Policy On the Collection, Use and Disclosure Of Personal Information
1. Objective & Scope of Policy
The Karson Group is committed to respecting the privacy of its customers’ personal information and that of its employees and has prepared this Policy to inform you of our policy and practices concerning the collection, use and disclosure of personal information.
This Policy governs Personal Information collected from and about (i) individuals who are or may become Clients of The Karson Group and (ii) individuals or organizations with whom The Karson Group works with. Using contractual or other arrangements, The Karson Group shall ensure that agents, contractors or third party service providers, who may receive personal information in the course of providing services to The Karson Group as part of our business operations, protect that personal information in a manner consistent with the principles articulated in this Policy. The Karson Group offers a range of services in a number of fields including the construction, aggregate, paving, landscaping and development/investment fields. This Policy does not cover aggregated data from which the identity of an individual cannot be determined. The Karson Group retains the right to use aggregated data in any way that it determines appropriate. In the event of questions about: (i) access to your Personal Information; (ii) The Karson Group’s collection, use, management or disclosure of Personal Information; or (iii) this Policy; please contact The Karson Group Privacy Officer:
John Adshead, Chief Financial Officer & Privacy Officer
The Karson Group
3725 Carp Road
( 613) 839-2816 Phone
2. The Collection, Use & Disclosure of Personal Information
For the purposes of this Policy “Personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred or determined from such information. Personal information does not include what is considered business contact information generally found on a business card such as name, title, business number, business fax number, business e-mail address and business cell phone number.
Although the Karson group deals commonly with other companies and in those cases it does not collect personal information, we also deal with individual customers. Personal information such as name, residential address, residential telephone number, residential fax number and residential e-mail address is collected to ensure delivery and supply of our products to our individual customers. When applying for credit with the Karson Group, an individual may be asked to supply banking information, trade references and particulars about his/her credit history.
The Karson Group only collects personal information from its customers as follows:
- To contact the customer for instruction,
- To issue invoices, administer accounts, collect and process payments;
- To include its customers on our mailing list for the distribution of information concerning products and services that may be of assistance to you;
- To comply with any legal requirements,
- To establish credit limits, and/or
- For any other purpose to which the customer may consent.
The Karson Group only collects personal information from its employees as follows:
- Name, residential address, residential telephone number, date of birth and banking information for contact, accounting/payroll and benefits purposes,
- Social Insurance Number to meet federal requirements under the Income Tax Act,
- Spouses’ and dependants name(s), residential address(es) and date(s) of birth for the purpose of administering the employee benefit programs, and
- Employees use of the internet and e-mail may be monitored.
For those employees that are operating company owned vehicles:
- Driver’s License information and driver’s records/medical information are obtained and forwarded to insurance companies and/or to the Ministry of Transportation of Ontario as required,
- Driver’s License searches are conducted by the company from time to time to confirm that the employee holds a valid license, and
- Company vehicles may be equipped with satellite tracking devices that monitor the vehicles movement and when doing so, may provide data on the location of the driver of the vehicle.
If you apply for credit with The Karson Group, we may use and obtain financially-related information from other sources with your consent. For example, we may wish to contact trade references, banks or credit bureaus in order to verify your financial and personal information.
If you apply for employment at The Karson Group, we will require your personal information, as part of our review process. We normally retain information from candidates after a decision has been made, unless you ask us not to retain the information. If we offer you a job, which you accept, the information will be retained in accordance with our privacy procedures for employee records.
The Karson Group does not use personal information for advertising and marketing purposes.
The Karson Group’s use of Personal information is limited to the above purposes. The Karson Group does not sell, trade, barter or exchange for consideration any Personal information it has obtained. Unless permitted by law, no personal information is collected about an individual without first obtaining the consent of the individual to the collection, use and dissemination of that information.
Personal information will be collected, to the extent possible, directly from the individual concerned.
Personal Information may also be transferred to another company in the event of a change of ownership of all or part of The Karson Group.
Please note that there are circumstances where the use and/or disclosure of personal information may be justified or permitted or where The Karson Group is obliged to disclose information without consent. Such circumstances may include:
- Where required by law or by order or requirement of a court, administrative agency or other governmental tribunal,
- Where The Karson Group believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group,
- Where it is necessary to establish or collect monies owning to The Karson Group, Where it is necessary to permit The Karson Group to pursue available remedies or limit any damages that The Karson Group may sustain, or
- Where the information is public.
Where obliged or permitted to disclose information without consent, The Karson Group will not disclose more information than is required.
The Karson Group endeavours to ensure that any Personal information provided by customers and employees in its possession is as accurate, current and complete as necessary for the purposes for which The Karson Group uses that data. Information contained in files that have been closed is not actively updated or maintained.
The Karson Group retains personal information as long as The Karson Group believes it is necessary to fulfil the purpose for which it was collected and legal or business requirements. We are also required by law to maintain certain records for set amounts of time.
The Karson Group endeavours to maintain adequate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of personal information.
The Karson Group further protects personal information by restricting access to it to those Employees and Contractors that the management of The Karson Group has determined need to know that information in order that The Karson Group may provide services to Clients.
Among the steps taken to protect your personal information are:
- Premises security,
- Restricted file access to personal information,
- Technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access,
- Internal password and security policies, and
- Proper training of the Karson Group’s employees in respect of privacy matters.
6. Access to Personal information
The Karson Group permits access to and review of personal information held by The Karson Group about an individual by the individual concerned.
If an individual believes any personal information concerning that individual is not correct, that person may request an amendment of that information by sending a request to the person indicated in Section 1 of this Policy. The Karson Group reserves the right not to change any personal information but will append any alternative text the individual concerned believes appropriate. Where not required to be retained by The Karson Group, an individual may also request that The Karson Group delete an individual’s personal information from The Karson Group’s system and records. However, due to constraints of computer technology and the fact that The Karson Group backs up its systems, personal information may continue to reside in The Karson Group’s systems after deletion. Individuals, therefore, should not expect that their personal information would be completely removed from The Karson Group systems in response to an accepted request for deletion.
The Karson Group reserves the right to decline access to personal information where the information requested:
- Would disclose the Personal Information of another individual or of a deceased individual,
- Would disclose business confidential information that may harm The Karson Group or the competitive position of a third party,
- Is subject to solicitor-client or litigation privilege,
- Could reasonably result in: (i) serious harm to the treatment or recovery of the individual concerned; (ii) serious emotional harm to the individual or another individual; or (iii) serious bodily harm to another individual,
- May harm, or interfere with, law enforcement activities and other investigative or regulatory functions of a body authorized by statute to perform such functions,
- Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information, or
- Does not exist, is not held, or cannot be found by The Karson Group.
Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.
Where information will be disclosed, The Karson Group will endeavor to provide the information in question within a reasonable time and no later than 30 days following the request.
The Karson Group will not respond to repetitious or vexatious requests for access. In determining whether a request is repetitious or vexatious, it will consider such factors as the frequency with which information is amended, the purpose for which the information is used, and the nature of the information.
To guard against fraudulent requests for access, The Karson Group will require sufficient information to allow it to confirm the identity of the person making the request before granting access or making corrections.
7. Amendment of Practices and This Policy
This statement is in effect as of January 1, 2004. The Karson Group will from time to time review and revise its privacy practices and this Policy. In the event of any amendment, an appropriate notice will be communicated to customers, employees and others in an appropriate manner.
Members of The Karson Group include Karson Kartage & Konstruction (1994) Limited, Karson Asphalt & Paving Inc., West Carleton Sand & Gravel Inc., 368178 Ontario Limited o/a Spratt Aggregates and 862923 Ontario Inc. o/a/ J & K Hydroseeding and Mulching