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KRISKA HOLDINGS LTD. PRIVACY POLICY
Overview
Kriska Holdings Ltd. (Kriska) will collect, use and disclose personal
information in compliance with the Personal Information Protection and
Electronic Documents Act (PIPEDA).
Kriska will manage personal information collected from employees,
customers, business partners and other individuals in a responsible
and business-like manner. We will control the collection and accuracy
of personal information, ensure up-to-date inventory of personal
information and protect the information collected from unauthorized
use or disclosure.
Identifying Purposes
Kriska collects personal information for the following purposes:
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to provide an appropriate supply of well trained
employees and contractors for all its critical functions
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to comply with all safety and regulatory
obligations
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to recruit and train professionals for all areas
of the business
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to deliver service to all its customers
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for management purposes, labor relations and
human resources including compliance with all regulatory
authorities, fact finding boards, investigation of operating
irregularities, employee discipline, employee fitness for work,
administration of pay, benefits and other related matters
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to manage equipment, properties and facilities
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to ensure environmental compliance
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to perform risk management
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for all other purposes necessary to ensure safe,
efficient and cost effective movement of goods within Canada and the
United States
Kriska identifies the purposes for which it
collects personal information at or before the time of collection from
an individual and collects only that information necessary for the
purposes identified. This information is normally collected through
the completion of forms or other documents. Collection of information
may also be by implied consent or orally.
Consent
Knowledge and consent of the individual is required for the
collection, use and disclosure of personal information except where
inappropriate and in cases of implied consent for statutorily required
purposes. The Personal Information Protection and Electronic Documents
Act sets out specific conditions under which Kriska may collect, use
or disclose personal information without the knowledge or consent of
the individual.
Consent requires “knowledge and consent”. Kriska will make every
reasonable effort to ensure that individuals are advised of the
purposes for which their information is being collected and used.
Purposes for collection will be stated in such a manner as to ensure
that the individual can reasonably understand how the information will
be used and disclosed.
Kriska will not require an individual to consent to the collection,
use or disclosure of information beyond that required to fulfill
explicitly specified and legitimate purposes. In determining the form
of consent, Kriska will take into account the sensitivity of the
information and the reasonable expectations of the individual.
Depending upon the circumstances and the type of information to be
collected, Kriska may request consent in a number of ways. Kriska will
generally seek express consent when the information is considered to
be of a sensitive nature and less sensitive information may be
collected by implied consent.
Individuals may give consent in a number of ways including:
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an application form may be used to seek consent,
collect information and inform the individual of the use that will
be made of that information. By completing and signing the form, the
individual gives consent to the collection and the specified uses.
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consent may be given orally when information is
collected over the telephone.
An individual may withdraw consent at any time
subject to legal and contractual restrictions and with reasonable
notice. Kriska will inform the individual of the implications of such
a withdrawal.
Limiting Collection
Personal information will be limited by Kriska to that which is
necessary for the purposes it has identified. Information will be
collected by lawful and fair means. Kriska will not collect personal
information in a misleading manner or indiscriminately. Kriska will
specify the type of information collected as part of its information
handling policies and practices.
Limiting Use, Disclosure and Retention
Personal information will not be disclosed or used for purposes other
than those identified without the consent of the individual. Personal
information will only be held for as long as it is necessary to
fulfill those purposes and as identified by various legislative,
regulatory and auditing requirement determining retention periods
(i.e. Income Tax Act, MOT/DOT regulations, etc). Personal information
that has been used to make a decision about an individual will
normally be held for a one year period to allow an individual access
following a decision making process. Kriska may also retain
information for a reasonable length of time after it is no longer
relevant to an individual in order to comply with its objectives,
provincial, federal and international requirements.
Personal information will be destroyed or erased after it is no longer
required to fulfill the identified purposes. Kriska has guidelines
that govern the destruction of personal information.
Accuracy and Security of Personal Information
Personal information collected will be kept as accurate, complete and
up to date as is necessary for the purposes for which it is used.
Safeguards may vary dependent upon they sensitivity of the information
being held. These methods include the following:
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physical measures (locked filing cabinets,
restricted access to offices)
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limiting access on a “need-to-know” basis
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the use of passwords and/or encryption on files.
Kriska will ensure that its employees are aware of
the importance of maintaining the protection of personal information
and will use care in disposing of or destroying personal information
collected to prevent unauthorized access to the information.
Individual Access
An individual will be informed, upon request, of the existence, use
and disclosure of his/her personal information and will be given
access to that information subject to the exclusions set out in the
PIPEDA. An individual may challenge the accuracy and completeness of
the information and have it amended as appropriate.
Kriska may make sensitive medical information available through a
medical practitioner.
Kriska will respond to an individual’s request for information within
a reasonable time and at a minimal cost to the individual. If there is
a cost to the individual for access, Kriska will provide an estimate
and the individual must advise Kriska that he/she is or is not
withdrawing the request. Kriska will make the information provided to
the individual in such form as to be readily understandable and will
include any explanations on abbreviations or codes.
Kriska will amend information when an individual successfully
demonstrates the inaccuracy or incompleteness of personal information.
The information may require correction, deletion or addition of
information.
Accountability
Kriska is responsible for the personal information under its control
and has designated the Human Resources Manager as its Privacy Officer.
The Privacy Officer is accountable for Kriska’s compliance with PIPEDA.
Any questions or comments regarding this privacy policy or its
administration should be forwarded to the Human Resources Manager.
Procedures have been put in place to receive and respond to inquiries
or complaints from our employees and independent operators relating to
handling personal information. Kriska will investigate all complaints
and, if the complaint is justified will take appropriate measures
including amending its policies and practices if necessary.
Personal information and privacy inquires should be directed as
follows:
In writing: Privacy Officer
Kriska Holdings Ltd.
P.O. Box 879
Prescott, ON
K0E 1T0
By e-mail:
mlanger@kriska.com
Facsimile: 613-925-1246
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