GWN

Privacy Principles

Introduction

Great White North Inc. ("Great White North") is concerned about the protection of personal information that it holds respecting its clients, subscribers and others. The approaches outlined in these privacy principles (the "Privacy Principles") provide the framework for Great White North's policies and procedures regarding its collection, use, retention and disclosure of personal information in all its operations.

The Privacy Principles are based on the principles contained in the federal Personal Information Protection and Electronic Documents Act and the Canadian Standards Association's Model Code for the Protection of Personal Information, which forms part of the Act and are consistent with principles contained in provincial privacy laws, where applicable.

The Privacy Principles apply to personal information that is collected, used or disclosed by Great White North. They do not apply to non-personal information or business information.

The Privacy Principles will be made available to clients, subscribers and other interested persons upon request.

Overview of Privacy Principles

  1. Accountability
    Great White North is responsible for personal information under its control and will designate a person or persons who are accountable for its compliance with the Privacy Principles.

  2. Identifying Purposes
    Great White North will identify the purposes for which personal information is collected at or before the time the information is collected.

  3. Consent
    The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate.

  4. Limiting Collection Great White North will limit the collection of personal information to that which is necessary for the purposes identified. Great White North will collect personal information by fair and lawful means.

  5. Limiting Use, Disclosure, and Retention
    Great White North will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Great White North will retain personal information only as long as necessary for the fulfilment of the purposes for which it was collected.

  6. Accuracy
    Great White North will use reasonable efforts to ensure that personal information is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

  7. Safeguards
    Great White North will protect personal information by security safeguards appropriate to the sensitivity of the information.

  8. Openness
    Great White North will make readily available to individuals specific information about its policies and practices relating to the management of personal information.

  9. Individual Access
    Upon request, Great White North will inform an individual of the existence, use and disclosure of his or her personal information and will give the individual access to that information. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

  10. Challenging Compliance An individual will be able to address a challenge concerning compliance with the Privacy Principles to the person(s) designated to oversee Great White North 's compliance.

Definitions

In the Privacy Principles, the following definitions apply:

client - a current or potential customer of Great White North

collection - gathering, acquiring or obtaining personal information from any source by any means

consent - voluntary agreement with what is being done or proposed. Consent can be either express or implied. Express consent is given explicitly, either orally or in writing. Express consent is unequivocal and does not require any inference on the part of the organization seeking consent. Implied consent arises where consent may reasonably be inferred from the action or inaction of the individual.

disclosure - making personal information available to a third party

individual - a client, subscriber or other interested person

personal information - any information that is about or can be linked to an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization.

subscriber - an individual who has requested newsletters from Great White North

third party - any person or organization other than Great White North

use - refers to the treatment and handling of personal information by Great White North