Personal Information Protection Policy – Pawlina Law Personal Information Protection Policy
At Pawlina Law, we are committed to providing our clients with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, protecting their personal information is one of our highest priorities.
While we have always respected our clients privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of the Personal Information Protection and Electronic Documents Act (“PIPEDA”).
We will inform our clients 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 policy, in compliance with PIPEDA, outlines the principles and practices we will follow in protecting clients’personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ personal information and allowing our clients to request access to, and correction of, their personal information.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the client 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 client information that is necessary to fulfill the following purposes:
- To verify identity;
- To understand the legal needs of our clients;
- To open and manage an account;
- To deliver requested products and services
- To provide legal services;
- To ensure a high standard of service to our clients; and
- To meet regulatory requirements.
Policy 2 – Consent
2.1 We will obtain client consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client 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 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), clients can withhold or withdraw their consent for Pawlina Law to use their personal information in certain ways. A client’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 in making the decision.
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose client personal information where necessary to fulfill the purposes identified at the time of collection.
3.2 We will not use or disclose client personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use client personal information to make a decision that directly affects the client we will retain that personal information for at least one year so that the client has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
4.3 Like most other commercial websites, we may monitor traffic patterns, site usage and related site information to optimize your visit to our website. Our website server will automatically collect IP addresses. We may view the IP log from time to time, for example, to maintain the security of our website.
4.4 By contacting Pawlina Law using an email address provided on its web site, your personal information will be collected for the sole purpose of responding to your email.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that client personal information is accurate and complete where it may be used to make a decision about the client or disclosed to another organization.
5.2 Clients 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’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 We will use appropriate security measures when destroying client’s personal information.
6.3 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Clients Access to Personal Information
7.1 Clients have a right to access their personal information, subject to limited exceptions, including solicitor-client privilege, or where disclosure would reveal personal information about another individual, health and safety concerns.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell clients 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 of the cost and request further direction from the client 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 in writing, providing the reasons for refusal and the recourse available to the client.
Policy 8 – Third-Party Services
8.1 The third-party providers used by Pawlina Law will only collect, use and disclose your information to the extent necessary to allow them to perform the services they provide to Pawlina Law. Payment transaction processors, have their own privacy policies in respect to the information we are required to provide to them for your purchase-related transactions.
8.2 Some providers may be located in or have facilities that are located in a different jurisdiction. If you elect to proceed with a transaction that involves the services of a third-party service provider, then your information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities are located.
Policy 9 – Age of Consent
9.1 By using this site, you represent that you are at least the age of majority in your state or province of residence, or that you are the age of majority in your state or province of residence and you have given us your consent to allow any of your minor dependents to use this site.
Policy 10 – Questions and Complaints: The Role of the Privacy Officer or designated individual
10.1 The Privacy Officer is responsible for ensuring Pawlina Law’s compliance with this policy and the Personal Information Protection and Electronic Documents Act.
10.2 Clients should direct any complaints, concerns or questions regarding Pawlina Law’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Pawlina Law’s Privacy Officer:
1800 – 2 St Clair Avenue West
Toronto, Ontario, Canada M4V 1L5
Last Revised June 10, 2019.
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