Unpublished Media Inc.’s protection of personal information
Unpublished Media Inc.
70 Bongard Ave.
Nepean, Ontario K2E 7Z9
Tel. (613) 883-7386
Statement of Policy
It is the policy of Unpublished Media Inc. to control the collection, use, and disclosure of personal information in accordance with all requirements set out in the Privacy Act. The Privacy Act does not apply to personal information that Unpublished Media Inc. collects, uses, or discloses.
The following requirements shall be met by Unpublished Media Inc. unless exempted by the Privacy Act.
Collection of Personal Information
Unless otherwise authorized by the Privacy Act
· No personal information shall be collected by Unpublished Media Inc. unless it relates directly to the operation of Unpublished Media Inc. World Wide Web pages, programs or activity.
· Unpublished Media Inc. shall, wherever possible, collect personal information that is intended to be used for an administrative purpose directly from the individual to whom it relates except where the individual authorizes otherwise.
· Unpublished Media Inc. shall inform any individual from whom it collects personal information of the purpose for which the information is being collected.
Retention of Personal Information
Personal information that has been used by Unpublished Media Inc. for an administrative purpose shall be retained for such period of time after it is so used as may be prescribed by regulation in order to ensure that the individual to whom it relates has a reasonable opportunity to obtain access to the information.
Accuracy of Personal Information
Unpublished Media Inc. shall take all reasonable steps to ensure that personal information that is used for an administrative purpose is as accurate, up-to-date and complete as possible.
Disposition of Personal Information
Unpublished Media Inc. shall dispose of personal information under its control in accordance with the regulations and with any directives or guidelines issued by the designated minister in relation to the disposal of that information.
Personal information under the control of Unpublished Media Inc. shall not, without the consent of the individual to whom it relates, be used or disclosed by Unpublished Media Inc. except for the purpose for which the information was obtained or compiled or for a use consistent with that purpose unless otherwise authorized by the Privacy Act. In certain circumstances personal information subject to the Privacy Act may be used or disclosed without the knowledge or consent of the individual concerned. Such circumstances include, but are not limited to personal information used or disclosed:
- for the purpose for which the information was obtained or compiled by Unpublished Media Inc. or for a use consistent with that purpose;
- for the purpose of complying with a subpoena or warrant issued or order made by a court, person or body with jurisdiction to compel the production of information or for the purpose of complying with rules of court relating to the production of information;
- to an investigative body specified in the regulations for the purpose of enforcing any laws or carrying out a lawful investigation;
- to officers or employees of Unpublished Media Inc. for internal audit purpose;
- where disclosure would clearly benefit the individual to whom the information relates
Record of Disclosures
Unpublished Media Inc. shall retain a record of any use of personal information contained in a personal information bank or any use or purpose for which that information is disclosed where the use or purpose is not included in the statements of uses in the personal information index published by the designated minister.
Personal Information Banks
· Unpublished Media Inc. shall include in personal information banks all personal information under its control that
o has been used, is being used or is available for use for an administrative purpose; or
o is organized or intended to be retrieved by the name of an individual or by an identifying number, symbol or other particular assigned to an individual.
Access to Personal Information
Upon receipt of a written request, Unpublished Media Inc. shall provide a right of access to personal information subject to the Privacy Act to
· any personal information about the individual requestor contained in a personal information bank; and
· any other personal information about the individual requestor under the control of a Unpublished Media Inc. with respect to which the individual is able to provide sufficiently specific information on the location of the information as to render it reasonably retrievable.
Individuals who are given access to their personal information may
· request correction of the personal information where the individual believes there is an error or omission therein;
· require that a notation be attached to the information reflecting any correction requested but not made; and
· require that any person or body to whom that information has been disclosed for use for an administrative purpose within two years prior to the time a correction is requested or a notation is required under this subsection in respect of that information be notified of the correction or notation, and
· where the disclosure is to be a government institution, the institution make the correction or notation on any copy of the information under its control.
Refusal of Access to Personal Information
Unpublished Media Inc. may refuse access to personal information as provided by the Privacy Act where such information, among other circumstances:
· is subject to solicitor client privilege
· is part of or relates to an investigative record where disclosure could be injurious to the enforcement of a law of Canada or a province or the conduct of investigation.
· Where disclosure threatens the safety of individuals.
All Unpublished Media Inc. employees, who collect, maintain and/or use personal information, are responsible for ensuring that the collection, use and disclosure of this information is carried out in accordance with this policy and relevant procedures.
Privacy on the Internet
This privacy statement is applicable to all Unpublished Media Inc. websites and web pages contained within.
Unpublished Media Inc. respects the privacy of its Internet users and will protect that privacy as vigorously as possible. Unpublished Media Inc. does not collect information that personally identifies individuals except when individuals provide such specific information on a voluntary basis or as part of the letter publishing process or registration process. There may be occasions where specific personal information is requested before an individual can enter certain sections of an Unpublished Media property. For example, registration is needed to publish an opinion piece or to comment on Unpublished.ca. This kind of registration helps us to ensure that content standards on these sections of the site are rigorously upheld or that contact can be made with Contributors and contest winners.
In all such cases, Unpublished Media Inc. will only collect information that is voluntarily provided by the user and undertakes that such information will be kept strictly confidential. Individual information provided to Unpublished Media Inc. to gain access to any Unpublished Media Inc. property will not be sold or made available to a third party.
Unpublished Media Inc. does reserve the right, however, to perform statistical analyses of user behaviour and characteristics, in order to measure interest in and use of the various sections of its sites so as to improve design and navigation and to gather marketing information. Only aggregated data from these analyses, not individual data, will be used for this purpose.
If you do not want a cookie placed on your computer by Unpublished Media Inc., you may disable cookies altogether by modifying the Preferences section of your internet browser (under Edit/Preferences/Advanced). Note that it is possible that some aspects of Unpublished Media Inc. web properties may be unavailable to you if you choose this option.
If you have no problem accepting cookies, but wish to be informed of their appearance, you may turn on a warning prompt by modifying the cookie warning section in Edit/Preferences/Advanced.
Third Party Cookies
In the course of serving advertisements to this site, our third-party advertiser may place or recognize a unique cookie on your browser.
· Personal Information Protection and Electronic Documents Act.
· Corporate Records and Information Management Procedures Corporate Retention Schedules.
All questions related to the interpretation and application of this policy should be directed to James O’Grady in Ottawa at 613-883-7386.
Third Party Advertising
Information about your visits to this site, such as number of times you have viewed an ad (but not your name, address, or other personal information), may be used to serve ads to you. Unpublished Media Inc. does not endorse and is not responsible for the content of external sites. Links will open in new window.
The Privacy Act is described as:
· An Act to extend the present laws of Canada that protect the privacy of individuals and that provide individuals with a right of access to personal information about themselves.
· The term personal information is defined as information about an identifiable individual that is recorded in any form with some specific exceptions for the purposes of Access to Information Act requests.
Unpublished Media Inc.’s privacy provisions are based on the CSA International's Model Code for the Protection of Personal Information, recognized as a national standard in 1996. The standard addresses the ways in which organizations collect, use and disclose personal information. It also addresses the rights of individuals to have access to their personal information and to have it corrected if necessary.
The code's 10 principles are:
An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization's compliance with these principles.
The purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected.
The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except where inappropriate.
The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means.
Limiting Use, Disclosure, and Retention
Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of these purposes.
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
An organization shall make readily available to individuals’ specific information about its policies and practices relating to the management of personal information.
Upon request, an individual shall be informed of the existence, use and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization's compliance.