At RUNWAY 01, we are committed to providing our customers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our customers protecting their personal information is one of our highest priorities.
While we have always respected our customers privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of Canada’s Personal Information Protection and Electronic Documents Act. (PIPEDA) , sets out the ground rules for how Ontario businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our customers of why and how 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 Policy, in compliance with PIPEDA, outlines the principles and practices we will follow in protecting customers personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our customers personal information and allowing our customers to request access to, and correction of, their personal information.
This Personal Information Protection Policy applies to Runway 01 and its subsidiaries.
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Runway 01.
Personal Information –means information about an identifiable individual. Personal information does not include contact information (described below).
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPEDA.
Privacy Officer – means the individual designated responsibility for ensuring that Runway 01 complies with this policy and PIPEDA.
1.1 Unless the purposes for collecting personal information are obvious and the customer voluntarily provides his or her 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.
1.2 We will only collect customer information that is necessary to fulfill the following purposes:
2.1 We will obtain customers consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 The purpose for collecting using or disclosing the personal information would be considered obvious and the customer voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the client, customer 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), customers, members can withhold or withdraw their consent for Runway 01 to use their personal information in certain ways. A client’s, customer’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client, customer in making the decision.
2.5 We may collect, use or disclose personal information without the client’s, customer’s knowledge or consent in the following limited circumstances:
3.1 We will only use or disclose client, customer personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
3.2 We will not use or disclose client, customer personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client, customer lists or personal information to other parties ever.
4.1 If we use client, customer personal information to make a decision that directly affects the client, customer we will retain that personal information for at least one year so that the client, customer has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client, customer personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
5.1 We will make reasonable efforts to ensure that client, customer personal information is accurate and complete where it may be used to make a decision about the client, customer or disclosed to another organization.
5.2 Clients, Customers 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’, customers’ correction request in the file.
6.1 We are committed to ensuring the security of client, customer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that client, customer personal information is appropriately protected:
The use of locked filing cabinets; physically securing offices where personal information is held; the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access; contractually requiring any service providers to provide comparable security measures].
6.3 We will use appropriate security measures when destroying client’s, customer’s 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 personal information security.
7.1 Clients, Customers have a right to access their personal information, subject to limited exceptions.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. [IF APPLICABLE: A request to access personal information should be forwarded to the Privacy Officer [or designated individual]
7.3 Upon request, we will also tell clients, customers 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 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client, customer of the cost and request further direction from the client, customer on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the client, customer in writing, providing the reasons for refusal and the recourse available to the client, customer.
8.1 The Privacy Officer or designated individual is responsible for ensuring Runway 01 compliance with this policy and the PIPEDA.
8.2 Clients, Customers should direct any complaints, concerns or questions regarding Runway 01 compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client, customer may also write to the Information and Privacy Commissioner of Ontario.
Contact information for Runway 01 Privacy Officer or designated individual: