NRT Technology Corp. and its affiliated companies, including TNS Smart Network Inc. (collectively “NRT”) are dedicated to maintaining high standards of confidentiality with respect to the information that has been provided to us. These obligations apply to all employees, contractors, agents and vendors who provide services in connection with our business. NRT is committed to protecting the privacy of your personal information. We have developed this policy and related procedures to comply with the Personal Information Protection and Electronic Documents Act (“Act”).
The Act sets out the following ten privacy principles:
- Identifying Purposes
- Limiting Collection
- Limiting Use, Disclosure and Retention
- Individual Access
- Challenging Compliance
These principles govern our approach to respecting your privacy. NRT is responsible for personal information it holds or has under its control, including personal information it passes on to others with your permission. We have designated a Privacy Officer to ensure our compliance with legislation and this policy. Our Privacy Officer will receive and respond to your inquiries and complaints regarding the protection and privacy of your personal information, and deal with requests for access to your information.
- What is Personal Information?
Canadian privacy legislation defines “personal information” broadly as information about an identifiable individual or as information that allows an individual to be identified. For the purposes of this policy, we rely on the definition used in the legislation. Generally speaking, personal information does not include what is considered business contact information: your name, title or position, business telephone or facsimile number, or business email address.
- Appointment of Privacy Officer
NRT is responsible for the personal information it collects and holds. To ensure this accountability, we have developed this policy, and have appointed our Privacy Officer to support this policy. Our Privacy Officer will receive and respond to your inquiries and complaints regarding the protection and privacy of your personal information, and deal with requests for access to your information.
- Purposes for the Collection of Personal Information
The purposes for which personal information may be collected by NRT include:
- to understand the operations, products and services of our clients and the public perception and consumption of those operations, products and services, through techniques that include market research tools;
- to administer the duties and compensation of our contractors;
- to administer the recruitment of employees; and
- to meet requirements imposed by law.
- Collection, Use and Disclosure of Personal Information
Only information required for the purpose(s) identified will be collected. Only lawful means will be used to collect personal information.
Use and disclosure
Personal information will not be used or disclosed for purposes other than those specified, except where required by law or to protect the interests of NRT against criminal activity, fraud, and material misrepresentation.
To help make our site more responsive to the needs of potential clients and other visitors, we invoke a standard feature found in browser software, called a “cookie”, to assign each visitor a unique, random number; this is an anonymous user identification that resides on your computer. The cookie does not identify the visitor, nor will we know who you are, even if we assign a cookie to your computer. A cookie cannot read data off your hard drive.
NRT keeps records of certain non-personally identifiable information such as the number of hits a Web page receives, Internet Protocol (IP) address, and other aggregate data. We do not link this aggregate data with any personal information. Third parties that help us administer our Web site may have access to this non-personally identifiable, aggregate data.
NRT may also obtain non-personally identifiable data from clients’ computer systems to assist NRT in evaluating its client’s information and to allow NRT to fulfill its mandate. As noted above, if personal information is to be gathered from any other source, including clients, safe guard measures appropriate to the sensitivity of such personal information will be taken by NRT.
Our Web servers automatically collect limited information about your computer’s connection to the Internet, including your IP address, when you visit our site. (Your IP address is a number that lets computers attached to the Internet know where to send you data – such as the Web pages you view.) Your IP address does not identify you personally. We use this information to deliver our Web page to you upon request, to tailor our site to the interests of our users and to measure traffic within our site.
- Consent to Collection, Use and Disclosure
There are circumstances where collection, use or disclosure may be justified or permitted, or where we are obliged to disclose personal information without your consent. These circumstances could include:
- Where the information is publicly available;
- Where we are required to do so by law or by order of a court of competent jurisdiction; and
- Where we believe, upon reasonable grounds, that there is an imminent risk of death or serious bodily harm to an identifiable person or group.
In these circumstances, we will not collect, use or disclose more personal information than is required.
- Storage, Security and Protection of Personal Information
NRT endeavours to maintain appropriate physical, procedural and technical security over our offices and information storage facilities so as to prevent any unauthorized access, disclosure, copying, use or modification of personal information. Your personal information may be stored in secured physical locations and/or on computer network servers controlled by NRT located either at our offices in Canada or at the offices of our service providers outside Canada. Personal information stored in jurisdictions outside Canada may be subject to the legislation of such jurisdictions. To help protect the confidentiality of your personal information, NRT employs physical, administrative and technological safeguards appropriate to the sensitivity of your personal information. For instance, we use secure computer data networks protected by industry standard firewalls and password protection systems. In addition, where personal information is sent to a third party for processing, we make sure, through our arrangements with them, that all personal information is kept secure.
It is our practice to retain our files, and the personal information contained therein for a reasonable period of time. This retention policy was developed due to tax, regulatory and business needs, as well as for the benefit of our clients. We will keep personal information only as a long as it is necessary, including for the purposes stated herein or as required by law. When the personal information is no longer required, it will be shredded or otherwise deleted or destroyed.
- Access and Accuracy
Upon receiving a written request, and subject to any applicable exemptions, NRT will inform you of its then currently-held version of your personal information and will give you access to that information and the opportunity to correct any errors in it. Access requests should be sent to our Privacy Officer, using the contact information provided below.
NRT endeavours to maintain the accuracy of all personal information on active matters. Personal information contained in closed files is not actively updated or maintained. It is encouraged that you keep NRT apprised of any changes to your personal information that so as to ensure that your information stored by NRT is current.
- Questions and Further Information
NRT Technology Corp.
c/o Privacy Officer
10 Compass Court
Toronto, ON M1S 5R3