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Disclaimer
The Bell Aliant Code of Fair Information Practices complies fully with the Personal Information Protection and Electronics Document Act and incorporates the ten principles of the Canadian Standards Association (CSA) Model Code for the Protection of Personal Information (CAN/CSA-Q830-96) which was published in March 1996 as a National Standard of Canada. Certified by QMI, a Division of CSA, November, 2000.
Introduction
Bell Aliant is Atlantic Canada's largest telecommunications company, offering customers a complete suite of leading edge telecom products and services.
Bell Aliant is committed to maintaining the accuracy, confidentiality, security and privacy of customer and employee personal information. This is reflected in existing privacy and confidentiality provisions found in various Bell Aliant policies and in applicable service rules approved by regulatory agencies over the years. It is also reflected in the high regard and trust with which customers and employees view the management of personal information by Bell Aliant.
In March 1996, the new Canadian Standards Association Model Code for the Protection of Personal Information , CAN/CSA-Q830-96 (the “CSA Code”), was published as a National Standard of Canada. Bell Aliant's Code of Fair Information Practices describes how we subscribe to the principles of the CSA Code.
The Bell Aliant Code of Fair Information Practices (the “Bell Aliant Code”) is a formal statement of principles and guidelines concerning the minimum requirements for the protection of personal information provided by Bell Aliant to our customers and employees. The objective of the Bell Aliant Code is responsible and transparent practices in the management of personal information, in accordance with the National Standard and all applicable legislation.
Bell Aliant will review the Code at least every five years to make sure it is relevant and remains current with changing technologies and laws and the evolving needs of Bell Aliant, our customers and employees.
Summary of Principles
Principle 1: Accountability
Bell Aliant is responsible for personal information under its control and shall designate one or more persons who are accountable for the company's compliance with the following principles.
Principle 2: Identifying Purposes for Collection of Personal Information
Bell Aliant shall identify the purposes for which personal information is collected at or before the time the information is collected.
Principle 3: Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of a customer or employee are required for the collection, use or disclosure of personal information, except where inappropriate.
Principle 4: Limiting Collection of Personal Information
Bell Aliant shall limit the collection of personal information to that which is necessary for the purposes identified by the company. Bell Aliant shall collect personal information by fair and lawful means.
Principle 5: Limiting Use, Disclosure and Retention of Personal Information
Bell Aliant shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Bell Aliant shall retain personal information only as long as necessary for the fulfillment of those purposes.
Principle 6: Accuracy of Personal Information
Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
Principle 7: Security Safeguards
Bell Aliant shall protect personal information by security safeguards appropriate to the sensitivity of the information.
Principle 8: Openness Concerning Policies and Practices
Bell Aliant shall make readily available to customers and employees specific information about its policies and practices relating to the management of personal information.
Principle 9: Customer and Employee Access to Personal Information
Bell Aliant shall inform a customer or employee of the existence, use and disclosure of his or her personal information upon request and shall give the individual access to that information. A customer or employee shall be able to challenge the accuracy and completeness of the information and to have it amended as appropriate.
Principle 10: Challenging Compliance
A customer or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Bell Aliant's compliance with the Bell Aliant Code.
Scope and Application
The 10 principles that form the basis of the Bell Aliant Code are interrelated and Bell Aliant shall adhere to the 10 principles as a whole. Each principle must be read in conjunction with the accompanying commentary. As permitted by the CSA Code, the commentary in the Bell Aliant Code has been tailored to reflect personal information issues specific to Bell Aliant.
The scope and application of the Bell Aliant Code are as follows:
- The Bell Aliant Code applies to personal information about Bell Aliant's customers and employees that is collected, used or disclosed by the company.
- The Bell Aliant Code applies to the management of personal information in any form whether oral, electronic or written.
- The Bell Aliant Code does not impose any limits on the use or disclosure of the following information by Bell Aliant:
- Information that is publicly available, such as a customer's name, address, telephone number and electronic address, when listed in a directory or made available through directory assistance; or
- The name, title or business address or telephone number of an employee of an organization.
- The application of the Bell Aliant Code is subject to the requirements or provisions of any applicable legislation, regulations, tariffs or agreements (such as collective agreements), or the order of any court or other lawful authority.
Definitions
Bell Aliant : Bell Aliant Regional Communications L. P. and any successors and assigns resulting from a corporate reorganization or restructuring.
Collection : The act of gathering, acquiring, recording or obtaining personal information from any source, including third parties, by any means.
Consent : Voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing but is always unequivocal and does not require any inference on the part of Bell Aliant. Implied consent is consent that can reasonably be inferred from an individual's action or inaction.
Customer : An individual who:
- uses, or applies to use, Bell Aliant's products or services;
- corresponds with Bell Aliant;
- or enters an Bell Aliant contest.
Disclosure : Making personal information available to a third party.
Employee : An employee or pensioner of Bell Aliant.
Personal information : Information about an identifiable individual that is recorded in any form but not aggregated information that cannot be associated with a specific individual. For a customer , such information includes a customer's credit information, billing records, service and equipment, and any recorded complaints. For an employee , such information includes information found in personal employment files, performance appraisals and medical and benefits information.
Third party : An individual other than the customer or his agent or an organization other than Bell Aliant.
Use : The treatment, handling, and management of personal information by Bell Aliant.
Principle 1 - Accountability
Bell Aliant is responsible for personal information under its control and shall designate one or more persons who are accountable for the company's compliance with the following principles.
| 1.1 |
Responsibility for ensuring compliance with the provisions of the Bell Aliant Code rests with the senior management of Bell Aliant, which shall designate one or more persons to be accountable for compliance with the Bell Aliant Code. Other individuals within Bell Aliant may be delegated to act on behalf of the designated person(s) or to take responsibility for the day-to-day collection and processing of personal information. |
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| 1.2 |
Bell Aliant shall make known, upon request, the title of the person or persons designated to oversee the company's compliance with the Bell Aliant Code.
Bell Aliant has designated the Bell Aliant Privacy Manager to oversee compliance with the Bell Aliant Code. The Bell Aliant Privacy Manager can be contacted at:
The Privacy Manager
Bell Aliant
Corporate Security and Privacy
1505 Barrington Street
P.O. Box 880 , Station Central
Halifax , NS B3J 2W3
PrivacyManager@aliant.ca |
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| 1.3 |
Bell Aliant is responsible for personal information in its possession or control, including information that has been transferred to a third party for processing. Bell Aliant shall use appropriate means to provide a comparable level of protection while information is being processed by a third party (see Principle 7). |
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| 1.4 |
Bell Aliant has implemented policies and procedures to give effect to the Bell Aliant Code, including:
- implementing procedures to protect personal information and to oversee the company's compliance with the Bell Aliant Code;
- establishing procedures to receive and respond to inquiries or complaints;
- training and communicating to staff about the company's policies and practices; and
- developing public information to explain the company's policies and practices.
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Principle 2 - Identifying Purposes for Collection of Personal Information
Bell Aliant shall identify the purposes for which personal information is collected at or before the time the information is collected.
| 2.1 |
Bell Aliant collects personal information only for the following purposes:
- To establish and maintain responsible commercial relations with customers and to provide ongoing service;
- To understand customer needs;
- To develop, enhance, market or provide products and services;
- To manage and develop our business and operations, including personnel and employment matters; and
- To meet legal and regulatory requirements.
Bell Aliant may also share personal information with affiliated Bell companies, including Bell Canada, Bell Mobility, Bell ExpressVu and Bell World and Espace Bell stores, to develop, enhance, market or provide products and services. Further references to “identified purposes” mean the purposes identified in Principle 2. |
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| 2.2 |
Bell Aliant shall specify orally, electronically or in writing the identified purposes to the customer or employee at or before the time personal information is collected. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within Bell Aliant who shall explain the purposes.
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| 2.3 |
Unless required by law, Bell Aliant shall not use or disclose, for any new purpose, personal information that has been collected without first identifying and documenting the new purpose and obtaining the consent of the customer or employee. |
Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of a customer or employee are required for the collection, use or disclosure of personal information, except where inappropriate.
| 3.1 |
In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual. For example, Bell Aliant may collect or use personal information without knowledge or consent if it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is a minor, seriously ill or mentally incapacitated.
Bell Aliant may also collect, use or disclose personal information without knowledge or consent if seeking the consent of the individual might defeat the purpose of collecting the information such as in the investigation of a breach of an agreement or a contravention of a federal or provincial law.
Bell Aliant may also use or disclose personal information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened.
Bell Aliant may disclose personal information without knowledge or consent to a lawyer representing the companies, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required by law. |
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| 3.2 |
In obtaining consent, Bell Aliant shall use reasonable efforts to ensure that a customer or employee is advised of the identified purposes for which personal information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the customer or employee.
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| 3.3 |
Generally, Bell Aliant shall seek consent to use and disclose personal information at the same time it collects the information. However, Bell Aliant may seek consent to use and disclose personal information after it has been collected but before it is used or disclosed for a new purpose. |
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| 3.4 |
Bell Aliant will require customers to consent to the collection, use or disclosure of personal information as a condition of the supply of a product or service only if such collection, use or disclosure is required to fulfill the identified purposes. |
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| 3.5 |
In determining the appropriate form of consent, Bell Aliant shall take into account the sensitivity of the personal information and the reasonable expectations of its customers and employees. |
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| 3.6 |
In general, the use of products and services by a customer, or the acceptance of employment or benefits by an employee, constitutes implied consent for Bell Aliant to collect, use and disclose personal information for all identified purposes. |
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| 3.7 |
A customer may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Customers may contact Bell Aliant for more information regarding the implications of withdrawing consent. |
Principle 4 - Limiting Collection of Personal Information
Bell Aliant shall limit the collection of personal information to that which is necessary for the purposes identified by the company.
Bell Aliant shall collect personal information by fair and lawful means.
| 4.1 |
Bell Aliant collects personal information primarily from its customers or employees. |
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| 4.2 |
Bell Aliant may also collect personal information from other sources including credit bureaus, employers or personal references, or other third parties that represent that they have the right to disclose the information. |
Principle 5 - Limiting Use, Disclosure and Retention of Personal Information
Bell Aliant shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law.
Bell Aliant shall retain personal information only as long as necessary for the fulfillment of the purposes for which it was collected.
| 5.1 |
In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual. (See Principle 3.1) |
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| 5.2 |
Bell Aliant may disclose a customer's personal information to:
- another telecommunications company for the efficient and effective provision of telecommunications services;
- a company involved in supplying the customer with communications or communications directory related services;
- another person for the development, enhancement, marketing or provision of any of Bell Aliant's products or services;
- an agent retained by Bell Aliant in connection with the collection of the customer's account;
- credit grantors and reporting agencies;
- a person who, in the reasonable judgment of the company, is seeking the information as an agent of the customer; and
- a third party or parties, where the customer consents to such disclosure or disclosure is required by law.
Bell Aliant may also share customer information with affiliated Bell companies, including Bell Canada, Bell Mobility, Bell ExpressVu and Bell World and Espace Bell stores, to develop, enhance, market or provide products and services. |
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| 5.3 |
Bell Aliant may disclose personal information about its employees:
- for normal personnel and benefits administration;
- in the context of providing references regarding current or former employees in response to requests from prospective employers; or
- where disclosure is required by law.
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| 5.4 |
Only Bell Aliant's employees who require access for business reasons, or whose duties reasonably so require, are granted access to personal information about customers and employees. |
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| 5.5 |
Bell Aliant shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about a customer or employee, Bell Aliant shall retain, for a period of time that is reasonably sufficient to allow for access by the customer or employee, either the actual information or the rationale for making the decision. |
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| 5.6 |
Bell Aliant shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous. |
Principle 6 - Accuracy of Personal Information
Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
| 6.1 |
Personal information used by Bell Aliant shall be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a customer or employee. |
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| 6.2 |
Bell Aliant shall update personal information about customers and employees as and when necessary to fulfill the identified purposes or upon notification by the individual. |
Principle 7 - Security Safeguards
Bell Aliant shall protect personal information by security safeguards appropriate to the sensitivity of the information.
| 7.1 |
Bell Aliant shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. Bell Aliant shall protect the information regardless of the format in which it is held. |
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| 7.2 |
Bell Aliant shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used. |
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| 7.3 |
All of Bell Aliant's employees with access to personal information shall be required as a condition of employment to respect the confidentiality of personal information. |
Principle 8 - Openness Concerning Policies and Practices
Bell Aliant shall make readily available to customers and employees specific information about its policies and practices relating to the management of personal information.
| 8.1 |
Bell Aliant shall make information about its policies and practices easy to understand, including:
- The title and address of the person or persons accountable for the company's compliance with the Bell Aliant Code and to whom inquiries or complaints can be forwarded;
- The means of gaining access to personal information held by the company; and
- A description of the type of personal information held by the company, including a general account of its use.
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| 8.2 |
Bell Aliant shall make available information to help customers and employees exercise choices regarding the use of their personal information and the privacy enhancing services available from the company. |
Principle 9 - Customer and Employee Access to Personal Information
Bell Aliant shall inform a customer or employee of the existence, use and disclosure of his or her personal information upon request and shall give the individual access to that information.
A customer or employee shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
| 9.1 |
Upon request, Bell Aliant shall afford to a customer or an employee a reasonable opportunity to review the personal information in the individual's file. Personal information shall be provided in understandable form within a reasonable time and at minimal or no cost to the individual. |
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| 9.2 |
In certain situations, Bell Aliant may not be able to provide access to all of the personal information it holds about a customer or employee. For example, Bell Aliant may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, Bell Aliant may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law. If access to personal information cannot be provided, Bell Aliant shall provide the reasons for denying access upon request. |
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| 9.3 |
Upon request, Bell Aliant shall provide an account of the use and disclosure of personal information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, Bell Aliant shall provide a list of organizations to which it may have disclosed personal information about the individual when it is not possible to provide an actual list.
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| 9.4 |
In order to safeguard personal information, a customer or employee may be required to provide sufficient identification information to permit Bell Aliant to account for the existence, use and disclosure of personal information and to authorize access to the individual's file. Any such information shall be used only for this purpose. |
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| 9.5 |
Bell Aliant shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual's file. Where appropriate, Bell Aliant shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences. |
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| 9.6 |
A customer can obtain information or seek access to his or her individual file by contacting a designated representative at one of Bell Aliant's business offices. |
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| 9.7 |
An employee can obtain information or seek access to his or her individual file by contacting his or her immediate supervisor within Bell Aliant. |
Principle 10 - Challenging Compliance
Principle 10: Challenging Compliance
A customer or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Bell Aliant's compliance with the Bell Aliant Code.
| 10.1 |
Bell Aliant shall maintain procedures for addressing and responding to all inquiries or complaints from its customers and employees about the companies' handling of personal information. |
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| 10.2 |
Bell Aliant shall inform its customers and employees about the existence of these procedures as well as the availability of complaint procedures. |
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| 10.3 |
The person or persons accountable for compliance with the Bell Aliant Code may seek external advice where appropriate before providing a final response to individual complaints. |
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| 10.4 |
Bell Aliant shall investigate all complaints concerning compliance with the Bell Aliant Code. If a complaint is found to be justified, the company shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A customer or employee shall be informed of the outcome of the investigation regarding his or her complaint. |
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For more information on Bell Aliant's commitment to Privacy, contact us at the number shown on your monthly bill, or contact us through our Web site : |
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www.aliant.net |
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| For additional copies of the Bell Aliant Code of Fair Information Practices please write to us or visit an Internet web site indicated above. |
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| For copies of the CSA Model Code for the Protection of Personal Information contact: |
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Canadian Standards Association
178 Rexdale Blvd.
Etobicoke, Ontario M9W 1R3 |
©Copyright 2000
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