- Objective & Scope of Policy
- The collection, Use & Disclosure of Personal Information
- Access to Personal information
- Web Site
- Amendment of HS Practices and this Policy
1. Objective & Scope of Policy
Hawktree Solutions (“HS”) is committed to respecting the privacy of Clients. Accordingly, we have prepared this Policy outlining our policy and practices concerning the collection, use and disclosure of Personal Information.
This Policy governs Personal Information collected from and about individuals who are or may become Clients of HS and those other individuals outside of the HS with whom we work.
In the event of questions about: (i) access to Personal Information; (ii) the collection, use, management or disclosure of Personal Information by or on behalf of HS; or (iii) this Policy, individuals should contact the HS Privacy Officer at the Head Office in Ottawa.
2. The Collection, Use & Disclosure of Personal Information
For the purposes of this Policy:
“Client” means an individual who has requested or used the services of HS or purchased product from HS, but does not include employees or contractors of HS;
"Personal Information" means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred or determined from such information, but not including any business contact information.
HS uses the verbal or written Personal Information provided by Clients to service Clients. Personal Information will be collected, to the extent possible, directly from the individual concerned. Your name, address and phone number will be stored on a secure computer server in the United States operated by Hawktree Solutions. Hawktree Solutions does not share personal information. No financial information will be stored.
Personal Information may be disclosed to third parties, from time to time, to assist HS with the administration and management of services. We will take reasonable measures to allow individuals to refuse consent or to limit their consent to sharing this information.
Where a Client does not wish to have his or her name and personal contact information disclosed to other organizations as provided in this Policy, or where a Client does not wish to receive information on other services, he or she may so inform HS. Notice must be in writing to HS to the HS Privacy Officer at the Head Office in Ottawa.
Where the Personal Information is health information the Client’s written consent will be obtained before the information is disclosed to third parties, except as otherwise specified in this Policy or by law.
HS may disclose Personal Information of Clients to organizations or individuals that perform services on behalf of HS. Using contractual or other arrangements, we will ensure that agents, contractors and other third parties who receive Personal Information in the course of providing services act in a manner consistent with this Policy, and also agree to use such information solely for the purpose of providing services to HS or on its behalf, in a consistent manner with our instructions.
Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted, or where we are obliged to disclose information without consent. Such circumstances may include:
- where required by law or by order or requirement of a court, administrative agency or other governmental tribunal;
- where we believe, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
- where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain; or
- Where the information being disclosed or used is in the public domain.
In situations where we are obliged or permitted to disclose information without consent, we will not disclose more information than is required in the applicable circumstances.
HS considers that where a person provides Personal Information to HS the person consents to our collection, use and disclosure of that Personal Information in accordance with this Policy. We may seek additional specific authorizations or consents from time to time where required by law or in situations where we consider these to be necessary or appropriate.
Subject to applicable legal or contractual restrictions to which an individual may be subject, an individual is free to refuse or withdraw his or her consent to the collection, use or disclosure of his or her Personal Information at any time upon reasonable notice in writing to HS. It should be noted that in some circumstances HS can only provide certain services if Personal Information is not made available.
HS endeavours to ensure that any Personal Information provided by Clients and in our possession is as accurate, current and complete as necessary for the purposes for which we use that data.
An individual who believes any Personal Information concerning that individual is not correct may request an update of the information. We reserve the right not to change any Personal Information but will append any alternative text the individual concerned believes appropriate. An individual may also request that we delete their Personal Information from our system and records. Note that due to technical constraints Personal Information may continue to reside in our systems, after reasonable efforts to delete it have been made.
We keep Personal Information for as long as it is required by law or for the reasons it was collected. We take reasonable steps to destroy, delete, or erase Personal Information which is no longer required.
We endeavour to maintain adequate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information.
We limit Personal Information access to the employees management has determined need to know the information in order to conduct HS activities and provide HS services and programs. Under HS policy any employee misuse of Personal Information is treated as a serious offence for which disciplinary action may be taken.
7. Access to Personal Information
HS permits access to and review of Personal Information about an individual by the individual concerned. We require sufficient information to confirm the identity of the person making the request before granting access. We endeavor to provide the information within a reasonable time.
We reserve the right to decline access to Personal Information where disclosure of the information requested
- could harm or threaten the interests and/or safety of others
- Or where the required information:
- is not readily retrievable and the burden or cost of providing it would be disproportionate to the nature or value of the information;
- does not exist, is not held, or cannot be found;
- is required not to be disclosed on any legal ground;
- is permitted by law not to be disclosed.
Where information is not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.
8. Web Site
Hawktree Solutions (HS) may collect information relating to individuals who access our Web site.
We do not share Personal Information obtained through our Web site with any third parties, except with persons who are contracted to administer our information technology requirements and who agree to comply with our policies and requirements relating to privacy and confidentiality of Personal Information.
9. Amendment of HS Practices and this Policy
This Policy is in effect as of September 2014. We will review, and may revise our privacy practices and this Policy. Policy changes will apply to the information collected from the date of the revised Policy as well as to existing information held by us.
For more information please email us.