1643434 Alberta Ltd. Operating as Rock-N-Wash™
Personal Information Protection Policy
At Rock-N-Wash®, we are committed to providing our clients, customers and or members with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, customers & or members, protecting their personal information is one of our highest priorities.
While we have always respected our clients, customers and or members privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result Alberta Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how Alberta businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our clients, customers & or members 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.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices
we will follow in protecting clients’, customers’ and or members’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’, customers’ and or members’ personal information and allowing our clients, customers and or members to request access to, and correction of, their personal information.
Scope of this Policy
This Personal Information Protection Policy applies to Rock-N-Wash® and its subsidiaries. This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Rock-N-Wash™.
Personal Information –means information about an identifiable individual E.g., including name, age, home address, e-mail address, license plate #, phone number, credit card #, employer, vehicle make-model-color 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 Sylvain Blouin 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, customer and or member 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 client, customer and or member information that is necessary to fulfill the following purposes:
• To verify identity;
• To verify creditworthiness;
• To identify client, customer and or member preferences;
• To open and manage an account;
• To improve our customer service;
• To deliver requested products and services
• To enroll the client in a program;
• To send periodic e-mails;
• To contact our clients, customers and or members for fundraising;
• To ensure a high standard of service to our clients, customers and or members;
• To meet regulatory requirements;
• To assess suitability for tenancy;
• To collect and process monthly membership payment;
• To set up fleet accounts;
Policy 2 – Consent
2.1 We will obtain client, customer and or member 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 either orally, in writing, electronically, through an authorized representative 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, customer and or member is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the client, customer and or member 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, customers and or members can withhold or withdraw their consent for Rock-N-Wash™ to use their personal information in certain ways. A client’s, customer’s and or member’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 client, customer and or member in making the decision.
2.5 We may collect, use or disclose personal information without the client’s, customer’s and or member’s knowledge or consent in the following limited circumstances:
• When the collection, use or disclosure of personal information is permitted or required by law;
• In an emergency that threatens an individual’s life, health, or personal security;
• When the personal information is available from a public source (e.g., a telephone directory);
• When we require legal advice from a lawyer;
• For the purposes of collecting a debt;
• To protect ourselves from fraud;
• To investigate an anticipated breach of an agreement or a contravention of law
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose client, customer and or member personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
Fill in any related purposes for which your organization uses or discloses personal information.
Examples that may be applicable to your organization include:
• To conduct client, customer and or member surveys in order to enhance the provision of our services;
• To contact our clients, customers and or members directly about products and services that may be of interest;
• To promote our Unlimited Monthly wash packages and or fleet accounts;
• To communicate via newsletters;
• To promote community events;
3.2 We will not use or disclose client, customer and or member personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client, customer and or member lists or personal information to other parties unless we have consent to do so.
Policy 4 – Retaining Personal Information
4.1 If we use client, customer and or member personal information to make a decision that directly affects the client, customer and or member, we will retain that personal information for at least one year so that the client, customer and or member has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client, customer and or member 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, customer and or member personal information is accurate and complete where it may be used to make a decision about the client, customer and or member or disclosed to another organization.
5.2 Clients, Customers and or Members 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. A request to correct personal information should be forwarded to the Privacy Officer or designated individual.
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’, customers’ and or members’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client, customer and or member 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 member personal information is appropriately protected: Physically securing offices where personal information is held; the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access; contractually requiring any service providers to provide comparable security measures as well as site security systems.
6.3 We will use appropriate security measures when destroying client’s, customer’s and or member’s personal information such as shredding and or burning documents, deleting electronically stored information.