| Lesley Brown, Executive Director;
Updated by Paige Backman, Aird & Berlis
|Current Revision Release Date
|April 14th, 2023
|Board of Directors
|March 10th, 2021
|Next Review Date
|RELATED DOCUMENTATION / POLICIES
|The QCC recognizes the importance of our member’s right to privacy and is committed to protecting the personal information that it collects, uses, and discloses in providing online services and operating its business. The QCC is committed to keeping members personal information accurate, confidential, secure, and private.
|Personal information is defined as any factual or subjective information, recorded or not, about an identifiable individual. Examples are age, name, home addresses, and telephone number. Personal information does not include the name, title, business address or telephone number of an employee of an organization.
|The QCC’s Privacy Principles
1. Privacy Rights and Accountability
Lesley Brown, Executive Director
The Ontario Public Service – Quarter Century Club (QCC), 2 Carlton Street, Suite 1805, Ontario, M5B 1J3, CAN
Phone (416) 325-1333 ext. 2001; Email: Lesley.brown@Ontario25.ca
The Privacy Officer’s Responsibilities include:
§ Documentation of uses of personal information.
§ Ensures training of employees in correct practices
§ Compliance monitoring
§ Reporting and dispute resolution
2. Use of Personal Information
The QCC uses your personal information in a manner that is reasonably connected to the purposes for which it was collected.
The QCC obtains consent of its members for the collection, use or disclosure of personal information by the QCC where appropriate, except as permitted by law, or as required by law or a recognized authority. Sometimes an individual’s consent may be implied through his or her conduct with the QCC.
When a member provides QCC with personal information by a means such as accessing and using the Circle platform, confirming survey particulars, entering a contest, or completing a transaction, the member has consented to QCC’s collection of and usage of your personal information only for the specific purpose for which it was obtained.
There may be circumstances where a member has provided personal information for an identified purpose, and the QCC later needs to use that information for a different purpose. In such circumstances, QCC will seek your express consent to use the information for the new purpose.
How Do you Withdraw Your Consent?
If after you opt-in you change your mind, you may withdraw your consent for receiving communication from the QCC for any identified purpose at any time, subject to legal and/or contractual restrictions and reasonable notice. You may withdraw your consent for QCC to contact you by email by clicking the “unsubscribe”
5. Identifying Purposes
The QCC will provide a statement to explain the purpose(s) for the collection of your personal information whenever possible before we ask you to disclose it.
The QCC may use and disclose data which does not identify individuals for statistical purposes to assess, to develop and improve the QCC’s programs and services. If you supply us with your contact information you may receive information from QCC.
When you browse the QCC site or access the Circle platform, QCC automatically receives your computer’s internet protocol (IP) address to provide us with information that helps us learn about your use of our platform, in order to improve the platform’s value to members.
We do not sell personal information we collect. We do not disclose your personal information to anyone else without your prior knowledge or consent, except when required by a government body or agency, or as permitted by law.
Using the QCC Website
You can access the QCC website home page and browse our site without disclosing your personal data. Any personal information that website visitors voluntarily choose, is not shared with third parties. The QCC will ensure that all personal information is secured and remains confidential.
User information is collected on an aggregate, anonymous basis, which means that no personal information is associated with this data.
Using the Circle Platform
Members may access and use the Circle platform by following a link on the QCC website or by directly accessing the platform’s URL from an approved browser.
To create an account, you will need to provide personal information, including your [name, email address and/or phone number, username and a password]. You will have the option to include additional information in your user profile and to make your profile information public or private.
The Circle platform contains interactive functions, such as forums, direct message, message boards and user chats, that allow you to share information and interact with other users. When voluntarily disclosing personal information about yourself to other users, however, we are unable to control what those users may do with that content. You should take all necessary precautions to protect your private information by not posting or publishing any information that you do not want in the public domain. You don’t have to post or upload personal information; though if you choose not to, it may limit your ability to engage with other Circle users.
A cookie is a small text file containing a unique identification number that is transferred from a website to the hard drive of your computer so that the website may identify separate visitors to the site and track users’ activities on the website. A cookie will not let a website know any personally identifiable information about you, such as your real name and address.
Links on our Website
Third Party Services
In general, the third-party service providers, such as Rewards partners endorsed by QCC, will only collect, use, and disclose your information to the extent necessary to allow them to perform the services they provide to you. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located. We recommend that you read their privacy policies so that you can understand the way your personal information will be handled by these service providers.
6. Consent Collection of Your Information
QCC only collects personal information with your knowledge and consent. You can choose not to disclose any personal information we may ask you to provide. However, a decision to withhold some personal information could result in our inability to provide you with some services.
Further, you can withdraw your consent to the collection, use or disclosure of your personal information at any time, subject to any legal requirements and reasonable notice.
7. Limiting Collection
The amount and type of information that the QCC collects is limited only to that which is necessary to fulfill the purposes identified. The QCC will ask for the information it requires directly from the individual. Personal information will be collected using procedures which are fair, transparent, and lawful.
8. Limiting Use, Disclosure and Retention
The QCC will only use your personal information for the purposes for which it was collected. Your information will not be disclosed to third parties without your knowledge and consent, unless permitted or required by law.
Your personal information will be retained to fulfill the purposes for which it was collected, and in compliance with any laws surrounding information retention. If all identified purposes for the use of your personal information have been exhausted, we will destroy the information or render it unidentifiable.
To ensure the reliable delivery of services and information, your personal information will be kept accurate, complete, and up to date.
10. Safeguards and Security
The QCC works hard to ensure that our systems are secure and that they meet industry standards. To prevent unauthorized access, maintain data accuracy, and ensure the correct use of information, we have put in place the following physical, electronic, and organizational procedures to safeguard and secure the personal information that we collect:
§ Physical measures such as locked filing cabinets and restricted access to offices.
§ Organizational measures such as staff training, security clearances and restrictions on employee access to personal information; and
§ Technological measures such as the use of passwords, encryptions, firewalls, and anonymizing software. The QCC stores personal information in a secure and confidential cloud system.
§ Never allowing partners to have access to any member’s personal information. All advertising on behalf of the Reward partners is done through a secure third-party system.
12. Individual Access
You have the right to view and/or update any personal information that the QCC retains on you. Should you wish to see the full contents of your information that is on file, you may make a formal written request by mail to: Lesley Brown, Executive Director at 2 Carlton Street. Suite 1805, Toronto, Ontario, M5B 1J3. Or by email at Lesley.email@example.com
We will respond to you within thirty (30) days after your receipt of your written request or will notify you if a longer period is required by us to fully address your request, provided that an extension of thirty (30) day period is permitted by applicable privacy laws.
13. Challenging Compliance
Lesley Brown, Executive Director
OPS – Quarter Century Club (QCC)
2 Carlton Street, Suite 1805, Toronto, Ontario, M5B 1J3
416-325-1333 ext. 2001
|CHANGES TRACKING LOG
|Section added on “Using the Circle Platform”, and additional provisions to accommodate Circle, known by members as the Applaud Community.