Personal information means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization.
As of January 1, 2004, all Canadian organizations engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Canadian Standards Association Model Code for the Protection of Personal Information incorporated by reference into PIPEDA. These obligations extend to Navigant Consulting Canada.
Personal Information at Navigant Consulting Canada
Navigant Consulting Canada provides services to a wide range of clients. In doing so, we often collect and use personal information. We may occasionally send to individuals, information and marketing materials concerning relevant developments in our various service areas.
Collecting Personal Information
We collect personal information fairly and in accordance with the law. Generally, we collect personal information directly from individuals to which it relates. Such collection may be done at the start of our relationship with a client or during the course of our representation or retainer.
Sometimes we may obtain information about individuals from other sources including, for example:
- a government agency or registry;
- other professionals who serve our clients;
- other parties or witnesses in the context of investigation or litigation files; and
- other parties or participants in a commercial transaction.
In most cases, if we collect, use, or disclose personal information, we will obtain consent from the individual to whom it relates. Sometimes we will ask for consent in writing, but in some cases, we may accept oral consent. Sometimes consent may be implied through conduct with us or the nature of our retainer. Should consent be withdrawn, that may impact on our ability to provide our services.
Use of Personal Information
We use personal information to provide services, to administer our client (time and billing) databases, to build and to maintain the firm's expertise and knowledge, and to include individuals in our information distribution and marketing activities. If an individual no longer wishes to receive information about developments in our various services areas or our services, he or she can ask us not to send any further material.
Disclosure of Personal Information
Navigant Consulting Canada does not disclose personal information to third parties to enable them to market their products and services.
Under certain circumstances Navigant Consulting Canada may disclose personal information. Some examples are:
- when the relevant individual has consented to the disclosure;
- when we are required by law to do so, or required by a warrant, a subpoena, or rules of court to do so;
- in order to comply with the requirements of any regulatory body that governs any of our professional practices;
- when the services we are providing requires us to give a client's personal information to third parties, his or her consent will be implied, unless he or she tells us otherwise;
- where it is necessary to collect fees or disbursements;
- where the disclosure is to a purchaser of all or a part of Navigant Canada's business;
- if we engage a third party to provide administrative services to us (like computer back-up services, archival file storage, or insurance) and the third party is bound by obligations regarding privacy which are consistent with this Policy; or
- if we retain other professional firms on behalf of a client.
In addition, where Navigant Consulting Canada is acting in the capacity of an investigative body, Navigant Consulting Canada may disclose personal information when the disclosure is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province.
Since we use personal information to provide our services, it is important that the information be accurate and up-to-date. If during the course of the retainer, any personal information changes, we ask that clients please inform us so that we can make any necessary changes. We may also periodically inquire of clients whether their personal information is accurate and up-to-date.
Securing Personal Information
Navigant Consulting Canada takes precautions to ensure that personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect personal information are:
- premises security;
- confidentiality policies as part of our professional obligations;
- deploying technological safeguards like security software and firewalls to prevent unauthorized computer access or "hacking"; and
- internal password and security policies.
E-mail is not an entirely secure medium, and appropriate precautions should be taken when contacting us to send personal or confidential information.
Accessing Personal Information
An individual may ask for access to personal information we hold about him or her.
Detailed requests which require archive or other retrieval costs may be subject to our normal professional and disbursement fees.
An individual's rights to access his or her personal information are not absolute. There are a number of situations where we may deny access. If we deny your request for access to, or refuse a request to correct personal information, we will provide a reason or reasons for doing so.
To help us make credit decisions about clients, to try to prevent fraud, and to check the identity of new clients, on occasion we may request information about clients or potential clients from the files of consumer reporting agencies.
Our website contains links to other sites, which are not governed by this Policy.
On our website, like most other commercial websites, we may monitor traffic patterns, site usage and related site information in order to optimise our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.
Requests for Access
Any questions, or any access requests regarding personal information should be directed to the professional with whom individuals normally deal in writing to our Chief Privacy Officer at:
Chief Privacy Officer
Navigant Consulting Ltd.
One Financial Place
One Adelaide Street East
Toronto, Ontario M5C 2V9;
If our response is not satisfactory, the Privacy Commissioner of Canada can be reached at:
112 Kent Street
Ottawa, Ontario, K1A 1H3