Microbusiness Training Centre Inc. (MBTC) and any of its operating subsidiaries aspires to abide by the ten principles of the Canadian Standards Association’s Model Code for the Protection of Personal Information. 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 and MBTC’s policies associated with those principles are:
1. Accountability: 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 the following principles.
2. Identifying Purposes: The purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected.
MBTC collects personal information from individuals, businesses and organizations for the sole purpose of carrying on business as a provider of training programs.
Typically, personal information is collected from:
Ø Community Partners – those individuals who work for or who are designated by their employer to be the contact person(s) for MBTC. This includes information about the organization, its owners, directors, board members and employees where the organization has indicated they wish to be associated with MBTC.
Ø Sponsors – those individuals who work for or who are designated by their employer to be the contact person(s) for MBTC. This includes information about the organization, its owners, directors, board members and employees where the organization has indicated they wish to be associated with MBTC.
Ø Clients – those individuals who register in a training program or course operated by MBTC or one of its agents (community partners). This can include extensive personal information that will clearly identify the individual and may include their name, address, various types of communication information, social insurance number, demographic information, financial information and/or other personal information typically identified as required on a registration form.
Ø Other – visitors to the MBTC website may be invited to complete forms that may contain personal information or information about an individual or an organization, its owners, employees, directors, board members and other individuals associated with the organization.
In all cases, the information collected is used only for the purpose of establishing a relationship with the individual or organization and for disseminating information that relates to the business dealings of MBTC and its agents (community partners).
Where applicable, MBTC and its agents also abide by Provincial Protection of Privacy Acts with respect to maintaining confidentiality of information in its possession.
Information gathered may be used in aggregate form for statistical purposes. In such cases, no identifying information is used to develop statistical data.
3. Consent: The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except when inappropriate.
MBTC is a business, and as such works on the principle of implied consent. Examples of implied consent include:
1. By addressing correspondence to MBTC, contacting us by phone, fax, email or any other means, or by completing a website form and submitting it, or by completing a registration form to enroll in a MBTC training program, you are consenting to the collection of personal information by MBTC You are also consenting to MBTC maintaining that information in both paper-based and electronic media.
2. Where your dealings are with an agent of MBTC, such as a community partner or sponsor you are consenting to the sharing of that information between the agent or sponsor and MBTC.
3. There may be other instances where implied consent is understood because you approached MBTC and we did not approach you.
4. Limiting Collection: 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. MBTC only collects information in fair and lawful ways that is required to provide its products and services to customers in a professional, businesslike, and effective manner. MBTC only collects personal information from people who have indicated either directly or through implied consent that they wish to participate in some way with MBTC.
Information collected is used primarily for the purposes of providing goods and services to an individual or organization. Aggregate information collected about customers is used to provide statistical reports that may include a variety of information such as location, demographics, business data, and financial data and so on. In all cases personal identifying information is not used. Statistical data may be shared with MBTC s agents, its sponsors (including municipal, provincial and federal government departments,) the media and others who are interested in such statistical data.
We do not randomly collect information by any means, however may use databases that contain names and addresses of people unknown to us for the purpose of marketing and promoting MBTC and its agents.
5. 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 the law. Personal information shall be retained only as long as necessary for fulfillment of those purposes.
MBTC may, from time to time, send information to individuals and organizations who have requested such information or who have indicated either in writing or electronically, that they wish to receive information from MBTC. This includes individuals and organizations that have implied their consent to receive such information.
Personal information may be kept indefinitely unless an individual or organization makes a request to MBTC’s privacy officer to have their information purged from the company’s paper-based files or electronic databases. All such requests are handled as promptly as possible, but can take up to one month to comply.
6. Accuracy: Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
MBTC strives to ensure that personal information in its possession is accurate with regard to the purpose for which it was collected. However, we cannot guarantee that this is the case.
7. Safeguards: Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
MBTC maintains information in both paper form and electronic form. In the case of paper information, information is typically stored in filing cabinets that are locked outside of normal business hours but which are unlocked during business hours. MBTC’s premises are monitored by an outside security company. In the case of electronic information, computer systems used by MBTC are protected by standard industry approaches, such as network firewalls, virus scanners and passwords.
Even though the safeguards that are in place are considered normal for typical business operations, MBTC cannot guarantee that personal information could never be accessed by an invading party, either through physical invasion or electronic invasion. However, the nature of the information held by MBTC is unlikely to be a target for such an invasion.
8. Openness: An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.
9. Individual Access: 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.
At any time an individual may contact MBTC to determine if we have any personal information about them in our possession. They may also request information about how this information was used and whether or not this information was disclosed to anyone other than MBTC’s agents or sponsors, as outlined elsewhere in this policy.
An individual can request that we provide a copy of any personal information we have in paper files, or a printout of any information held in electronic files. MBTC will provide this information at no cost and will send any requested copies to the individual by regular mail.
Individuals have the right to ask us to amend any personal information held by us and we will comply with this request. Individuals also have the right to ask us to erase their personal information from electronic databases and to destroy any paper files.
10. Challenging Compliance: An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals for the organization's compliance.
While MBTC is an ethical company, who strives to do the best it possibly can in all its dealings, the company relies on people. As such, people are fallible and mistakes can be made. If an individual feels the company has made a mistake, they can contact the company’s privacy officer and challenge us to do better if we have failed to meet any of the obligations outlined in this policy.
MBTC will comply with the request once it has been submitted to MBTC by the appropriate government department.
MBTC takes your privacy seriously and will adjust its policies to reflect errors in performance or judgment that are brought to our attention.
For further information contact:
Microbusiness Training Centre Inc.
203 Energy Square
10109 - 106 Street