The CPB Canada Privacy Policy is based on these ten principles, and CPB Canada will adhere to them as a whole. Each principle should be read in conjunction with the accompanying commentary. As permitted by PIPEDA, commentary in the CPB Canada Privacy Policy has been drafted to reflect personal information issues specific to CPB Canada. 

CPB Canada will continue to review and update the CPB Canada Privacy Policy at any time to ensure it is relevant and remains current with changing industry standards, technologies, and laws.  

Scope and Application 

The scope and application of the CPB Canada Privacy Policy are as follows: 

• The CPB Canada Privacy Policy applies to personal information collected, used, or disclosed by CPB Canada in the course of commercial activities.

• The CPB Canada Privacy Policy applies to managing personal information in any form, whether oral, electronic or written.

• The CPB Canada Privacy Policy will not typically apply to information regarding CPB Canada’s corporate members. However, such information may be protected by other CPB Canada policies and procedures or through contractual arrangements.

• The CPB Canada Privacy Policy application is subject to the requirements and provisions of PIPEDA, the regulations enacted thereunder, and other applicable legislation or regulations.

• The CPB Canada Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by CPB Canada:

1. 1. Business-related information of a corporate member, non-member, or employee, such as an individual’s title, duty, business address, business email address, and business number;

1. 2. Other information about an individual that is publicly available and is specified by regulation pursuant to the PIPEDA; 

1. 3. Non-personal information that does not directly or indirectly reveal an individual’s identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information; or,

1. 4. As otherwise exempted by the CPB Canada Privacy Policy and/or applicable law.

Privacy Policy in Detail 

PRINCIPLE 1: Accountability 

1.01 CPB Canada is responsible for personal information under its control and will designate one or more persons accountable for CPB Canada’s compliance with the following principles. 

1.02 Responsibility for compliance with the CPB Canada Privacy Policy provisions rests with the CPB Canada Chief Executive Officer (CEO), who can be reached at 1-866-616-4722 or via info@cpbcan.ca. Other individuals within CPB Canada may be delegated to act on behalf of the CPB Canada Chief Executive Officer or to take responsibility for the day-to-day collection and/or processing of personal information. 

1.03 CPB Canada will make known, upon request, the title of the person or persons designated to oversee CPB Canada’s compliance with the CPB Canada Privacy Policy. 

1.04 CPB Canada is responsible for personal information in its possession or control. CPB Canada will use contractual or other means to provide a comparable level of protection while information is being processed or used by a third party. 

1.05 CPB Canada may contract with third parties in a jurisdiction not subject to PIPEDA, for example, outside Canada. In such circumstances, CPB Canada will use contractual or other means to ensure that the third party employs a comparable level of protection as established by PIPEDA while using or processing personal information provided by CPB Canada.  

1.06 CPB Canada implements policies and procedures to give effect to the CPB Canada Privacy Policy, including: 

1. Implementing procedures to protect personal information and to oversee CPB Canada’s compliance with the CPB Canada Privacy Policy;

2. Implementing procedures to receive and respond to complaints or inquiries;

3. Training employees to understand and follow CPB Canada’s policies and procedures;

4. Developing information materials to explain CPB Canada’s policies and procedures; and,

5. Review the effectiveness of the policies and procedures to facilitate compliance with the CPB Canada Privacy Policy and consider any revisions as deemed appropriate biannually.

    

PRINCIPLE 2: Identifying Purposes for Collection of Personal Information 

2.01 CPB Canada will identify the purposes for which personal information is collected at or before the time the information is collected. 

2.02 CPB Canada collects personal information only for the following purposes: 

1.  To identify individuals;

2. To establish, maintain, communicate and renew membership in CPB Canada;

3. To advertise, develop, enhance and provide marketing services and products;

4. To measure and improve the effectiveness of CPB Canada services, products and marketing endeavours;

5. To manage and develop Canada’s business operations, including personnel and employment matters;

6. To protect CPB Canada against error and fraud; and

7. To meet legal and regulatory requirements.

    

2.03 Further reference to “identified purposes” means the purposes identified in this Principle. 

2.04 Upon request, persons collecting personal information on behalf of CPB Canada will explain these identified purposes or refer the individual to a designated person within CPB Canada who can explain the purposes. 

2.05 When personal information collected is to be used or disclosed for a purpose not previously identified, the new purpose will be identified before use. Unless otherwise permitted or required by law, the individual’s consent will be acquired before their information is used or disclosed for the new purpose. 

5.02 CPB Canada may disclose an individual’s personal information to a third party who, in the reasonable judgment of CPB Canada, is seeking the information as an agent of the individual, such as: 

1. a third party involved in supplying the individual with CPB Canada products or services;

2. a third party engaged by CPB Canada to perform functions on its behalf;

3. a third party engaged by CPB Canada for the development, enhancement, marketing or provision of any of CPB Canada’s products or services;

4. a third party engaged by CPB Canada to collect the member’s or non-member’s account;

5. a credit reporting agency;

6. a public authority or agent of a public authority if, in the reasonable judgment of CPB Canada, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or,

7. a third party or parties, where the individual consents to such disclosure or disclosure is required or permitted by law.

5.03 In addition to the purposes identified in 5.02, CPB Canada may disclose personal information about an individual who is an employee: 

1. for regular personnel and benefits administration, such as the initiation, management or termination of the employment relationship; or,

2. in the context of providing references regarding current or former employees in response to requests from prospective employers.

5.04 Only CPB Canada employees with a business “need-to-know”, or whose duties reasonably so require, are granted access to personal information about members and employees. 

5.05 CPB Canada will keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about an individual, CPB Canada will retain, for a period that is reasonably sufficient to allow for access by the individual, either the actual information or the rationale for making the decision. 

5.06 CPB Canada will maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction that apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information will be destroyed, erased or made anonymous. 

PRINCIPLE 6: Accuracy of Personal Information 

6.01 Personal information will be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. 

6.02 Personal information used by CPB Canada will be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about an individual. 

6.03 CPB Canada will update personal information about individuals as necessary to fulfill the identified purposes or upon notification by the individual. 

PRINCIPLE 7: Security Safeguards 

7.01 CPB Canada will protect personal information by security safeguards appropriate to the sensitivity of the information. 

7.02 CPB Canada will protect personal information against risks such as loss or theft, unauthorized access, disclosure, copying, use, modification, or destruction through appropriate security measures, regardless of the format in which it is held. 

7.03 CPB Canada will protect personal information disclosed to third parties by contractual or other means to safeguard the confidentiality of the information and the purposes for which it is to be used. 

7.04 CPB Canada will not permit third parties to use any personal information provided by CPB Canada for their own purposes.  

7.05 CPB Canada will only permit third parties to use personal information provided by CPB Canada for specified purposes in accordance with our instructions.  

7.06 All CPB Canada employees with access to personal information will be contractually required to respect the confidentiality of that information. 

7.07 The nature of the safeguards will vary depending on the sensitivity, amount, distribution and format of the information, and the storage method. A higher level of protection will safeguard more sensitive information. 

The methods of protection will include:

1. physical measures, for example, locked filing cabinets and restricted access to offices;

2. organizational measures, for example, controlling entry to data centers and limiting access to information on a “need-to-know” basis;

3. technological measures, for example, the use of passwords and encryption; and,

4. investigative measures, in cases where CPB Canada has reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed.

PRINCIPLE 8: Openness Concerning Policies and Procedures 

8.01 CPB Canada will make specific information about its policies and procedures readily available to individuals, relating to the management of personal information. 

8.02 CPB Canada will make information about its policies and procedures easy to understand, including: 

1. the title and address of the person or persons accountable for CPB Canada’s compliance with the CPB Canada Privacy Policy and to whom inquiries and/or complaints can be forwarded;

2. the means of gaining access to personal information held by CPB Canada;

3. a description of the type of personal information held by CPB Canada, including a general account of its use; and,

4. a description of what personal information is made available to third parties.

PRINCIPLE 9: Access To Personal Information 

9.01 CPB Canada will inform an individual of the existence, use, and disclosure of their personal information upon request and will provide the individual access to that information except where inappropriate. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate. 

10.03 CPB Canada will inform individuals about the existence of these procedures and the availability of complaint procedures. 

10.04 The person or persons accountable for compliance with the CPB Canada Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints. 

10.05 CPB Canada will investigate all complaints concerning compliance with the CPB Canada Privacy Policy. If a complaint is found to be justified, CPB Canada will take appropriate measures to resolve it, including, if necessary, amending its privacy policies and procedures. An individual will be informed of the outcome of the investigation regarding their complaint. 

Website Privacy Policies  

Usage Tracking 

CPB Canada’s website may automatically record some general information about visitors, which CPB Canada may use for statistical analysis to help make the site more useful to visitors. This information might include: 

1. the internet domain for a visitor’s internet service provider, such as “company.com” or “service.ca”;

2. the IP address of the computer accessing the website, such as “ppp-55”;

3. the type of browser the visitor is using;

4. the type of operating system the visitor is using, such as Windows or Macintosh;

5. the date and time the visitor accesses CPB Canada’s site;

6. the web pages that the visitor accesses on CPB Canada’s site; and,

7. the address of the previous website the visitor accessed, if the visitor linked to CPB Canada’s website from another website.

Cookies 

CPB Canada also uses “cookies” that identify visitors as they return, which can help CPB Canada tailor information to suit a visitor’s individual preferences. A cookie is a piece of data that a website can send to a visitor’s browser, which may store the cookie on the visitor’s hard drive. The goal is to save visitors time, provide them with a more meaningful visit, and measure website activity. Cookies do not contain any personally identifying information. Many browsers, however, allow visitors to disable cookie collection or inform visitors when a cookie is being stored on their hard drive. 

Online Transactions 

CPB Canada protects the security of transactions on our website using Secure Socket Layer (SSL) encryption-based Internet security protocol. SSL offers secure communications by encrypting all data going to and from the CPB Canada website. Stripe is used to process credit card transactions; its security, standards, and regulation compliance can be referenced here. 

CPB Canada protects the security of member renewal payments by utilizing tokenized credit card information.  

External Links