PRIVACY POLICY

Use of this web site signifies your acknowledgement and consent to this privacy policy. Please read this privacy policy carefully before using this web site.

Our firm takes your privacy seriously and is committed to safeguarding your privacy online. Because we gather certain types of personal information from visitors to this web site (e.g. name, e-mail address, etc.), we have developed this privacy policy (the “Privacy Policy”) to help you understand the terms and conditions surrounding the collection and use of your personal information. This Privacy Policy discloses the types of personal information we gather, how it is used, and how you can gain access to and edit any data that we’ve collected about you at any time.

 

Guiding Principles:

Our Privacy Policy has been developed using the following guiding principles:

Our firm collects personal information online primarily to provide our visitors with a more relevant experience on this web site. When doing so, we will make every reasonable effort to avoid excessive or irrelevant collection of data. Our firm will take reasonable physical, electronic and managerial measures to safeguard and secure any personal information you provide to us (e.g. data will be stored in protected databases on secured servers with restricted access). However, given that electronically submitted data is not 100% secure, we make no representations or warranties as to the security of any personal information you submit online, which you do at your own risk.

 

Disclosure of Personal Information:

We do not sell, rent, or trade consumer personal information to third parties other than as described in this Privacy Policy. Our firm may disclose certain personal information as follows:

  • to business partners, such as third party service providers, agents and affiliated entities in connection with the services that they perform for our firm, such as providing certain services necessary for the administration of this web site and the provision of certain interactive functionalities. Please note that some of our agents and contractors are located outside of Canada and, as such, are subject to foreign laws, including laws that may require disclosure of personal information to government agencies in those countries;

  • to law enforcement agencies for the purposes of investigating fraud or other offences; or

  • to legal, financial, and other professional advisors or in connection with the sale or reorganization of all or part of its business or operations.

Except as provided above, our firm will not use or disclose personal information for purposes other than those for which it was collected, except with your consent, as required or permitted by law, and to provide the features and service(s) you’ve requested. At the time you register for any such feature or service, you will be notified of, and asked to consent to, the sharing of your personal information necessary for the provision of these requested features or services.

Non-Personally Identifiable Data:

Anytime you visit this web site, we may gather certain non-personally identifiable information regarding the means you use to access our site. This information may include the type and version of your browser, your service provider, your IP address and any search engine you may have used to locate the site. We use this information to help diagnose problems with our server, administer the Web site, and compile broad statistical data. In addition, we gather certain navigational information about where you go on this web site. This information enables us to determine which areas of the Web sites are most frequently visited and helps us to tailor the sites to the needs and interests of our online visitors. Such information is gathered by us in the aggregate and will not be associated with a specific individual without that individual’s consent.

Use of Cookies:

Our firm may use a browser feature known as a “cookie.” Cookies are small files placed on your hard drive that assist us in providing you with a customized browsing experience. Our firm uses cookies to provide you with the convenience of not having to reenter information, such as user IDs and passwords, multiple times during your visits to this web site. Cookies can also be utilized to help us provide you with information targeted to your interests, based upon your prior browsing on this web site. The “help” section of the toolbar on most browsers will inform you on how to prevent your browser from accepting new cookies, how to have the browser notify you upon the receipt of a new cookie, or how to disable the use of cookies completely. As this web site has been designed to take advantage of the use of cookies, should you configure your browser to decline their use, certain features of this web site may not function correctly and you may be required to renter any user IDs and passwords more frequently.

Personal Information Voluntarily Provided:

Any personal information you provide to us (i.e. name, e-mail address, etc.) when you enroll in one of our E-Mail Reminder Services, request information, or use any of the other interactive portions of this web site may be used to provide you with information you’ve requested about our company, our products and our services, or to provide you with special notices. You may opt out of receiving future communications at any time (see opt-out Procedures below). This data may also be used to tailor your experience on this web site by providing content that is relevant to your interests and geographic region.

Accessing this Web Site:

This web site is hosted on servers located in the United States. As such, your connection will be through and to servers located in the U.S. Any personal information you provide during your visit will be processed and maintained on our Web server and other internal systems located within the U.S.

 

External Links:

This web site contains links to other sites. Our firm is not responsible for the privacy practices or the content of such web sites. To help ensure the protection of your privacy, we recommend that you review the privacy policy of any site you visit via a link from this web site.

 

Public Forums:

This web site may make chat rooms, forums, message boards, and/or news groups available to its users at various times. Please remember that, unless otherwise stated, any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information in these areas.

 

Opt-out Procedures:

Other than as set forth in this Privacy Policy, you will be notified when any personally-identifiable information about you may be shared with third parties, and you will be given the opportunity to decline to share that information.

You may always opt-out of receiving future communications from our firm. This web site allows users to opt-out of receiving such communications at the point where personal information is requested, or through other means as identified.

 

Changes to this Privacy Policy:

We reserve the right to change and update this Privacy Policy. These changes will be made when appropriate, in a timely manner. We encourage you to examine our Policy from time to time to ensure you are aware of any changes we may have made.

CAN SPAM Act:

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
 

We collect your contact information and email address in order to:

      • Send information, respond to inquiries, and/or other requests or questions

      • Process orders and to send information and updates pertaining to orders.

      • Send you additional information related to your product and/or service

      • Market to our mailing list or continue to send emails to our clients after the original transaction has occurred.


To be in accordance with CANSPAM, we agree to the following:

      • Not use false or misleading subjects or email addresses.

      • Identify the message as an advertisement in some reasonable way.

      • Include the physical address of our business or site headquarters.

      • Monitor third-party email marketing services for compliance, if one is used.

      • Honour opt-out/unsubscribe requests quickly.

      • Allow users to unsubscribe by using the link at the bottom of each email.

GDPR Compliance:

Our Commitment

Casesensitive Consulting Inc. (‘we’ or ‘us’ or ‘our’) are committed to ensuring the security and protection of the personal information that we process, and to provide a compliant and consistent approach to data protection. We have always had a robust and effective data protection program in place which complies with existing law and abides by the data protection principles. However, we recognize our obligations in updating and expanding this program to meet the demands of the GDPR and the [UK’s Data Protection Bill/insert relevant country DP law]. 

 

Casesensitive Consulting Inc. are dedicated to safeguarding the personal information under our remit and in developing a data protection regime that is effective, fit for purpose and demonstrates an understanding of, and appreciation for the new Regulation. Our preparation and objectives for GDPR compliance have been summarized in this statement and include the development and implementation of new data protection roles, policies, procedures, controls and measures to ensure maximum and ongoing compliance.

 

Casesensitive Consulting Inc. already have a consistent level of data protection and security across our organization, and are fully compliant with the GDPR.

 

Our preparation includes:

  • Information Audit - carrying out a company-wide information audit to identify and assess what personal information we hold, where it comes from, how and why it is processed and if and to whom it is disclosed.

  • Policies & Procedures - [revising/implementing new] data protection policies and procedures to meet the requirements and standards of the GDPR and any relevant data protection laws, including:

    • Data Protection – our main policy and procedure document for data protection has been overhauled to meet the standards and requirements of the GDPR. Accountability and governance measures are in place to ensure that we understand and adequately disseminate and evidence our obligations and responsibilities; with a dedicated focus on privacy by design and the rights of individuals.

    • Data Retention & Erasure – we have updated our retention policy and schedule to ensure that we meet the ‘data minimisation’ and ‘storage limitation’ principles and that personal information is stored, archived and destroyed compliantly and ethically. We have dedicated erasure procedures in place to meet the new ‘Right to Erasure’ obligation and are aware of when this and other data subject’s rights apply; along with any exemptions, response timeframes and notification responsibilities.

    • Data Breaches – our breach procedures ensure that we have safeguards and measures in place to identify, assess, investigate and report any personal data breach at the earliest possible time. Our procedures are robust and have been disseminated to all employees, making them aware of the reporting lines and steps to follow. 

    • International Data Transfers & Third-Party Disclosures – where Casesensitive Consulting Inc. stores or transfers personal information outside the EU, we have robust procedures and safeguarding measures in place to secure, encrypt and maintain the integrity of the data. Our procedures include a continual review of the countries with sufficient adequacy decisions, as well as provisions for binding corporate rules; standard data protection clauses or approved codes of conduct for those countries without. We carry out strict due diligence checks with all recipients of personal data to assess and verify that they have appropriate safeguards in place to protect the information, ensure enforceable data subject rights and have effective legal remedies for data subjects where applicable.

    • Subject Access Request (SAR) – we have revised our SAR procedures to accommodate the revised 30-day timeframe for providing the requested information and for making this provision free of charge. Our new procedures detail how to verify the data subject, what steps to take for processing an access request, what exemptions apply and a suite of response templates to ensure that communications with data subjects are compliant, consistent and adequate.

  • Legal Basis for Processing - we are reviewing all processing activities to identify the legal basis for processing and ensuring that each basis is appropriate for the activity it relates to. Where applicable, we also maintain records of our processing activities, ensuring that our obligations under Article 30 of the GDPR and Schedule 1 of the Data Protection Bill are met.

  • Privacy Notice/Policy – we [have revised/are revising] our Privacy Notice(s) to comply with the GDPR, ensuring that all individuals whose personal information we process have been informed of why we need it, how it is used, what their rights are, who the information is disclosed to and what safeguarding measures are in place to protect their information.

  • Obtaining Consent - we [have revised/are revising] our consent mechanisms for obtaining personal data, ensuring that individuals understand what they are providing, why and how we use it and giving clear, defined ways to consent to us processing their information. We have developed stringent processes for recording consent, making sure that we can evidence an affirmative opt-in, along with time and date records; and an easy to see and access way to withdraw consent at any time.

  • Direct Marketing - we [have revised/are revising] the wording and processes for direct marketing, including clear opt-in mechanisms for marketing subscriptions; a clear notice and method for opting out and providing unsubscribe features on all subsequent marketing materials.

  • Data Protection Impact Assessments (DPIA) – where we process personal information that is considered high risk, involves large scale processing or includes special category/criminal conviction data; we have developed stringent procedures and assessment templates for carrying out impact assessments that comply fully with the GDPR’s Article 35 requirements. We have implemented documentation processes that record each assessment, allow us to rate the risk posed by the processing activity and implement mitigating measures to reduce the risk posed to the data subject(s).

  • Processor Agreements – where we use any third-party to process personal information on our behalf (i.e. Payroll, Recruitment, Hosting etc), we have drafted compliant Processor Agreements and due diligence procedures for ensuring that they (as well as we), meet and understand their/our GDPR obligations. These measures include initial and ongoing reviews of the service provided, the necessity of the processing activity, the technical and organizational measures in place and compliance with the GDPR.

  • Special Categories Data - where we obtain and process any special category information, we do so in complete compliance with the Article 9 requirements and have high-level encryptions and protections on all such data. Special category data is only processed where necessary and is only processed where we have first identified the appropriate Article 9(2) basis or the Data Protection Bill Schedule 1 condition. Where we rely on consent for processing, this is explicit and is verified by a signature, with the right to modify or remove consent being clearly signposted.

 

Data Subject Rights

In addition to the policies and procedures mentioned above that ensure individuals can enforce their data protection rights, we provide easy to access information via [our website, in the office, during induction etc] of an individual’s right to access any personal information that Casesensitive Consulting Inc. processes about them and to request information about: -

  • What personal data we hold about them

  • The purposes of the processing

  • The categories of personal data concerned

  • The recipients to whom the personal data has/will be disclosed

  • How long we intend to store your personal data for

  • If we did not collect the data directly from them, information about the source

  • The right to have incomplete or inaccurate data about them corrected or completed and the process for requesting this

  • The right to request erasure of personal data (where applicable) or to restrict processing in accordance with data protection laws, as well as to object to any direct marketing from us and to be informed about any automated decision-making that we use

  • The right to lodge a complaint or seek judicial remedy and who to contact in such instances

 

Information Security & Technical and Organizational Measures

Casesensitive Consulting Inc. takes the privacy and security of individuals and their personal information very seriously and take every reasonable measure and precaution to protect and secure the personal data that we process. We have robust information security policies and procedures in place to protect personal information from unauthorized access, alteration, disclosure or destruction and have several layers of security measures, including: SSL, access controls, password policy, encryptions.

Casesensitive Consulting Inc. understands that continuous employee awareness and understanding is vital to the continued compliance of the GDPR and have involved our employees in our preparation plans. We have implemented an employee training program specific to the which will be provided to all employees prior to May 25th, 2018, and forms part of our induction and annual training program.

If you have any questions about our preparation for the GDPR, please contact Raj Dhatt.


If at any time you would like to unsubscribe from receiving future emails, you can email us at

info@casesensitive.ca and we will promptly remove you from ALL correspondence.

Contacting Us

If there are any questions regarding this privacy policy, you may contact us using the information below.
 

Customer Support

casesensitive.ca

info@casesensitive.ca

(604) 369-8803


Last Edited on February 5 2019

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