Personal Information Protection Policy
At McCoy Global Inc. (“McCoy” or “we”), we are committed to maintaining the security, confidentiality and privacy of your personal information. This Policy applies to McCoy and its divisions and subsidiaries.
McCoy has developed this Policy in compliance with the Personal Information Protection Act (“PIPA”) of Alberta. Where applicable, McCoy also complies with PIPA’s counterpart in British Columbia, and the federal Personal Information Protection and Electronic Documents Act.
This Policy addresses the ways in which McCoy collects, uses and discloses personal information about identifiable individuals, and does not apply to information collected, used or disclosed with respect to corporate or commercial entities.
This Policy outlines the principles and practices McCoy will follow with respect to your personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of your personal information and allowing you to request access to, and correction of, your personal information.
Scope of this Policy
This Policy applies to McCoy and any divisions and subsidiaries it may have from time to time. This Policy also applies to any service providers collecting, using or disclosing personal information on behalf of McCoy or its divisions or subsidiaries.
“Personal Information” means any information about an identifiable individual (for example, name, age, home address and phone number, social insurance number, marital status, income, or credit history). Personal information does not include contact information (described below) when that contact information is used for contacting an individual in their capacity as an employee of an organization.
“Contact information” means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.
“Privacy Officer” means the individual designated responsibility for ensuring that McCoy complies with this Policy and PIPA.
“Assistant Privacy Officer” means the individual designated responsibility for the practical application of this Policy and compliance with PIPA and other applicable legislation.
Collecting Personal Information
As part of our business activities, we may collect some or all of the following information from you, either directly or from various other sources:
- your name, address, home and mobile telephone numbers, home e-mail address;
- information about products and services you have obtained through us.
Unless the purposes for collecting personal information are obvious and you voluntarily provide your personal information for those purposes, McCoy will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
McCoy will only collect information that is necessary to fulfill the following purposes:
- verify identity;
- verify creditworthiness;
- report to and obtain reports from credit bureaus;
- identify customer preferences;
- understand the financial, banking, insurance needs of our customers;
- open and manage an account;
- deliver requested products and services;
- ensure a high standard of service to our customers;
- retain a contractor or agent who will perform services for us on an outsource or contract basis.
McCoy will obtain your consent to collect, use or disclose personal information except where McCoy is authorized or required by law to do so without your consent. For example, we may collect, use or disclose personal information without your knowledge or consent if the information is publicly available, we are obtaining legal advice, or we reasonably expect that obtaining consent would compromise an investigation or proceeding. Other exceptions may also apply.
Consent can be provided expressly, impliedly, orally, in writing, electronically, through an authorized representative or through inaction (for example, if we notify you that we want to collect, use or disclose your personal information for a specific purpose and you do not object).
Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), you can withhold or withdraw your consent in writing at any time. Your decision to withhold or withdraw consent may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist you in making your decision.
Using and Disclosing Personal Information
McCoy will only use or disclose your personal information where necessary to fulfill the purposes identified at the time of collection or as indicated in this Policy.
McCoy will not use or disclose your personal information for any additional purpose unless McCoy obtains consent to do so, or as authorized or required by law.
McCoy will not sell customer lists or personal information to other parties.
Retaining Personal Information
If McCoy uses your personal information to make a decision that directly affects you, McCoy will retain that personal information for at least one year so that you have a reasonable opportunity to request access to it. Otherwise, McCoy will retain your information only as long as is reasonable to fulfill the identified purposes or a legal or business purpose.
Ensuring Accuracy of Personal Information
McCoy will make reasonable efforts to ensure that personal information we are using or disclosing is accurate and complete. In most cases, we will rely on you to ensure that information is current, complete and accurate.
You may request correction to your personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. A request to correct personal information should be forwarded to the Assistant Privacy Officer.
If you demonstrate the inaccuracy of personal information, McCoy will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note your correction request in the file.
Securing Personal Information
McCoy makes reasonable security arrangements to protect your personal information from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
McCoy continually reviews and updates its security policies and controls as technology changes to ensure ongoing personal information security.
McCoy will take reasonable steps, through contractual or other reasonable means, to ensure our contractors, suppliers and others whom we ask to assist in providing goods and services implement a comparable level of personal information protection.
Note that confidentiality and security may not be assured when information is transmitted through e-mail, Internet or wireless communication. McCoy will not be responsible for any loss or damage suffered as a result of breach of security or confidentiality when you transmit information to us by e-mail or other Internet or wireless communication, or when we transmit information by such means.
Providing Access to Personal Information
You have the right to access your personal information held by McCoy, subject to limited exceptions as provided by law.
A request to access personal information must be made in writing on forms provided by McCoy and must provide sufficient detail to identify the personal information being sought. Requests to access personal information should be forwarded to the Assistant Privacy Officer.
Upon request, we will also tell you how we use your personal information and to whom it has been disclosed (if applicable).
We will make the requested information available within 45 business days (or as otherwise required by law), or provide written notice of an extension where additional time is required to fulfill the request.
McCoy may charge a minimal fee for providing access to personal information. Where a fee may apply, we will inform you of the cost and request further direction from you about whether or not to proceed with the request.
If a request is refused in full or in part, we will notify you in writing, providing the reasons for refusal and the available recourse, all as provided by law.
If you have applied for a job with McCoy, McCoy can collect, use or disclose personal information that is reasonably related to the hiring decision without your consent, so long as the collection, use and disclosure is reasonable. Information that is related to your hiring decision may include your qualifications, experience, knowledge, skills and education, and references.
If you submit an application for a specific position, McCoy will retain your application as set out in section 6. If you submit an application generally (i.e., not for a posted job opening, and not when requested by McCoy), McCoy will: (i) keep your application reasonably secure, if McCoy decides to keep your application on file; (ii) securely destroy your application, if McCoy decides that your application is not suited for McCoy’s current employment needs; and (iii) retain your application for at least one year if McCoy uses it to make a decision that directly affects you.
Questions and Complaints
The Assistant Privacy Officer is responsible for the practical application of this Policy. The Privacy Officer is responsible for ensuring McCoy ‘s compliance with this Policy and PIPA.
You should direct any complaints, concerns or questions regarding McCoy’s compliance in writing to the Assistant Privacy Officer. If the Assistant Privacy Officer is unable to resolve the concern, you may also write to the Information and Privacy Commissioner of Alberta.
Assistant Privacy Officer - Peter Watson
General Counsel & Corporate Secretary
#301, 9618 - 42 Avenue NW,