Willowbrae Academy respects your privacy and is committed to complying with all standards set by law and in particular with the Personal Information Protection and Electronic Documents Act (Canada) (“PIPEDA”).
“Personal information” as defined in this document 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. It applies to our dealings with all of our clients.
“We” “our” “us” and “Academy” as defined in this document mean Willowbrae Academy.
Willowbrae Academy’s Chief Privacy Officer is accountable for compliance with this policy, though other individuals within our organization may have responsibility for the day-to-day collection and processing of Personal Information and may be delegated to act on behalf of the Chief Privacy Officer.
We are responsible for all Personal Information in our possession or custody, as well as for Personal Information that we provide to third party contractors.
Disclosure of your personal information
We may from time to time engage a third party to provide services to Willowbrae Academy. In this case, we may disclose your Personal Information only to the extent that it is required. We shall use contractual or other means to protect the personal information that is being provided to the third party.
Otherwise, we will not disclose your personal information beyond the purposes identified to you and that you have consented unless it is required by law, allowed for in this document, or is required in order to collect any fees due to the Academy.
Collection of personal information
We require personal information in order to properly serve you and your family at our Academy. We use only lawful and fair means to collect your information and only collect what is reasonably necessary for the legitimate purposes identified and for which consent has been obtained. Whenever possible, we will collect your personal information directly from you or someone that you have authorized.
Sometimes we may obtain information about you from other sources including government agencies or other third parties who have the right to disclose your information to us.
How will we use your information?
We will make a reasonable effort to identify the purpose of collection to the individual from whom the Personal Information is collected. If we plan to use Personal Information we have collected for a purpose not previously identified, we will identify and document this purpose before such use.
We may use your personal information for the following purposes:
• to process applications submitted, particularly with respect to childcare and employment;
• to provide childcare services to your children, including developing individualizes plans for each child;
• to provide compensation and benefits to employees;
• to manage and develop our business and operations;
• to communicate with you regarding current and future products and services;
• to follow up with any of your comments or suggestions;
• to assist with employee training;
• for security purposes;
• to investigate any requests for incident review;
• for billing and record-keeping;
• for account collection;
• to meet legal and regulatory requirements.
Consent and exceptions
When you visit our website, Personal Information is not collected that could identify you unless you choose to provide it voluntarily. We are not responsible for the privacy practices or the content of the websites to which it may link.
We may obtain your consent to our collection, use and disclosure of your information either expressly for stated purposes or impliedly when the purposes are not stated expressly but are indicated by the relevant circumstances or follow logically from other expressly stated purposes. We will make reasonable efforts to obtain consent at the time of collection of Personal Information, and to advise you of all the purposes for which the Personal Information is being sought, unless the purposes are plain and obvious. If additional consent is required, we will obtain that additional consent. We will not, as a condition of the supply of services, require an individual to consent to the collection, use, or disclosure of Personal Information beyond that required to fulfill legitimate purposes. You may withdraw or amend any consent previously given by contacting any of our Privacy Officers, subject to any legal or contractual restrictions and upon reasonable notice to us.
In certain circumstances, as permitted or required by law, we may collect, use or disclose Personal Information without the knowledge or consent of the individual. These circumstances include:
• when collection and use is clearly in the interests of the individual and consent cannot be obtained in a timely way;
• in emergencies;
• where consent would compromise investigating a breach of contract or law;
• to collect a debt;
• in other circumstances where permitted or required by law.
If we plan to use Personal Information we have collected for a purpose not previously identified, we will identify and document this purpose before such use.
Security of Personal Information
We use appropriate security measures to protect against loss, theft, unauthorized access, disclosure, use or modification of personal information. Our security measures vary depending on the sensitivity, amount, format, nature and storage of the personal information and will involve, as applicable, physical, organizational and electronic security measures, including premises security, restricted file access, technological safeguards including security software and firewalls to prevent unauthorized computer access, and password and security policies.
We will make our employees aware of the importance of maintaining the confidentiality of Personal Information, and we will exercise care in the disposal or destruction of Personal Information to prevent unauthorized parties from gaining access to the information.
Although we have enacted various security measures, we cannot guarantee the absolute security of our website, our Liveview System or the security of information that you submit (or that we send to you) over the internet, since no internet transmission is ever 100% secure or error-free. Your use of the internet, our software, and electronic mail is at your own risk.
Access to your Personal Information
We will respond promptly to any request for access to your personal information. There will be no cost for reasonable requests to such access, unless you request copies of records or your request involves significant retrieval costs. We will not respond to requests for access to personal information that are frivolous, vexatious or repetitious.
We may require an individual to provide sufficient information to permit us to provide an account of the existence, use and disclosure of Personal Information.
If an individual successfully demonstrates the inaccuracy or incompleteness of Personal Information, we will amend the information as required. If a challenge is not resolved to the satisfaction of the individual, we will record the substance of the unresolved challenge. Where appropriate the amended information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the information in question.
We may refuse a request or not be able to provide access to all the Personal Information we hold about an individual, as permitted or required by law. Where permitted, the reasons for denying access will be provided to the individual upon request. Exceptions may include: information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record; information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and information that is subject to solicitor-client privilege.
Changes to this policy
Questions, concerns or requests for access
We will investigate all written complaints. If we find a complaint to be justified, we will take all appropriate measures, including, if necessary, amending our policies and practices. A client or employee shall be informed of the outcome of the investigation regarding his or her complaint.
Chief Privacy Officer
94 Garland Avenue, Suite 201
Dartmouth, NS B3B 0A7 Telephone: 902.481-5435
Email us at: firstname.lastname@example.org.