Privacy Policy
I. Introduction
Alberta Women Entrepreneurs Association (AWE) recognizes the importance of privacy and recognizes the sensitivity of personal information received by us in the course of our operations. We recognize our obligation to maintain the confidentiality of our clients’ information, and recognize our obligations concerning the personal information of all individuals that we collect, use or disclose in our business. This policy has been developed with those obligations in mind.
The Personal Information Protection Act (PIPA) regulates the way that private sector organizations in Alberta, collect, use and disclose personal information. Furthermore, PIPA regulates requests from individuals for access to the personal information that has been collected by organizations. AWE is a “Part 9” company (not-for-profit company) and accordingly, as a non-profit organization, PIPA does not apply to AWE except in so far as AWE is involved with ‘commercial activities’ as defined in PIPA. AWE recognizes the importance of privacy to our clients and accordingly, has developed this policy in compliance with PIPA.
Where practical, we endeavor to collect personal information directly from the person to whom the information pertains. When necessary, we will collect personal information from other sources. By retaining this organization to provide services, an individual consents to our necessary collection, use or disclosure of the individual’s personal information in order to properly advise and represent the individual. It is our policy to collect personal information about individuals other than our clients in accordance with the provisions of the PIPA. When we collect, use or disclose personal information, we will make reasonable efforts to ensure that it is accurate and complete.
II. Collection, Consent, Use and Disclosure of Personal Information
(a) Collection
Why do we collect personal information?
We collect personal information for the purposes of serving the needs of our clients. We require information to:
• Understand, access and assist our clients with ongoing needs;
• Verify our client’s identity.
• Ensure information is accurate and up-to-date;
• Providing credit lending services, including to evaluate and process loan application;
• Inform clients and prospective clients about new business initiatives;
• Comply with legal and governmental requirements;
• Fulfill any other purpose for which you provide it or with your consent; and
• Facilitate communications, process and evaluate loans and other reasonable purposes consistent with the objectives of AWE.
What information do we collect?
‘Personal information’ refers to information about an identifiable individual. Personal information includes, among other things, an individual’s name, home address, phone number, age, sex, marital or family status, an identifying number, financial information, and educational history.
In Alberta, business contact information such as your business address, job title, business phone number, business email address, business fax number or other related business contact information is not considered personal information if the collection, use, or disclosure is for the purpose of enabling the individual to be contacted in relation to the individual’s business responsibilities.
The types of personal information that AWE may collect about an individual include, but are not limited to the following:
• Name;
• Home address, Telephone number;
• Personal email address;
• Date of birth, gender, SIN, Driver’s License Information;
• Income, employment information, credit history, billing and account information;
• Information about a client’s lending related issue(s).
• Other information incidental to providing services including, but not limited to the following: personal information about co-signors, beneficiaries, directors, officers, employees, adverse parties, parties-in-interest, other professional advisors, and our client’s business partners, investors, shareholders, competitors and customers whom are individuals; and
• Any other personal information that may be collected in accordance with the provisions of PIPA
How do we collect your personal information?
We collect personal information in accordance with the provisions of PIPA. We collect personal information only for purposes that are reasonable and to the extent it is reasonable for meeting the purposes for which the information is collected. Before or at the time of collection of personal information, unless voluntarily provided by the individual for a particular purpose and it is reasonable that a person would voluntarily provide the information, AWE will notify you orally or in writing as to the purpose for which the information is collected and of the title of a person who is able to answer questions on behalf of AWE about the collection of the personal information.
Wherever possible we collect personal information directly from individuals. However, it may be necessary to make directed individual requests for relevant sensitive personal information from a particular organization or business, such as financial institutions. If we need to make this request on behalf of a client, we will obtain consent prior to collecting this information. Consent may be in writing, verbal or implied as necessary to fulfill requirements.
The following is a list of some of the potential sources of personal information which we may need to access depending on the nature of the services we are providing to a client:
• The Client;
• Public registries such as the Land Titles Office, Personal Property Registry, or the Probate Registry
• Financial institutions;
• Credit bureaus and credit reporting agencies;
• A client’s employer;
• Motor vehicle and driving licensing authorities; and
• Law enforcement.
(b) Consent
PIPA provides that an individual is deemed to consent to the collection, use or disclosure of personal information about that individual for a particular purpose if the individual voluntarily provides the information for that purpose, and it is reasonable that a person would voluntarily provide that information.
Consent may be given in the following ways:
• AWE will request either written or express oral consent from an individual, which may be given in person or over the telephone if her/his identity is authenticated;
• If an individual volunteers to provide relevant personal information verbally or in writing, we assume that consent is being given to the collection, use and disclosure of your personal information as described in this Privacy Policy;
• When contact is initiated with us, AWE may determine that consent has been implied for us to collect, use and disclose personal information in a reasonable manner.
• In some situations, we will require express consent in writing, by the provision of a letter, application form, electronic signature, or other document authorizing certain activities.
There are certain circumstances where AWE is required or permitted by law, to collect, use and disclose personal information without consent. Such circumstances include, but are not limited to situations where:
• The collection, use or disclosure is clearly in the interests of the individual and consent cannot be obtained in a timely way or the individual would not reasonably be expected to withhold consent;
• The collection, use and disclosure is necessary to respond to an emergency that threatens the life, health or security of an individual or the public;
• It is necessary to establish or collect AWE fees;
• Collection, use, or disclosure is reasonable for the purposes of an investigation or proceeding;
• The personal information is available to the public from a prescribed source; or
• The collection, use, or disclosure is required or authorized by a statute or regulation of Alberta or Canada.
AWE will handle all personal information confidentially and will substantiate the legal authority to collect, use and disclose personal information in these circumstances. Furthermore, we will make reasonable efforts to ensure that the information we collect is accurate and complete.
On giving reasonable notice to AWE, an individual may at any time withdraw or vary their consent to the collection, use, or disclosure by AWE of personal information about the individual subject to the exceptions detailed in PIPA. If AWE receives notice to withdraw or vary an individual’s consent, AWE will inform the individual of the likely consequences of withdrawing or varying their consent, unless the likely consequences of withdrawing or varying consent would be reasonably obvious to the individual.
(c) Use
AWE will use personal information to provide services to clients and to administer our business. AWE will use personal information only for purposes that are reasonable and to the extent the use of the personal information is reasonable for meeting the purposes for which the personal information is used.
With an individual’s permission, we may send you information about our other services, or about upcoming events and new programs we may have to offer. An individual may at any time withdraw consent by notifying us, and we will not send any further materials.
(d) Disclosure
It is AWE’s policy not to disclose or sell personal information or business contact information to any third party to enable them to market their products or services.
Personal information will only be disclosed if it is reasonable, necessary or beneficial to the provision of services to our client or to the extent it is reasonable for meeting the purposes for which the information is disclosed. Information may be disclosed to the following sources:
• Our staff and agents who use the information for the reasonable business purpose of providing an individual with client services;
• To a third party we contract to provide administrative services to the organization. These third-party contractors are bound by law not to use this information in a way that would be inconsistent with the privacy laws of Alberta;
• Professionals working with us such as our accountants, lawyers, or service professionals to help us collect a debt or enforce an obligation owed by a client etc.; and
• Financial institutions and credit reporting agencies.
It should further be noted that all of our employees and Board members are bound by a strict confidentiality agreement.
III. Protection (Safeguarding information)
We recognize our obligations to protect the confidential information of our clients. We further recognize our obligations to protect personal information in our custody or control. We have therefore made arrangements to secure against the unauthorized access, collection, use, disclosure, copying, modification, disposal, or destruction of personal information.
IV. Access
Requesting access to personal information
PIPA requires that every organization that collects personal information about an individual give that individual access to the personal information that they have in their custody or control upon request subject to the exceptions outlined in PIPA as described below. Furthermore, PIPA requires that the organization must state the purposes for which the personal information has been and is being used and the circumstances and names of all persons to whom this personal information has been and is being disclosed to. If AWE, in response to a request, refuses to provide information about the about the purposes for which the personal information has been and is being used by AWE and the names of the persons to whom and the circumstances in which the personal information has been and is being disclosed, AWE will inform the individual of the name of the person who can answer the individual’s questions on behalf of AWE about the refusal and that the individual may ask for a review as outlined in Section 46 of PIPA.
Any individual may request access to their personal information by directing a written request to AWE’s Privacy Officer, as identified below. AWE will respond to written requests in the time allowed under PIPA. Furthermore, we are permitted by law to charge a reasonable fee for retrieval and copying of personal information; notification of the amount to be communicated prior to us completing the request. If the fee is going to be extensive due to a large volume of information, a deposit may be required in advance of receiving the information.
Denial of access to personal information
There are two sets of specific circumstances where an individual may be denied access to her/his personal information.
First, the following list describes circumstances where AWE may refuse access:
• The information is protected by any legal privilege;
• The disclosure of the information would reveal confidential information that is of a commercial nature and it is not unreasonable to withhold that information;
• The information was collected for an investigation or legal proceeding;
• The disclosure of the information might result in that type of information no longer being provided to the organization when it is reasonable that that type of information would be provided;
• The information was collected by a mediator or arbitrator or was created in the conduct of a mediation or arbitration for which the mediator or arbitrator was appointed to act
o Under an agreement,
o Under an enactment, or
o By a court;
• The information relates to or may be used in the exercise of prosecutorial discretion
Secondly, the following list describes circumstances where AWE must refuse access:
• The disclosure of the information could reasonably be expected to threaten the life or security of another individual;
• The information would reveal personal information about another individual and the personal information cannot be reasonably severed from a copy of the record; or
• The information would reveal the identity of an individual who has in confidence provided an opinion about another individual and the individual providing the opinion does not consent to disclosure of his or her identity and the information cannot reasonably be severed from a copy of the record.
V. Revisions to Personal Information
We make every reasonable effort to ensure that personal information is accurate and complete. We rely on individuals to notify us if there is a change to their personal information that may affect their relationship with our organization. If you are aware of an error in personal information about you, please let us know.
PIPA permits individuals to submit written requests to organizations to correct errors or omissions about the individual in the personal information that is in the custody or under the control of the organization. If AWE receives a written request to correct an error or omission, AWE will, as soon as reasonably possible, correct the personal information and, if reasonable to do so, send correction notifications to any other organizations to whom we disclosed the incorrect information. AWE may make a determination to not make the correction requested. If AWE makes a determination to not make the correction, AWE will annotate the personal information under its control with the correction that was requested but not made.
AWE will notify the individual who submitted the written request of the action taken by AWE, of the name of the person who can answer any question about the request for correction on behalf of AWE, and that the individual may ask for a review of the decision under Section 46 of PIPA.
VI. Information Regarding Website Practices and Cookies
Cookies
Cookies are an essential part of how the internet works today, and they allow web servers to recognize your computer's browser when you return. When you enter our site, a cookie is set on your hard drive so that our site can be easily located by your browser on future visits. Although the information is stored on your hard drive, a cookie can never look at the contents of your hard drive or deliver information on your hard drive to others. When you visit our site, we may collect and store information about your visit.
We use this data on an aggregate basis to measure and analyze site activity, and on an individual basis to provide information that may be of interest to you. We may use these cookies for marketing and remarketing purposes through third-party ad platforms for our various programs, events, and services. If you wish to opt-out, or have the cookies removed, you can simply delete them from your browsing history. You may choose not to accept cookies by changing your preferences on your browser.
Links to External Sites
Links to external websites are provided for you as a convenience and we assume no responsibility or liability for such linked sites. These other sites may send their own cookies to users, collect data or solicit personal information. You should check the privacy policy of any website you visit.
VII. Other
Communications by Email
E-mail is not a secure, confidential method of communicating your confidential and personal information with us. We will not use e-mail to send personal or confidential information unless you expressly authorize this form of communication and accept all the inherent risks associated with this type of communication.
Canada’s Anti-Spam Legislation (“CASL”)
AWE complies with CASL and we are committed to making sure you only receive the electronic messages that you want from us. AWE will never send you unsolicited electronic messages in connection with the marketing of AWE, its services or products.
AWE may send you electronic messages if you signed up to join our electronic messages list. We occasionally send electronic messages to members of mailing lists shared with us from other organizations who have received your opt-in consent, we may occasionally contact you to notify you about updates to our website or new products or services offered by us, or to deliver targeted information that may be of interest to you.
No matter how you joint our list or provide us with your consent to receive communications, at the bottom of all of our electronic messages, you will find a clear, easy way to unsubscribe.
For more information about our anti-spam policy or if you have questions or a complaint related to CASL, please contact our Privacy Officer as set out in the “Contact Information & Resources” section of this Privacy Policy.
Changes to this Privacy Policy
We may review and change our Privacy Policy from time to time in order to update our privacy commitment to you in keeping with current privacy laws.
Contact Information & Resources
If you have any questions with respect to our policies concerning the handling of your personal information, or if you wish to request access to, or correction of, your personal information under our care and control, please contact our Privacy Officer at:
Alberta Women Entrepreneurs Association
100, 10237 – 104th Street
Edmonton, Alberta, T5J 1B1
Telephone 1-800-713-3558
Email: info@awebusiness.com
If anyone is dissatisfied with AWE’s handling of personal information, they may contact our Privacy Officer in writing, setting out the reasons for concern. If, after our Privacy Officer has reviewed and responded to concerns, the individual remains dissatisfied, she/he may wish to contact the Privacy Commissioner at:
Office of the Information and Privacy Commissioner of Alberta
410, 9925-109th Street
Edmonton, Alberta, T5K 2J8
Telephone: (780) 422-6860
Website: http://www.oipc.ab.ca
