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QCC Privacy Policy

Document TitlePrivacy PolicyDocument No.  



Document TypePolicy Category 


Prepared By Lesley Brown, Executive Director;

Updated by Paige Backman, Aird & Berlis

Current Revision Release DateApril 14th, 2023
Approved ByBoard of DirectorsReview CadenceAnnually
Date ApprovedMarch 10th, 2021Next Review DateApril 2024




Policy Statement 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.


The QCC’s privacy policy is based on the 10 Privacy Principles contained within the Canadian Standards Association (CSA) Model Privacy Code for the Protection of Personal Information and reflects the requirements of applicable legislation including the Personal Information Protection and Electronic Documents Act (PIPEDA).


This Privacy Policy outlines the principles that the QCC will use to protect the privacy of your personal information in its possession.  It addresses the type of information collected, the reasons why such information is collected, how it is used, how its confidentiality is protected, and outlines your rights with respect to this information.

ScopeThis Privacy Policy is applicable to QCC Members, Reward Partners, Government Partners, Directors, Volunteers, Employees, Consultants, and any other persons in relationship in any capacity with the QCC.
DefinitionPersonal 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

The QCC is responsible for the personal information that it collects and holds.  To ensure this accountability, QCC has developed this Privacy Policy and has trained its employees, Directors, and partners in respect of it.  The QCC Executive Director is designated as the QCC’s Privacy Officer and has overall responsibility for the protection of personal information and for the QCC’s compliance with this Privacy Policy.


Lesley Brown, Executive Director

Privacy Officer

The Ontario Public Service – Quarter Century Club (QCC), 2 Carlton Street, Suite 1805, Ontario, M5B 1J3, CAN

Phone (416) 325-1333 ext. 2001; Email:


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.


3.      Consent

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”
button at the bottom of our emails.


4.      Acceptance of Privacy Policy

By submitting your personal information to the QCC, you signify your consent to the collection, use and disclosure of your personal information in accordance with this privacy policy.  If you do not consent to the collection, use and disclosure of your personal information in accordance with this Privacy Policy, do not provide your personal information to the QCC. Of course, certain services can only be offered to you if you provide your personal information, and therefore QCC may not be able to offer those services if you choose not to provide QCC with the required personal information.


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.


The QCC’s Use of Cookies

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

The QCC wants to ensure that the QCC website is informational and resourceful, and as such, it contains several links to third party sites, including discounts and special offers.  Although the QCC works diligently with our partners to ensure privacy and security considerations are met, the QCC can assume no responsibility for the informational practices of sites you are able to access through our site.  We encourage you to review each site’s privacy policy before disclosing any personally identifiable information.


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.


9.      Accuracy

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.


11.   Openness

This privacy policy is always available on the QCC’s website.


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


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

If for any reason you are concerned about our compliance with this Privacy Policy, you may contact our Privacy Officer in writing, by phone or by email:

Lesley Brown, Executive Director

Privacy Officer

OPS – Quarter Century Club (QCC)

2 Carlton Street, Suite 1805, Toronto, Ontario, M5B 1J3

416-325-1333 ext. 2001


This Privacy Policy may be updated from time to time.  Notice of changes to this Privacy Policy that affect members will be posted on the QCC website –


Revision(s) DateRevision(s) Made
April 2023Section added on “Using the Circle Platform”, and additional provisions to accommodate Circle, known by members as the Applaud Community.