Options Consulting Solutions, a division of Options Personnel Inc.Personal Information Protection and Privacy Policy
At Options Consulting Solutions (OCS), we are committed to providing our clients and candidates with exceptional service. The ability to provide this service involves the collection, use and disclosure of some personal information about our clients and candidates, as such; protecting this personal information is one of our highest priorities.

While we have always respected the privacy of our clients and candidates and taken measures to safeguard their personal information, we have strengthened our commitment to protecting personal information as a result of Ontario’s Personal Information Protection and Electronic Documents Act (PIPEDA). PIPEDA, which came into effect on April 13, 2000, sets out the ground rules for how Ontario businesses may collect, use and disclose personal information.

It is our objective to inform our clients and candidates of how and why we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection and Electronic Documents Policy, in compliance with PIPEDA, outlines the principles and practices we will follow in protecting clients and candidates’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients and candidates’ personal information and allowing our clients and candidates to request access to, and correction of, their personal information.

Scope
This Personal Information Protection Policy applies to Options Personnel Inc. and its subsidiary, Options Consulting Solutions.

This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Options Personnel Inc.

 

Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the client and/or candidate voluntarily provides their personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

• • The categories of personal information we may request include your name and contact information (email, address and phone number).
  • Our website also tracks your online activities, including, but not limited to, registration, submissions and information requests. You may edit, review and change your online profile after the initial sign-up is complete.

1.2 We will only collect client and/or candidate information that is necessary to fulfill the following purposes:

• To verify identity
• To verify credit, criminal, employment, educational, social media or public safety requirements on behalf of our clients
• To identify client and/or candidate preferences
• To manage a membership
• To deliver requested products and services
• To enrol the client in a program
• To send out OCS membership information
• To contact our clients or candidates for fundraising
• To ensure a high standard of service to our clients
• To meet regulatory requirements

Policy 2 – Consent

2.1 We will obtain client and/or candidate consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2 Consent can be provided through writing, electronically, orally and through an authorized representative. It can also be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the client and/or candidate voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a client and/or candidate is given notice and a reasonable opportunity to opt-out of their personal information being used for mail-outs, the marketing of new services or products, fundraising and where the client and/or candidate does not opt-out.

2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients and/or candidates can withhold or withdraw their consent for Options Consulting Solutions to use their personal information in certain ways. A client and/or candidates’ decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service. If so, we will explain the situation to assist the client and/or candidate in making the decision.

2.5 We may collect, use or disclose personal information without the clients’ or candidates’ knowledge or consent in the following limited circumstances:

• When the collection, use or disclosure of personal information is permitted or required by law
• In an emergency that threatens an individual’s life, health, or personal security
• When the personal information is available from a public source
• When we require legal advice from a lawyer
• To protect ourselves from fraud
• To investigate an anticipated breach of an agreement or a contravention of law

Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose client and/or candidate personal information where necessary to fulfill reasonably related purposes such as:

• We may disclose information to companies and individuals we employ to perform business functions and services on our behalf; such functions may include, for example, hosting our web servers, analyzing data, and providing legal, accounting and marketing services
• We may disclose information to the extent necessary or appropriate to government agencies, advisors, and other third parties in order to comply with applicable laws, the service of legal processes, or if we reasonably believe that such action is necessary to (a) comply with the law requiring such disclosure; (b) protect the rights or property of OCS or its affiliated companies; (c) prevent a crime or protect national security or (d) protect the personal safety of the users or the public.
• To conduct client and/or candidate surveys in order to enhance the provision of our services
• To contact our clients and/or candidates directly about products and services that may be of interest

3.2 We will not use or disclose client and/or candidate personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell client and/or candidate lists or personal information to other parties.

Policy 4 – Retaining Personal Information

4.1 If we use client and/or candidate personal information to make a decision that directly affects the client and/or candidate we will retain that personal information for at least one (1) year so that the client and/or candidate has a reasonable opportunity to request access to it.

4.2 Subject to policy 4.1, we will retain client and/or candidate personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 – Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that client and/or candidate personal information is accurate and complete where it may be used to make a decision about the client and/or candidate or disclosed to another party.

5.2 Clients and/or candidates may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.

5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients and/or candidates’ correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of client and/or candidate personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification, disposal or other similar risks.

6.2 The following security measures will be followed to ensure that client and/or candidate personal information is appropriately protected:

• Physically securing office locations where personal information is held
• Use of user IDs and passwords
• Database restrictions and firewalls
• Restricting employee access to personal information as appropriate

6.3 We will use appropriate security measures when destroying client and/or candidate personal information such as:

• Shredding documents
• Deleting electronically stored information

6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing security of personal information.

Policy 7 – Providing Access to Personal Information

7.1 Clients and/or candidates have a right to access their personal information, subject to limited exceptions.

• Disclosure would reveal personal information about another party however, if the information that relates to the third party can be severed or blacked-out, the requested information will be provided with such information relating to the third party as stricken or removed
• This information is protected by solicitor-client privilege (reference paragraph 9(3)(a) of Ontario PIPEDA Act)
• Disclosure of the information would reveal confidential commercial information
• Disclosure of the information could reasonably be expected to threaten the life or security of another individual or party
• The information was collected for purposes related to an investigation of a breach of an agreement or contravention of the laws of Canada or a province, and it would be reasonable to expect that the individual’s knowledge of or consent for the collection would compromise the availability or accuracy or the information

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.

7.3 Upon request, we will also tell clients and/or candidates how we use their personal information and to whom it has been disclosed if applicable.

7.4 We will make the requested information available within 60 business days, or provide written notice of an extension where additional time is required to fulfill the request.

7.5 If a request is refused in full or in part, we will notify the client and/or candidate in writing, providing the reasons for refusal and the recourse available to the client and/or candidate.

Policy 8 – Revisions to the Policy

8.1 Any updates made to this privacy policy will be posted here for your review. If we change material terms in this policy, we will provide a notice of the revised policy for 30 days on the homepage at www.optionscs.com along with a link to this page.

Policy 9 – Questions and Complaints: The Role of the Privacy Officer or designated individual

9.1 The Privacy Officer is responsible for ensuring Options Consulting Solutions’ compliance with this policy and the Personal Information Protection and Electronic Documents Act.

9.2 Clients and/or candidates should direct any complaints, concerns or questions regarding this Privacy Policy or any of OCS’ procedures, they must contact our Privacy Officer using the below details. If the complaint is justified, we will take the steps necessary to resolve the issues, including amending our Privacy Policy and practices, if necessary.

Contact Information for Options Consulting Solutions’ Privacy Officer: