Policy Purpose & Scope
The purpose of this policy is to give guidance to how Grey Owl Engineering (“GOE”) staff members will manage personal information that is collected. GOE is committed to safeguarding the personal information entrusted to us by our clients and other members of the public. We manage your personal information in accordance with Alberta’s Personal Information Protection Act and other applicable laws.
This policy outlines the principles and practices we follow in protecting your personal information. The policy also applies to any person providing services on our behalf. A copy of this policy is provided to any client or member of the public on request.
Personal information means information about an identifiable individual. This includes an individual’s name, home address and phone number, age, sex, marital or family status, an identifying number, financial information, educational history, etc.
We collect only the personal information that we need for the purposes of providing services to our clients, including personal information needed to: open and manage project files, notify clients of upcoming events of interest, understand client’s service and project needs, deliver services to our clients, meet legal and regulatory requirements and manage employee and contractor files.
We collect and maintain different types of information about our clients including:
- contact and identification information, such as name, address, telephone number and e-mail address;
- services and product related information including the services we provide to you;
- financial information including your payment methods and preferences; and
- customer relationship information including requests for services and feedback information relating to these services.
We normally collect client information directly from our clients. We may collect your information from other persons with your consent or as authorized by law. We inform our clients, before or at the time of collecting personal information, of the purposes for which we are collecting the information. However, we don’t provide this notification when a client volunteers information for an obvious purpose (for example, entry into a draw or signing up for a newsletter).
We ask for consent to collect, use or disclose client personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose. In cases where we collected personal information before January 1, 2004, we assume your consent to our use and, where applicable, disclosure for the purpose for which the information was collected. We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask clients to provide their consent orally (in person, by telephone), in writing (by signing a consent form, by checking a box on a form, or electronically (by clicking a button).
You may withdraw consent to use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfill our legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary personal information.
We may collect, use or disclose client personal information without consent only as authorized by law. For example, we may not request consent when the collection, use or disclosure is reasonable for an investigation or legal proceeding, to collect a debt owed to our organization, in an emergency that threatens life, health or safety, or when the personal information is from a public telephone directory.
Disclosing Personal Information
We use and disclose client personal information only for the purposes for which the information was collected, except as authorized by law. For example, we may use client contact information to deliver materials. The law also allows us to use that contact information for the purpose of collecting a debt owed to our organization, should that be necessary. If we wish to use or disclose your personal information for any new business purpose, we will ask for your consent.
Safeguarding Personal Information
We make every reasonable effort to ensure that client information is accurate and complete. We rely on our clients to notify us if there is a change to their personal information that may affect their relationship with our organization. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible. In some cases we may ask for a written request for correction.
We protect client personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information. We will notify the Office of the Information and Privacy Commissioner of Alberta, without delay, of a security breach affecting personal information if it creates a real risk of significant harm to individuals. We retain client personal information only as long as is reasonable to fulfil the purposes for which the information was collected or for legal or business purposes. We render client personal information non-identifying, or destroy records containing personal information once the information is no longer needed. We use appropriate security measures when destroying client personal information, including shredding paper records and permanently deleting electronic records.
Access to records containing personal information
Clients of GOE have a right of access to their own personal information in a record that is in our custody or under our control, subject to some exceptions. For example, organizations are required under the Personal Information Protection Act to refuse to provide access to information that would reveal personal information about another individual. Organizations are authorized under the Act to refuse access to personal information if disclosure would reveal confidential business information. Access may also be refused if the information is privileged or contained in mediation records. If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record.
You may make a request for access to your personal information by writing to the Privacy Officer designated to ensure compliance with PIPA. You must provide sufficient information in your request to allow us to identify the information you are seeking. You may also request information about our use of your personal information and any disclosure of that information to persons outside our organization. For personal information collected before January 2004, if we do not have a record of disclosures, we will provide information about any disclosure of your information that is likely to have occurred. You may also request a correction of an error or omission in your personal information. We will respond to your request within 45 calendar days, unless an extension is granted. We may charge a reasonable fee to provide information, but not to make a correction. We will advise you of any fees that may apply before beginning to process your request.
Links to Third Party Sites
The GOE/GOLD web site contains links to third party sites. These links are provided as a convenience, GOE/GOLD does not control or endorse the content of such third party sites. You acknowledge and agree that GOE is not responsible for the content or accuracy of any third party sites linked to from this web site, makes no representations or warranties regarding the content or accuracy of information available on such third party sites, and shall not be liable for any damages or injury arising out of or in any way connected to a dispute with another site.
In the event of a conflict between this policy and applicable law, applicable law shall prevail.
If you have a question or concern about any collection, use or disclosure of personal information by GOE, or about a request for access to your own personal information, please contact our Privacy Officer designated to ensure compliance with PIPA in the first instance:
Grey Owl Engineering
815, 715-5th Avneue SW
Calgary, Alberta T2P 2V6
If you are not satisfied with the response you receive, you should contact the Information and Privacy Commissioner of Alberta:
Office of the Information and Privacy Commissioner of Alberta
Suite 2460, 801 – 6 Avenue, SW
Calgary, Alberta T2P 3W2
Phone: 403-297-2728 Toll Free: 1-888-878-4044