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Privacy Policy

C-Suite Solutions is a registered trade name for Clissold Professional Services Corp.  We respect the privacy rights of our clients and personnel and are committed to protecting all personal information in our possession or control. We have adopted this Privacy Policy to guide how we collect, use and disclose the personal information we require in the course of fulfilling our professional responsibilities and operating our business. This Privacy Policy applies to CLISSOLD PROFESSIONAL SERVICES CORP. and all of it’s divisions (collectively referred to in this Privacy Policy as “C-Suite Solutions”, “we”, “our” or “us”).

C-Suite Solutions takes the privacy of our clients and our personnel very seriously. We have developed this Privacy Policy to clearly define our ongoing commitment to protecting the privacy rights of our clients and personnel. Certain of the practices discussed in this Privacy Policy reflect requirements set out in Canadian federal and/or provincial privacy legislation. C-Suite Solution’s policy is to at all times adhere to the requirements of applicable law and professional responsibilities, and to be responsive to our clients and personnel who expect us to respect their privacy and to protect their personal information.

For purposes of this Privacy Policy, the term “personal information” means information about an identifiable individual, as more specifically defined by applicable privacy legislation.

 

Principle 1 - We are accountable for the personal information in our possession or control.

 

C-Suite Solutions is accountable for all personal information in our possession or control. This includes any personal information that we receive directly, for example, from individual clients and C-Suite Solutions personnel, as well as any personal information that we may receive indirectly, for example, through corporate and government clients. We have established policies and procedures aimed at protecting the personal information of our clients and personnel. We have appointed a Privacy Officer to oversee privacy issues for C-Suite Solutions. We have also educated C-Suite Solutions personnel about our Privacy Policy and their role in protecting the personal information of our clients and personnel.

 

Principle 2 – C-Suite Solutions will explain why we are collecting personal information at or before the time that the information is collected, subject to limited exceptions.

In most instances, C-Suite Solutions will collect, use or disclose personal information about clients only for the purpose of providing professional services, to comply with applicable laws, regulations and professional standards, or for the purpose of obtaining technological, administrative, analytical and clerical services or support.

Client personal information may also be collected, used or disclosed internally in the performance of quality reviews, or in order to allow us to offer services or products that may be of interest to clients.

Principle 3 – C-Suite Solutions limits the amount and type of personal information we collect.

C-Suite will limit the collection of personal information to that which is reasonably required to provide our services and to operate our business.

 

Principle 4 – C-Suite Solutions will use and disclose your personal information only for the purposes for which we have your consent or as permitted or required by law. We will keep personal information only as long as necessary to accomplish these purposes.

 

Use and Disclosure of Personal Information

 

If C-Suite Solutions intends to use or disclose personal information for any purpose not previously identified to an individual, we will obtain their prior consent unless we are permitted or required by law to use or disclose their personal information without consent.

For example, but without limitation, C-Suite Solutions may use and disclose personal information without consent:

  • for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual, including steps taken under our pandemic policies;

  • to prevent, detect or suppress fraud or financial abuse;

  • in connection with an investigation;

  • to comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction or to comply with rules of conduct required by regulatory bodies;

  • to a government institution that has requested the information, identified its lawful authority, and has indicated that disclosure is for the purpose of enforcing, administering, carrying out an investigation, or gathering intelligence relating to any federal, provincial or foreign law, or to national security or the conduct of international affairs; and

  • to an investigative body or government institution on our initiative when we believe the information concerns a breach of an agreement, or a contravention of a federal, provincial, or foreign law, or we suspect the information relates to national security or the conduct of international affairs.

 

Retention of Personal Information

 

In compliance with professional standards, we keep a record of the work performed by C-Suite personnel. This record, or “working papers”, may include personal information and will be retained until such working papers are no longer reasonably required for legal, administrative, audit, regulatory or professional purposes. Working papers are safeguarded against inappropriate access, as discussed in Principle 7 below.

C-Suite Solutions retains personal information about current and past C-Suite Solutions personnel in accordance with employment laws and standards. We will destroy human resources and other files containing C-Suite Solutions employee personal information when such information is no longer reasonably required for legal, administrative, audit or regulatory purposes.

 

Principle 5 – C-Suite Solutions will endeavor to keep accurate the personal information in our possession or control.

 

In order to provide clients with a professional level of service the personal information that we collect must be accurate, complete and current. From time to time, clients may be asked to update their personal information. Individuals are encouraged to advise us of any changes to their personal information.

 

Principle 6 - C-Suite Solutions protects your personal information with safeguards appropriate to the sensitivity of the information.

 

C-Suite Solutions will protect personal information by using physically secure facilities, industry standard security tools and practices, and clearly defined internal policies and practices. Security measures are in place to prevent the loss, misuse and alteration of the personal information under our control. Personal information is stored in secure environments that are not available to the public (e.g., restricted access premises, locked rooms and filing cabinets). To prevent unauthorized electronic access to personal information, any information that is stored in electronic form is protected in a secure electronic and physical environment.

We are responsible for all personal information transferred to third party service providers. We require third party service providers to respect the confidentiality of personal information and all legal requirements under applicable Canadian federal and provincial privacy legislation, and to agree to contractual requirements that are consistent with this Privacy Policy. These third party service providers are prohibited from using personal information except for the specific purpose(s) for which we supply it to them.

 

Principle 7 - At their request, C-Suite Solutions will advise individuals of what personal information we have in our possession or control about them, what it is being used for, and to whom and why it has been disclosed.

 

Personal information files are maintained in our offices or on our servers (or those of our service providers) and are accessible by authorized personnel, agents and mandataries who require access in connection with their job responsibilities.

 

Clients have the right to review and obtain a copy of their personal information on record in our individual offices by contacting their engagement partner.

The right to access personal information is subject to certain legal restrictions and we will take reasonable steps to verify an individual’s identity before providing access.

 

Principle 8 - Individuals may challenge C-Suite Solutions’ compliance with this Privacy Policy.

 

C-Suite Solutions will respond to individual complaints and questions relating to privacy. We will investigate and attempt to resolve all complaints.

 

MAY 2022

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