Private Policy

General Philosophy

Schooley Mitchell Telecom Consultants is committed to ensuring that your privacy is protected. This Privacy Policy identifies the ways we ensure that your privacy and the confidentiality of your personal information are protected within our business, whether provided at our offices, paper based collections, electronic communications over the Internet or on the telephone. It also outlines what personal information Schooley Mitchell Telecom Consultants may collect and how we use or restrict the use of your personal information. The objectives of our Policy are to inform you of our commitments and actions for the protection of personal information and the rules we use to govern when we collect, hold, use or disclose personal information and data.

The privacy of our clients, our employees and visitors to our web sites is of prime importance to us. We are committed, no matter what the circumstances, to protect your privacy and our integrity. Our Policy is designed to meet or exceed the requirements of Canadian and United States Privacy law including the recently enacted Personal Information Protection and Electronics Documents Act (PIPEDA) and the principles and standards set forth in the Canadian National Standard for the Protection of Personal Information. We are committed to a constant self-evaluation of our practices and procedures and responding to our clients’ and our employees’ needs.

PIPEDA came about primarily so that individuals could be assured of retaining their privacy while participating in some form of electronic business or commerce. But the Act also applies to all personal information, not just that which is housed within a computer system. Therefore, compliance to the Act helps put in place safeguards to protect your business information and personal data. While the original intention of the Act is to foster electronic commerce by ensuring the protection of personal information, other benefits derived from the implementation of such a policy promote an organization’s reputation and help develop confidence with clients. Companies also are finding that organizational support amongst employees strengthens. Further, by implementing a Privacy Policy, companies can demonstrate a competitive advantage to their clients. Tomorrow’s world will cherish the attribute of protection even more strongly. Organizations that demonstrate their support in protecting their clients’ personal information will find increased growth as client confidence expands.

Protection of employee information within the company is also of prime importance. By protecting employee data, a company can increase employee respect and loyalty. Increased morale and corporate confidence that employees feel are the direct results of solid and fair policies and procedures.

Our organization’s Policy has been developed as a cooperative effort of several departments and of several areas of responsibility. These include information technology and computer security, communications and legal services.

An Individuals Rights

The Act gives individuals the right to know why an organization collects, uses or discloses personal information about them. It also gives an individual the right to expect an organization to collect, protect, use or disclose personal information reasonably and appropriately and not to use the information for any other purposes without again obtaining consent. Individuals have the right to obtain access to their personal information, ask for clarification, and to complain to the Privacy Commissioner of Canada about how an organization handles their personal information.

An Organization’s Responsibilities

An organization is responsible for the protection of personal information, the fair handling of it at all times within the organization and in dealings with third parties. These responsibilities are outlined in principles that an organization must follow including accountability, identification of purpose, obtaining consent, limits to collection, use disclosure and retention as well as accuracy, safeguards, openness, access and recourse.

The Act impacts personal information of our clients and our staff. It is imperative that a proper Privacy Policy, in conjunction with the right controls, procedures and training to support the policy, be established, maintained and communicated. It will be these activities that will protect the organization’s reputation, encourage employee morale and support and foster client relations.

Privacy Principles

Canada’s Personal Information Protection and Electronics Document Act is in place to assure individuals that their personal information is safeguarded by private sector companies with whom they conduct business. All organizations must comply with principles of the Act that specify limits and constraints for businesses and the rights of individuals. These principles involve the collection, consent, use, distribution, safeguards to protect, transmittal and complaint procedures of personal information.

Accountability: be responsible for the information which is collected

Identify the Purpose: identify reasons before or at collection

Obtain Consent: before or at collection and if the use changes

Limit Collection: to only what is needed to conduct business or the specific activity

Limit Use, Disclosure, and Retention: control access, consider third parties and outline limits for retention time

Be Accurate: minimize the risk of inaccuracies

Safeguard Appropriately: protect from loss, theft and misuse

Be Open: inform people of your policies and procedures

Grant Access: respond to requests within limited and stated time frames

Provide Recourse: provide a complaint procedure and process.

Our Use

Schooley Mitchell asks for your name, e-mail and other personal information when you join our pulse program or when you bring forth a complaint about services we have provided. The identification information is used to collect data about your preferences and for us to communicate with you as well as to correct service issues.

The information also enables our organization to customize programs as well as services to better meet your preferences and to offer you services appropriately. We may tailor our offers to you based on information you provide when you purchase services from us. We may also use information available from external sources including demographic and census data.

We may also consider utilizing on-line surveys to better understand the needs and profiles of clients of Schooley Mitchell. Survey information is used for internal management uses only. Your participation in surveys is optional. You will never be asked to respond to any survey in order to visit our web site or to take advantage of any of its features. This survey information will provide aggregate statistics about our clients and will not include any information or private details that identify you.

At this point in time, we will store data concerning your preferences and behaviours for an indefinite time period. If at any time you wish to withdraw from the pulse program, contact your local representative and request that your personal information be rendered inactive.

Within Schooley Mitchell Telecom Consultants

Schooley Mitchell strictly controls access to your personal information to employees who need this information to serve you or to those employees who analyze our performance to measure and improve our client service to you. Schooley Mitchell issues directives to its employees to inform, train and educate them in the matters included in this Policy as well as the privacy obligations/responsibilities they have to adhere to within this Policy.

Changes to our Privacy Policy

Schooley Mitchell reserves the right to change the Policy at any time. All changes will be posted on a timely basis on the web site entitled to inform you, our client, of the changes that might occur to our present Policy and procedures. However, regardless of changes or updates to our Privacy Policy, we will continue to adhere to the Act and will never use the information you submit under our current Policy in a new way without providing you an opportunity to give us your consent.

Contact Us

Schooley Mitchell wants to assure you that we are dedicated to protecting your privacy. We also understand that you may have questions and concerns about our organization’s Privacy Policies and procedures or changes to our Policy. If you have any comments, suggestions or questions, please contact us for further details about our web site applications.

Our Compliant Process

Schooley Mitchell is committed to ensuring the effective implementation of all of our Privacy Policies and Procedures. Nevertheless, in the event that a dispute, complaint or a problem may arise concerning our privacy policies and practices, a definite procedure for complaint resolution has been established. It is the intent of our organization’s complaint policy and processes to provide all clients with a “voice” in such potential adverse matters. The company is committed to resolving issues conflicts promptly, justly, objectively and confidentially.

A written outline of the issue should be forwarded directly to Schooley Mitchell who in turn will investigate, examine and evaluate all of the facts. On the information gathered and other related details, a formal written decision will be completed and will be forwarded to the client within 30 days. During the investigation of the conflict, it may be necessary for further private information to be shared with Schooley Mitchell Telecom Consultants or other appropriate parties either internal or external to the organization. In all cases, Schooley Mitchell Telecom Consultants will be responsible for the protection of all the information. Individuals may also contact the office of the Privacy Commissioner of the federal government if they are dissatisfied with the implementation of the policy by our organization.

Web Site

Schooley Mitchell Telecom Consultants collects personal information about you (information that could be used to identify you) when you voluntarily provide it. For example, you are asked to provide your first and last name, and e-mail address when you register for our pulse program or subscribe to our E-Book. If you e-mail us, we collect your e-mail address.

Schooley Mitchell Telecom Consultants uses your personal information to operate the site, to deliver and improve the products and services and if you ask us, to send you information about products, services or promotions that may be of interest to you. Schooley Mitchell Telecom Consultants gives you the opportunity to “opt-in” to receiving such information when you register for any of our services. Schooley Mitchell Telecom Consultants may also use your personal information to create aggregate information that does not allow you to be personally identified or contacted. Rather than showing individual activity, aggregate information shows user behaviour as a whole. For example, Schooley Mitchell Telecom Consultants might compile personal information in order to calculate the number of users living in certain geographic areas. Aggregate information is used in order to market and promote the site.

Schooley Mitchell Telecom Consultants may collect information about you and your use of the site through the use of “cookies”. Cookies are small data files that are sent to your browser and stored on your computer’s hard-drive when you visit certain web sites, thereby “tracking” use of the site. Some browsers can be set to reject all cookies; if you choose to modify your browser in this manner, some pages of the site may not function properly. Schooley Mitchell Telecom Consultants uses the information generated through the use of cookies to estimate the number of people that are using the site and to track the pages of the site that are being visited. This information tells us about user interests and behaviours which can, in turn, be used to provide you with information about products, services or promotions that may be of interest to you.

Schooley Mitchell Telecom Consultants will not, without your permission, disclose your personal information. However we reserve the right to disclose information to our affiliates, related companies, franchisees and third party service providers for purposes related to providing you with information about products, services or promotions that may be of interest to you.

Linked Sites

You should be aware that operators of linked web sites and advertisers on the site might also collect your personal information (including information generated through the use of cookies) when you link to their web sites or select their advertisements. Schooley Mitchell Telecom Consultants is not responsible for how such third parties collect, use or disclose your personal information, therefore you should check their privacy policies before providing them with any of your personal information.

When We Disclose Information

Schooley Mitchell reserves the right to release personal information to cooperate with local, provincial or federal agencies to identify those individuals who use or misuse this site or our services for fraudulent or other illegal activities. We will also release information if the rights or property of Schooley Mitchell Telecom Consultants, its affiliates, related companies, franchisees, third party service providers, the users of the site or the general public are in jeopardy. We will cooperate with government and other agencies in any legal investigation whether information is provided online or through participation within our pulse program.

How We Protect Your Privacy Online

Recognizing that your privacy is important to you, Schooley Mitchell Telecom Consultants employs technical security measures to protect your personal information. However, no transmission over the Internet can be guaranteed to be completely secure. Consequently, Schooley Mitchell Telecom Consultants, its affiliates, related companies, franchisees, third party service providers and their respective officers, directors, employees and agents do not represent, warrant or guarantee that personal information will be protected against misuse, loss or alterations and do not accept any liability for personal information submitted to them, nor for your or third parties’ use or misuse of personal information.

Privacy and Children

Schooley Mitchell Telecom Consultants web sites are neither developed nor created to be targeted to children (defined as those under 18) as an audience. As an organization, we do not collect information about the age of our web users. If, inadvertently, personal information is collected from a child, we will endeavour to take all necessary actions to delete the data from our records.