Complete Test Preparation Inc. (“CTP”) values our visitors, and is committed to the protection of their personal information. Accordingly, CTP adheres to the privacy principles, and accompanying commentary, set out below (the “Privacy Principles”). The Privacy Principles are based on the principles set out in Schedule 1 of the Personal Information Protection and Electronic Documents Act (Canada) (the “Act”). “Personal Information,” as used in this Policy, means information about an identifiable individual but does not include the name, title, business address or telephone number of an employee of an organization. Where an individual uses his or her home contact information as business contact information, we consider the contact information provided as business contact information. It is not, therefore, subject to protection as personal information.
Principle 1 – Accountability
CTP is responsible for all Personal Information under its control.
Accountability for our compliance with the Privacy Principles rests with our Privacy Officer, even though other individuals within CTP and its related companies have responsibility for the day-to-day collection and processing of Personal Information and may be delegated to act on behalf of the Privacy Officer.
We are responsible for Personal information in our possession or custody, including information that has been transferred to a third party for processing. We will use contractual or other means to provide a comparable level of protection when the information is being processed by a third party or where it is provided to third parties to enable us to provide services to you.
Principle 2 – Identifying Purposes
We will identify and document the purposes for which we collect, use or disclose Personal Information at or before the time of collection.
The purposes will be limited to those which are related to our operations and which a reasonable person would consider appropriate in the circumstances.
We collect, use and disclose Personal Information concerning our students for the following reasons:
To assist in communicating with the students (this would include, without limitation, contacting students about upcoming events and activities and collecting information to assist us in carrying on our activities);
To help us identify individual students’ interests and needs so that we can tailor our offering of information and services based on the information we have regarding students; and
To provide information to appropriate parties in an emergency and to comply with applicable legal requirements.
We will make a reasonable effort to specify the identified purposes, orally or in writing, to the individual from whom the Personal Information is collected either at the time of collection or after collection but before use. We will state the identified purposes in such a manner that an individual can reasonably understand how the information will be used or disclosed.
Principle 3 – Consent
Personal Information will only be collected, used or disclosed with the knowledge and consent of the individual except where inappropriate.
The way in which we seek consent, including whether it is express or implied, may vary depending upon the sensitivity of the information and the reasonable expectations of the individual. An individual can withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, by providing written instructions to the Privacy Officer.
Typically, we will seek consent for the use or disclosure of information at the time of collection (including, without limitation, for educational courses, for CTP events, and for trips abroad). In certain circumstances, consent may be sought after the information has been collected but before use (such as where we want to use information for a purpose not previously identified).
We will not, as a condition of the supply of services, hiring or accepting an application, require an individual to consent to the collection, use or disclosure of Personal Information beyond that required to fulfill the explicitly specified and legitimate purposes.
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.
Principle 4 – Limiting Collection
We will limit the amount and type of Personal Information collected and retained to that which is necessary for our identified purposes and we will only collect Personal Information by fair and lawful means.
Principle 5 – Limiting Use, Disclosure, and Retention
Personal Information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal Information will be retained only as long as necessary to fulfill the identified purposes.
Personal Information that has been used to make a decision about an individual will be retained long enough to allow the individual access to the information after the decision has been made and, in the event of an access request or a challenge, long enough to exhaust any recourse an individual may have under the law. Where Personal Information is no longer required to fulfill the identified purposes, it will be destroyed, erased or made anonymous.
We will not sell, rent or transfer any list of teachers, employees, students, clients, directors, volunteers or agents without the consent of all persons identified on the list, except as required by law.
Principle 6 – Accuracy
We will use our best efforts to ensure that Personal Information is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
Principle 7 – Safeguards
We will protect Personal Information with safeguards appropriate to the sensitivity of the information.
Our safeguards will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. 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.
Our methods of protection will include physical measures (for example, locked filing cabinets and restricted access to offices), organizational measures (for example, security clearances and limiting access on a “need-to-know” basis), and technological measures (for example, the use of passwords and encryption).
Principle 8 – Openness
We will make specific information about our policies readily available, except to the extent this is confidential commercial information.
The information we will make available will include: how to gain access to Personal Information; the type of Personal Information held by us, including a general account of its use; and how to contact our Privacy Officer.
Principle 9 – Individual Access
Upon written request, we will inform an individual of the existence, use and disclosure of his or her Personal Information and we will give the individual access to that Personal Information. An individual can challenge the accuracy and completeness of his or her Personal Information and have it amended as appropriate.
We will respond to an individual’s written request within a reasonable time (generally within 30 days).
We will attempt to be as specific as possible when providing an account of third parties to which we may have disclosed Personal Information about an individual.
If an individual successfully demonstrates the inaccuracy or incompleteness of Personal Information, we will amend the information as required. Where appropriate, the amended information will be transmitted to third parties having access to the information in question.
In certain situations, we may refuse a request or not be able to provide access to all the Personal Information we hold about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law.
Principle 10 – Challenging Compliance
Any individual can address a challenge concerning our compliance with any of the Privacy Principles to our Privacy Officer.
We will investigate all written complaints. We will take all appropriate measures including, if necessary, an amendment to our policies and practices if we find a complaint to be justified.
Designation of Privacy Officer
The following individual is designated as our Privacy Officer:
Victoria BC Canada