Privacypolicy

Six Sigma Canada Inc. (Six Sigma) is committed to protecting the privacy of its clients and employees and the privacy of their personal information. We will do so through the responsible collection, use and disclosure of personal information according to the principles outlined in this Privacy Policy and the Personal Information Protection and Electronic Documents Act (PIPEDA).

1.APPLICATION AND SCOPE

1.1Six Sigmas Privacy Policy applies to its management, collection, use and disclosure of Personal Information about its customers, potential customers, employees and non-employed persons, including consultants and independent contractors, who interact with Six Sigma and the products and services that it provides.

1.2The application of this Privacy Policy is subject to requirements or provisions of any applicable legislation, regulation or agreement or the order of any court or other lawful authority.

2.DEFINITIONS

(1) Identified Purposes means those purposes as set out in section 4.2 and 4.3 of this Privacy Policy.

(2)Person means an individual, corporation, partnership, organization, or any legal entity that (i) is an employee of Six Sigma; (ii) works with Six Sigma as a consultant, contractor or otherwise; (iii) corresponds with Six Sigma; or (iv) uses, or applies to use, the products or services of Six Sigma.

(3)Personal Information means information that personally identifies an individual such as age, name, address, ID numbers, sex, ethnic origin, social status, opinions, personal records or activities. Personal Information does not include (i) information that is publicly available, such as name, telephone number or address when listed in a public directory; (ii) business contact information, such as a name, title or business address or business phone number of an employee of an organization; (iii) information collected, used or disclosed in the course of journalistic, literary or artistic activities; or (iv) aggregate information that cannot be associated with a specific person, such as demographic statistics about Six Sigma customers.

3.ACCOUNTABILITY

3.1Six Sigma is responsible and accountable for all Personal Information in its possession and control and shall use appropriate means to manage the Personal Information in its possession and control.

3.2Six Sigma shall implement policies and procedures to give effect to its Privacy Policy, including:
(a)implementing procedures to protect Personal Information and to oversee Six Sigmas compliance with its Privacy Policy and the PIPEDA;
(b)designating a Privacy Officer who is accountable for Six Sigmas compliance with its Privacy Policy and the PIPEDA;
(c)establishing procedures to receive and respond to inquiries or complaints with regard to Six Sigmas privacy policies and procedures;
(d)training or communicating to Six Sigma staff about its Privacy Policy and privacy procedures; and
(e)developing a written privacy policy to explain Six Sigmas privacy policies and procedures.

4.IDENTIFYING PURPOSES FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

4.1Six Sigma provides consulting in Six Sigma methodologies for eliminating defects, waste or quality control problems in manufacturing, service, delivery, management or other business activities.

4.2Six Sigma has collected and collects Personal Information primarily for the following purposes:
(a)to establish and maintain responsible business relations with employees, customers and other persons and to provide ongoing services;
(b)to understand persons needs;
(c)to develop, enhance, market or provide products and services to its customers and potential customers;
(d)to manage and develop its business and operations, including its relationship with consultants, contractors and other personnel and employment matters; and
(e)to meet legal and regulatory requirements.

4.3Upon request and at or before the time Personal Information is collected, those employees and persons collecting the Personal Information on behalf of Six Sigma shall explain and identify the purposes for which the Personal Information is being collected, used or disclosed or shall advise of the name and contact information of a Privacy Officer to explain and identify the purposes.

4.4Unless required by law, Six Sigma will not collect, use or disclose Personal Information in its possession and control for any other purposes then those Identified Purposes without first identifying the new purpose and obtaining the proper consent.

5.OBTAINING CONSENT

5.1The knowledge and consent of each person are required for the collection, use and disclosure of Personal Information.

5.2Generally, Six Sigma shall obtain consent to collect, use or disclose Personal Information at the same time Six Sigma collects the information. However, Six Sigma may seek consent to use or disclose the Personal Information after it has been collected, but before it is used or disclosed.

5.3In obtaining consent, Six Sigma shall use reasonable efforts to ensure that a person is advised of the purposes for which the Personal Information is being collected, used or disclosed and Six Sigma shall be clear and use language that can be reasonably understood by the person when obtaining consent.

5.4A person is deemed to have consented to the collection, use or disclosure of his/her/its Personal Information for any Identified Purpose on the happening of:
(a)The person voluntarily providing Personal Information directly to Six Sigma for the purpose of inquiring into or obtaining Six Sigmas products or services;
(b)The person provides express written consent in executing a consulting agreement with Six Sigma;
(c)The person provides express written consent solicited for a specific purpose; or
(d)The person uses the products or services provided by Six Sigma.

5.5A person may withdraw consent at any time subject to legal and contractual restrictions and reasonable notice. A person may contact Six Sigma or a Privacy Officer for more information with regard to the consequences, implications and procedures of withdrawing consent.

5.6Six Sigma may collect, use or disclose Personal Information without a persons knowledge or consent if:
(a)doing so is clearly in the best interests of the person and consent cannot be obtained in a timely manner, such as when the person is a minor, seriously ill or mentally incapacitated;
(b)seeking consent might defeat the purpose of collecting, using or disclosing the information, such as in the investigation of a breach of an agreement or a contravention of a federal or provincial law or regulation;
(c)it becomes necessary in the case of an emergency where the life, health or security of an individual or property is threatened;
(d)if it is necessary in order to collect an account receivable or a debt; or
(e)if it is necessary in order to comply with a warrant, subpoena, or court order or to comply with other legal or regulatory requirements.

6.LIMITING COLLECTION OF PERSONAL INFORMATION

6.1Six Sigma shall limit the collection of Personal Information to that which is necessary for the Identified Purposes and shall only collect Personal Information by fair and lawful means.

6.2Generally, Six Sigma collects Personal Information directly from the person but it may also collect Personal Information from other sources, including, without limitation, employers, agents, representatives, credit bureaus, personal references or other third parties that are authorized or have the right to disclose the Personal Information to Six Sigma.

7.LIMITING USE, DISCLOSURE AND RETENTION OF PERSONAL INFORMATION

7.1Six Sigma shall not use or disclose Personal Information for purposes other than those Identified Purposes except with the consent of the person or as required by law.

7.2Six Sigma shall retain Personal Information only as long as necessary for the fulfillment of the purpose for which it was collected or as required by law.

7.3Personal Information may be used, disclosed or retained by those employees, agents, consultants or contractors of Six Sigma who require access to the Personal Information for business reasons or whose duties reasonably so require.

7.4Six Sigma shall not use or disclose Personal Information to a third party that is not affiliated with or a proper designated representative of Six Sigma unless use or disclosure is in accordance with the Identified Purposes or required by law.

7.5Six Sigma may be required to disclose Personal Information to third parties that assist in providing Six Sigma products and services, including, without limitation, (i) contractors or technical support technicians or (ii) collection agencies. Six Sigma shall ensure that Personal Information disclosed to third parties shall be in accordance with this Privacy Policy.

7.6Six Sigma shall maintain reasonable and systematic controls, schedules and practices for Personal Information retention and destruction.

7.7Six Sigma shall retain Personal Information for as long as necessary to fulfill the purpose for which the Personal Information was collected or as required by law and when retention of Personal Information is no longer necessary or relevant for the Identified Purposes or required by law, Six Sigma shall ensure that the Personal Information is safely and securely destroyed or made anonymous.

8.ACCURACY OF PERSONAL INFORMATION

8.1Six Sigma shall make every reasonable effort to ensure Personal Information is sufficiently accurate, complete and up-to-date as is necessary to fulfill the specific purposes for which it was collected.

8.2The accuracy, completeness and currency of the Personal Information is dependant on the persons disclosure of such information to Six Sigma and notification to Six Sigma of any changes.

8.3A person shall be able to challenge the accuracy and completeness of the Personal Information collected and retained by Six Sigma and have Six Sigma amend it as appropriate upon providing Six Sigma with sufficient evidence to support the change requested. Six Sigma shall promptly correct or complete any Personal Information found to be inaccurate or incomplete and shall notify the person making the request if Six Sigma disagrees with the requested change.

9.SECURITY SAFEGUARDS

9.1Six Sigma shall take every reasonable precaution, appropriate to the sensitivity of the Personal Information, to protect the Personal Information collected, used and disclosed by Six Sigma.

9.2Six Sigma shall protect Personal Information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction through appropriate security measures and shall protect the Personal Information regardless of the format in which it is held.

9.3Six Sigma shall protect Personal Information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

9.4All employees of Six Sigma with access to Personal Information shall be required as a condition of employment to respect the confidentiality of Personal Information collected, used or disclosed by Six Sigma.

10.OPENNESS CONCERNING POLICIES AND PRACTICES

10.1Six Sigma has prepared this Privacy Policy to keep persons informed and shall make information about its policies and practices relating to management of Personal Information readily available to persons.

10.2Six Sigma shall be open about the purposes for its collection, use and disclosure of Personal Information and shall make information about its policies and practices easy to understand to help persons exercise choices with regard to the use and disclosure of their Personal Information.

10.3If you have any question or concerns about Six Sigmas Privacy Policy please contact a Privacy Officer for further information.

11.INDIVIDUAL ACCESS TO PERSONAL INFORMATION

11.1Upon written request, Six Sigma shall inform a person about the existence, content and use of his/her/its Personal Information and afford to the person a reasonable opportunity to review and access the Personal Information. You may send a written request to:

Six Sigma Privacy Officer
Christine Burns, Client Services
360 Stonebrook Blvd.
Tecumseh, Ontario N8N 5H1
Fax: 519.735.3224
E-mail: cburns@sixsigmacanada.net

11.2Personal Information shall be provided to the person in an understandable form within a reasonable amount of time and at minimal or no cost to the person requesting access to the Personal Information.

11.3Six Sigma may refuse a persons request to access Personal Information in certain situations, including, without limitation, the following:
(a)if providing access would likely reveal Personal Information about a third party;
(b)if providing access could reasonably be expected to threaten the life, health or security of another person;
(c)if providing access would reveal confidential information;
(d)if the Personal Information was collected in relation to the investigation of a breach of an agreement or contravention of a federal or provincial law or regulation;
(e)if the Personal Information was collected as part of journalistic, literary or artistic activities;
(f)if providing access would be prohibitively costly to Six Sigma; or
(g)if the denial to access the Personal Information is related to detection or prevention of fraud.

11.4If access to Personal Information is denied Six Sigma shall provide reasons for denying access upon request.

11.5For security reasons, Six Sigma shall require a person to provide sufficient identification information to permit access to Personal Information and any such information shall be used only for this purpose.

12.CHALLENGING SIX SIGMAS COMPLIANCE

12.1Six Sigma shall maintain procedures for addressing and responding to all inquiries or complaints from persons about Six Sigmas management and handling of Personal Information in its possession and control.

12.2All complaints shall be made in writing address to the Privacy Officer at:

Privacy Officer
Christine Burns, Client Services
360 Stonebrook Blvd.
Tecumseh, Ontario N8N 5H1
Fax: 519.735.3224
E-mail: cburns@sixsigmacanada.net

12.3The Privacy Officer handling the inquiry or complaint may seek external advise where appropriate before providing a final response to the person making the inquiry or complaint.

12.4Six Sigma shall investigate all complaints concerning compliance with Six Sigmas Privacy Policy. If a complaint is found to be justified, Six Sigma shall take appropriate measures to resolve the complaint, including, if necessary, amending its policies and procedures.

12.5A person shall be informed of the outcome of the investigation with regard to his/her/its complaint.

13.GENERAL

13.1This privacy policy is made pursuant to the provisions and principles identified in the Personal Information Protection and Electronic Documents Act and is subject to the provisions thereof as well as to any applicable legislation, regulation or agreement.

13.2Six Sigma encourages every person to review the PIPEDA for a greater understating of the privacy laws. The PIPEDA can be found at the web site of the Office of the Privacy Commissioner of Canada at www.privcom.gc.ca or by contacting the Office of the Privacy Commissioner of Canada at 112 Kent Street, Ottawa, Ontario K1A 1H3 (1-800-282-1376).

13.3Six Sigma reserves the right to amend this Privacy Policy from time to time as it deems necessary.