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The Ten Principles of PrivacyThe following ten principles govern our actions as they relate to the use of our clients' personal information:
Principle 1 – Accountability
We are accountable for all personal information in our possession or custody, including personal information disclosed to third parties for purposes of providing services requested by our clients or employees.
Principle 2 – Identifying Purposes
We will inform our clients of the purposes for which we are collecting any personal information, before or at the time the information is collected.
Principle 3 – Consent
Our policy is to require our agents to obtain consent from our clients before or when we collect, use or disclose their personal information. A client's consent can be expressed, implied, or given through an authorized representative. A client can withdraw consent at any time, with certain exceptions. We may, however, collect, use or disclose personal information without the client' knowledge or consent in exceptional circumstances where such collection, use or disclosure is permitted or required by law.
Principle 4 – Limiting Collection
The information collected from the client will be limited to those details necessary for the purposes we have identified to the client. Information will be collected by fair and lawful means.
Principle 5 – Limiting Use, Disclosure and Retention
Personal information will only be used or disclosed for the purpose for which it was collectedunless the client has otherwise consented, or when it is required or permitted by law. In certain exceptional circumstances, we may have a legal duty or right to disclose personal information without client knowledge or consent with respect to matters that concern the company's or the public's interest.
Principle 6 – Accuracy
We will keep personal information as accurate, complete and current as necessary to fulfill the identified purposes for which it was collected. Clients may have this information amended where it is found to be inaccurate or incomplete.
Principle 7 – Safeguarding Personal Information
Personal information is safeguarded using measures appropriate to the sensitivity of the information.
Principle 8 – Openness
We will make information available to our clients about the policies and procedures we use to manage personal information. Clients have access to this information through our Web site, or through alternate means if requested.
Principle 9 – Client Access
Upon written request, a client will be informed of the existence, use and disclosure of their personal information, and will be given access to it. We will respond to such requests as efficiently as possible. If we are prohibited from providing such access we will explain the reasons for the lack of access, except where prohibited by law.
Principle 10 – Addressing Client Complaints and Suggestions
When Can We Disclose Personal Information?We are obliged to keep clients personal information confidential except under the following circumstances:
With Whom We May Share Information
How We Safeguard Information
C&W LePage has extensive controls in place to maintain the security of its information and information systems. Client files are stored according to the sensitivity of the information contained therein. Appropriate controls (such as restricted access) are placed on our computer systems and data processing procedures. Physical access to areas where personal information is gathered, processed or stored is limited to authorized employees.
Opting OutIn order to provide clients with our services and products, we may, with their consent, share their personal information with other C&W LePage affiliates. Should a client not want to receive promotional materials from or have their personal information shared with these companies please contact C&W LePage at the address, phone number or email address provided below:
Address: 33 Yonge Street, suite 1000, Toronto, Ontario M5E 1S9
Phone Number: (416) 359-2751
Email Address: email@example.com
Privacy Officer: Beth Connor
Contact Information: (416) 359-2365 or firstname.lastname@example.org