BENNINGTON LIMOUSINE CODE OF PRIVACY
INTRODUCTION
Bennington Limousine Inc.is an executive limousine seNice providing a wide range of executive ground transportation seNices throughout Ontario Canada, and through our affiliated network in over four hundred and fifty Cities worldwide.
We collect personal and business information on individuals and Corporations on a daily basis to facilitate the seNices that we offer.
We at Bennington Limousine Inc.embrace the new “Federal Personal Information Protection and Electronics Documents Act ( PIPEDA”) and acknowledge the importance of national standards to protect the personal information that we collect.
Bennington Limousine is licensed and tightly controlled by The Ministry of Transportation of Ontario, Canada.
1. ACCOUNTABILITY
Bennington Limousine Inc. will be responsible for all personal information under our control.
We have designated two individuals, headed up by our Chief Privacy Officer, to ensure our organization’s compliance with the policies and procedures of the act ( PIPEDA ).
The Chief Privacy Officer of Bennington Limousine Inc. is
Brian Beaulieu. Mr. Beaulieu can be reached at:
Bennington Limousine Inc.
6215 Kennedy Road, Unit A
Mississauga, Ontario, Canada
L5T 288
1-800-313-7262
bennington@benningtonlimo.com
Upon receiving an inquiry, Mr. Beaulieu will respond to you within 30 days.
It is Bennington Limousine Inc.’s commitment to:
• Protect personal information
• Allow individuals to request information; seek amendments to Itheir personal information; and file complaints agains1t Bennington Limousine Inc. with our privacy officer.
• Train and educate our staff on the policy and procedures of (PIPEDA)
• Develop information, which explains these procedures to our clients.
2. IDENTIFY PURPOSES
Bennington Limousine will identify the purpose for which we collect information on individuals, or (;orporations on, or before the time of collection.
We may choose to orally explain to the individuals, or representatives of the Corporations, the purpose for which the personal information is being collected, and then place a notation in the applicable file indicating that this has been done. Alternatively, an application form may be used.
Bennington Limousine may identify any new purpose that may arise during the course of dealing with personal information in order to facilitate the services we provide and obtain prior consent required for this new use, even if we have already identified certain initial services.
3. CONSENT
We will obtain the appropriate (;onsent from individuals, or corporations, for collection, USE! or disclosure of personal information.
We may obtain express consent for the collection, user disclosure of personal information, or when we determine that consent has been applied by the circumstances.
Express consent is specific authorization given by the individual, or representative of the corporation, to Bennington Limousine Inc.,
either orally, or in writing.
Implied consent is when Bennington Limousine Inc. has not received a specific consent, but the circumstances allow us to use, or disclose, personal information.
Personal information will only be collected, used and disclosed by Bennington Limousine Inc. employees without consent in accordance with Section 7 of “The Personal Information Protection and Electronics Documents Act”, S.C. 200,c.5 ( PIPEDA ) or under other lawful means.
4. LIMITING COLLECTION
The personal information that we collect will be limited to that which is necessary for the purposes that we have identified. We will only collect personal information for specific, legitimate purposes. We will not collect personal information indiscriminately.
Our Policies and procedures relating to the limitation on collection of personal and corporate information will be regularly communicated to our staff who deal with the collection, use, and disclosure of personal and corporate information.
5. LIMITING USE, DISCLOSURE, AND RETENTION
Personal information will not IDe used or disclosed for any purpose other than those for which it il; collected, except with the consent of the individual, or as permitted by law. We will only retain personal information as long as necessary for the fulfillment of those purposes, Personal information that is no longer required to provide the services we offer will be destroyed erasled or made anonymous.
6. ACCURACY
The personal information we collect will be accurate, complete and up-to-date as necessary, for its intended purposes.
The process for ensuring accuracy and compliance will involve:
• initial collection from the client
• client will be asked to verify accuracy and completeness
• regular reviews
If an error is identified, we will correct the information, and advise the client of the action taken.
7. SAFEGUARDS
Bennington Limousine Inc. will safeguard all personal information under our control in a manner that is appropriate to the sensitivity of the information. We will take all the physical security measures necessary, including alarming, and properly locking our facilities, and locking all personal information in secure filing cabinets. All
Bennington Limousine staff, including chauffeurs and administration staff, have been properly trained in the policies that pertain to these safeguards.
No unauthorized personnel will have access to areas where personal information is stored. No personal information, pertaining to clients will be electronically transferred to our clients unless the electronic files have been encrypted with an industry standard encryption program before being transferred. Distribution of personal information will be on a need to know basis.
We will take precautions in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information. These measures include:
• ensuring that no one may retrieve personal information after disposal.
• shredding documents before recycling them.
• Deleting electronically stored information.
8. OPENNESS
We will make readily available to individuals requesting specific information about our policies and procedures relating to the management of personal information that is under our control.
Bennington Limousine, and its staff, will make available to the public easily understandable information about our company, its policies, the code of privacy, both in hard copy, or by requesting a copy of same, by calling toll free 1-800- 313-7262.
9. INDIVIDUAL ACCESS
Upon request, an individual will be informed of the existence, use and disclosure of his/her personal information, which is under our control, and may be given access to, and be permitted to challenge the accuracy or deletion of that information.
There are lawful expectations that will prevent us from providing access, which include, but are 110t limited to, the following;
Personal information about another person might be revealed.
Commercially confidential information might be revealed.
10. CHALLENGING COMPLIANCE
An individual may address a challenge concerning compliance with the aforementioned policies and procedures to our Privacy Officer, the details of which are listed in Section 1.