privcom.gc.ca.
Scope and Application
The above ten principles, which form the basis of the Advocate Group of Companies' privacy code are interrelated. We will adhere to the principles as a whole.
The scope and application of our privacy code is as follows:
# The code applies to personal information about our customers that we collect, use or disclose. # The code applies to the management of personal information in any form whether oral, electronic or written. # The code does not impose any limits on the collection, use or disclosure of the following information:
=> A customer's name, address, telephone number and e-mail address, when listed in a directory or available through directory assistance; => An employee's name, title, business address (including e-mail address) or business telephone or fax number; or, => Other information about the customer that is publicly available and is specified by regulation pursuant to the Personal Information Protection and Electronic Document Act.
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