Our Commitment to the Protection of Personal Information
We, at Sustain, are committed to protecting the privacy of our customers and others with whom we do business. Personal information shall be dealt with in accordance with applicable privacy legislation in the jurisdictions in which we carry on business. For these purposes, “personal information” is any piece of information, either factual or subjective, about an identifiable individual. Personal information does not include the name, title, business address or telephone number of an employee of an organization.
Principle 1 • Accountability
An organization is responsible for Personal Information under its control and shall designate an individual or individuals who are accountable for the Company’s compliance with privacy legislation.
Sustain has appointed a Chief Privacy Officer who is responsible for the company’s compliance with privacy legislation.
Sustain employees are informed about the importance of privacy and are committed to upholding the company’s privacy practices.
Principle 2 • Identifying purposes
The purposes for which Personal Information is collected shall be identified at or before the time the information is collected.
Sustain collects personal information primarily for the purpose of providing a variety of services to its customers.
Whenever Sustain collects personal information, we will identify how the information is to be used, at or prior to the time of collection. Sustain will obtain an individual’s consent prior to using personal information for any other purpose than that identified.
Principle 3 • Consent
The knowledge and consent of the individual are required for the collection, use, or disclosure of Personal Information, except where inappropriate.
Sustain will obtain an individual’s consent to the collection, use or disclosure of personal information at or prior to the time of collection. Sustain will strive to ensure that individuals understand how their personal information will be used or disclosed.
Sustain may collect, use or disclose personal information without an individual’s knowledge or consent in circumstances when such use or disclosure is required by court order, is in connection with enforcement of laws or contractual rights, or is in connection with an emergency involving a person’s life, health or security.
Consent may be expressed in writing or implied, and in some cases, it may be provided verbally, electronically, or through an authorized representative, provided such representative has the appropriate written authorization to do so.
An individual may withdraw his or her consent to the further use of his or her personal information at any time, subject to any legal or contractual restrictions, and upon reasonable notice to Sustain. Upon request, Sustain will explain to the individual any implications of withdrawing consent.
Principle 4 • Limiting collection
The collection of Personal Information shall be limited to that which is necessary for the purposes identified. Information shall be collected by fair and lawful means.
Sustain will only collect information that is reasonably necessary for the purposes identified. Sustain may request additional personal information, if appropriate in the circumstances, provided consent is first obtained. Sustain will only collect personal information by fair and lawful means.
Principle 5 • Limiting use, disclosure and retention
Personal Information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal Information shall be retained only as long as necessary for the fulfilment of those purposes.
Sustain will not sell personal information to third parties, neither will Sustain use or disclose personal information for purposes other than those for which it was collected, without the express consent of the individual concerned, or as required by law. Sustain may employ third parties to process some aspects of personal information on its behalf. In such circumstances, appropriate assurances will be sought to ensure the personal information is similarly protected by such third parties.
Sustain has established guidelines and put procedures in place for the appropriate retention and destruction of personal information.
Principle 6 • Accuracy
Personal Information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
Sustain will strive to ensure that personal information that is used on an ongoing basis, including information that is disclosed to third parties, and information that is used to make a decision about an individual is accurate, complete and up-to-date.
Principle 7 • Safeguards
Personal Information shall be protected through security safeguards appropriate to the sensitivity of the information.
Sustain uses appropriate safeguards and security measures to protect personal information. Paper records are physically secured and access is limited to authorized personnel who are trained and aware of the requirements of the Company’s privacy practices.
Electronic files are similarly safeguarded by the limitation of access to authorized personnel and the use of appropriate electronic security devices.
Principle 8 • Openness
Sustain shall make readily available to individuals specific information about its policies and practices relating to the management of Personal Information.
Chief Privacy Officer
Sustain Design Studio Ltd.
109 Atlantic Ave.
Toronto, ON M6K 1X4
Fax. No. (416) 516-7774
Principle 9 • Individual access
Upon request, an individual shall be informed of the existence, use, and disclosure of his or her Personal Information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
An individual may request access to his or her personal information. Requests for access should be made in writing to the Chief Privacy Officer at the address provided above and should include satisfactory identification and proof of entitlement. Sustain will respond to such requests within the time period prescribed by law.
If an individual’s personal information is inaccurate or incomplete, Sustain will make the appropriate amendments, based on the receipt of satisfactory evidence.
In certain circumstances, Sustain may be unable to provide access to personal information. Where permitted, the reasons for denying access will be provided to the individual upon request. Exceptions may include: information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record; information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and information that is subject to solicitor-client privilege. The individual may then choose to challenge the decision.
Principle 10 • Challenging Compliance
An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for Sustain’s compliance.