1.1) Where the Company and its group of radio stations are engaged in Commercial Activities that sometimes involve the collection of personal and private information from customers, suppliers and the general public; and 1.2) Where the Company and its group of radio stations are sensitive to the collection and use of that information because of its importance to the individual from whom it was collected; and 1.3)Where the Company and its group of radio stations wish to be in compliance with certain federal legislation as it relates to the collection and use of personal private information; THE COMPANY HEREBY ENACTS THIS POLICY ON THE COLLECTION AND RETENTION OF PERSONAL PRIVATE INFORMATION.
2.1) This policy is intended to address the collection and use of information that is both personal and identifiable to an individual. Personal and Identifiable Information includes personal characteristics such as home address, telephone number, social insurance number and financial information. 2.2) For clarity, this policy is not meant to capture the collection of corporate information from other companies or businesses. 2.3) This policy shall also apply to any consultant such as lawyers and accountants that the Company may engage in the regular course of business.
SOURCE OF INFORMATION
Clients 3.1) The Media Industry is driven primarily by advertising. Private individuals often purchase ad time, which necessitates the collection of contact information and financial information for proper contract maintenance and collection. 3.2) Further, the collection of contact information allows the company to follow up with clients to offer future advertising time as it becomes available. General Public 3.3) The Radio Business is interactive in nature and engages its audience. As a result, listeners will often be invited to “call-in” for reasons such as contests or making requests. 3.4) The contact information of the caller will be recorded in order to ensure the proper collection of prizes. Upon claiming a prize, photo identification is recorded for accounting purposes. 3.5) In the past few years, Radio has expanded onto the internet to allow for more personalized listening. Information gathered through the use of our web-site on cookies can NOT identify users and is beyond the scope of this policy. Identifiable information is voluntarily provided by listeners in order to join fan clubs, participate in surveys or contests and to provide feed-back. We may use this information to provide listeners with promotional material of general interest. A listener may “opt-out” at any time and the Personal Information is removed from our data-base. 3.6) Occasionally, listeners may take offence to an item they heard, or thought they heard, on our stations and may file a complaint with the Canadian Broadcast Standards Council (CBSC). Under CBSC guidelines, we are required to respond to the complainant directly and will receive their contact information in order to comply with the regulations. 3.7) Our stations are continuously updating our talent-banks. As a result, we are provided with resumes and demos from members of the public. As a result, we require contact information in order to conduct interviews, etc. Although we do not require certain information, some individuals may also provide us with birthdates and Social Insurance Numbers which are held in the strictest confidence. Employees/Independent Contractors 3.8) To ensure proper payment and accounting of staff and contractors, we are required to collect Identifiable Information from individuals such as contact information, banking information, legal status to work in Canada, Social Insurance Numbers. 3.9) To ensure the safety of Employees and Contractors, we also collect family information to be used in the case of an emergency which occurs during work hours. Students 3.10) Our stations will often work with Universities and Colleges through their Co-Operative Education programs and will hire students for a determined work-term. 3.11) In order to determine we have hired qualified candidates, the Company will collect academic information including academic records and student numbers. 3.12) In order to ensure the effectiveness of the Co-Op program, the Company will continue to collect personal information such as performance reviews of students throughout the work-term. Students acknowledge the importance of this collection process to the program and understand that it will be shared with their academic institution whatever its content.
USE AND DISCLOSURE
4.1) None of the Personal and Identifiable Information collected shall be used for any purpose other than those outlined in this policy. 4.2) It is rare that the Company would disclose any Personal and Identifiable Information without the consent of the individual concerned. There are certain instances, however, where such consent is not required such as medical emergencies, debt collection, reporting to federal agencies (such as Canada Revenue Agency) and the Courts or during the investigation of a criminal activity.
STORAGE OF PRIVATE INFORMATION
5.1) The Company shall endeavour to keep the information covered by this Policy secure during the entire time is in the possession of the company. To that end, information is held and viewable only by employees whose job requires them to have access to that information. 5.2) As a general rule, Personal Information shall be maintained for a minimum period of seven (7) years to satisfy the audit requirements of the Canada Revenue Agency. At the end of that period, all documents shall be destroyed in a manner that is acceptable to the tax authorities. 5.3) Employee/Contractor personnel files will be maintained for the duration of employment and will be kept for the length of any limitation period in which an employee can bring suit against the Company. 5.4) Applications received from the general public will be held only as long as required to staff vacant positions.
ACCESS TO INFORMATION
6.1) Any individual who knows or suspects the Company is in possession of Personal Information is entitled to know the degree and content of that information. 6.2) In order to view the Information, an individual must arrange an appointment with the Privacy Officer in writing and must detail the nature of the information sought with as much precision as is possible in the circumstances. No information will be revealed in any manner other than during a personal meeting with the Privacy Officer. 6.3) We may charge a fee to recover any expenses incurred in processing your request. 6.4) Not every request to view personal information will be granted. There are certain legal exceptions to the disclosure of information to an individual. In the event your request has been denied, the Privacy Officer will advise you in writing of the detailed reasons for the refusal. 6.5) upon viewing the information, an individual may request that the Company correct factual errors. In the event the Company disagrees as to the accuracy of the information and the correction proposed, a notation shall be made in the file of your objection and delivered to any individual who has access to that information.
7.1) Any concerns regarding this policy or its application may be directed to the Chief Privacy Officer (CPO): Chief Privacy Officer The Evanov Radio Group 5302 Dundas St. West Toronto, ON M9B 1B2 7.2) If you wish to make a formal complaint please address your concerns in writing to the CPO. All complaints received by the CPO will be investigated and a reporting detailing the results of that investigation shall be delivered to you within 60 days. 7.3) For general inquiries regarding privacy legislation in Canada, please address your questions to: The Information and Privacy Commissioner of Canada 112 Kent Street Ottawa, ON K1A 1H3.