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Pomer and Boccia Professional Corporation Limited Privacy Policy Personal Information Protection and Electronic Documents Act

The staff and management of Pomer and Boccia Professional Corporation are committed to respecting the personal privacy of individuals we deal with.

Pomer and Boccia Professional Corporation will comply with (i) Personal Information Protection and Electronic Document Act (PIPEDA), a federally enacted act which protects personal information that is collected, used or disclosed; (ii) Collection Agencies Act, which dictates how we are to perform our services, collection and use of personal information and any future provincial legislation as it relates to the rights of consumers. For the purposes of this policy, personal information means information about an identifiable individual, but does not include the name, title, or business address or telephone number of an employee of an organization. Any reference to a Consumer within this policy is in reference to personal information and not business information.

The Canadian Standards Association Mode Code (“code”) for the protection of personal information is a national standard that was developed by the Canadian Standards Association. The Code is the central part of PIPEDA. The Code’s ten privacy principles are identified in PIPEDA as follows:

  • Accountability
  • Identifying Purpose
  • Consent
  • Limiting Collection
  • Limiting Use, Disclosure & Retention
  • Accuracy
  • Safeguards
  • Openness
  • Individual Access
  • Challenging Compliance

Pomer and Boccia Professional Corporation has implemented policies and procedures to give effect to the principles including:

  • Implementing procedures to protect information.
  • Establishing procedures to receive and respond to complaints and inquiries in connection with the collection, use and disclosure of personal information of Pomer and Boccia Professional Corporation.
  • Training staff and communicating information to Pomer and Boccia Professional Corporation staff about our policies and procedures.
  • Developing information to explain the policies of and procedures of Pomer and Boccia Professional Corporation Consumers.

The ten (10) principles are explained in more detail as follows:

  1. Accountability
    Pomer and Boccia Professional Corporation is responsible for the personal information under its control and has designated two (2) Privacy Officers to be accountable for Pomer and Boccia Professional Corporation compliance with PIPEDA.

  2. Identifying Purpose
    Pomer and Boccia Professional Corporation will identify and document the purpose for which it collects personal information. Only personal information is necessary for those identified purpose will be collected.

    Pomer and Boccia Professional Corporation shall only collect, use and disclose personal information about Consumers for the following purpose: a) To sell Consumer lists to other entities.

  3. Consent
    The knowledge and consent of Consumers is required for the collection, use or disclosure of personal information, except when inappropriate, including where permitted or required by law.

    In certain circumstances, personal information can be collected, used or disclosed without the knowledge or consent of the Consumer. For example, legal, medical, debt collection or locating the Consumer for their benefit.

    Although information may be publicly available, Pomer and Boccia Professional Corporation will treat this in accordance with PIPEDA principles. Moreover, Pomer and Boccia Professional Corporation may provide personal information to its lawyers, agents to collect a debt, comply with a subpoena, warrant or other court order, to a government institution requesting the information upon lawful authority, or as may be otherwise required by law. In all cases, proper internal authorization for disclosure procedures will be followed.

  4. Limiting Collection
    The collection of personal information will be limited to that which is appropriate in the circumstances.

    The Pomer and Boccia Professional Corporation Website does not use or capture cookies; a technology that installs a small amount of information on a visitor’s computer to permit the Website to recognize future visits from that computer.

  5. Limiting Use, Disclosure & Retention
    Pomer and Boccia Professional Corporation will not use or disclose personal information for purpose other than those for which it was collected, except with consent of the Consumer or as required by law. Personal information cannot be used or passed on in a manner inconsistent with the identified purpose.

    Pomer and Boccia Professional Corporation may disclose a Consumer’s personal information to third parties retained by Pomer and Boccia Professional Corporation for the purpose of collecting a debt from a Consumer.

    Certain Pomer and Boccia Professional Corporation employees may be given access to a Consumer’s personal information collected by Pomer and Boccia Professional Corporation in so far as their duties require access for the purposes outlined. Pomer and Boccia Professional Corporation employees are governed by a non-disclosure agreement prohibiting disclosure or use of any confidential or personal information for any purpose other than the stated purpose.

    Personal information that has been used to make a decision about a Consumer will be retained in accordance with the Pomer and Boccia Professional Corporation document retention guidelines. Personal information that is no longer required will be destroyed, erased or made anonymous. Pomer and Boccia Professional Corporation retains personal information of a consumer only for as long as it is required for Pomer and Boccia Professional Corporation business purposes or as required by federal and provincial laws.

  6. Accuracy
    Pomer and Boccia Professional Corporation will take reasonable steps to ensure that the personal information under its control is as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

    Pomer and Boccia Professional Corporation will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected. Pomer and Boccia Professional Corporation will take reasonable steps to ensure that personal information that is used on an ongoing basis, including personal information that is disclosed to third parties, is as accurate and up-to-date.

    Access to a Consumer’s personal information on record with Pomer and Boccia Professional Corporation may be requested by the Consumer in order to review and amend their personal information, as appropriate.

  7. Safeguards
    Pomer and Boccia Professional Corporation will take responsible steps to protect personal information through security safeguard as appropriate to the sensitivity of the personal information. Employees of Pomer and Boccia Professional Corporation who have access to personal information will be made aware of the importance of maintaining the confidentiality of personal information. Security safeguards protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

  8. Openness
    Pomer and Boccia Professional Corporation will make availability to any Consumer specific information about its policy and guidelines relating to the management of personal information.

    Pomer and Boccia Professional Corporation will be open about its policy and procedure with respect to the management of personal information, and Consumer will be able to acquire information about these policies. This policy and any related information is available at all times on Pomer and Boccia Professional Corporation website, www.pomerandboccia.com under Privacy Act.

  9. Individual Access
    Pomer and Boccia Professional Corporation will inform a Consumer of the existence, use and disclosure of their personal information and will provide access to that personal information, upon written request. Pomer and Boccia Professional Corporation will assist a Consumer in the preparation of a request for access when such a Consumer request assistance. Pomer and Boccia Professional Corporation will inform the Consumer whether or not it holds personal information about them, and will indicate the source of any such personal information, when possible.

    There may, however be situations in which Pomer and Boccia Professional Corporation will not be able to provide access to all the personal information that it holds about a Consumer, although these situations will be limited and specific, and permitted or required by law. For example, Pomer and Boccia Professional Corporation will not be able to provide access to Consumer’s personal information where given such access would likely reveal personal information about a third party, unless that third party’s personal information can be severed from the Consumer’s personal information. If Pomer and Boccia Professional Corporation refuse a request for access, the Consumer will be informed in writing of the refusal, setting out the reasons for the refusal and informing the Consumer of their recourse.

    Pomer and Boccia Professional Corporation will require the Consumer requesting access to their personal information will provide the appropriate verification information required to obtain access to such personal information. This information will not be used for any purpose other than to permit Pomer and Boccia Professional Corporation to provide an account of the existence, use and disclosure of the Consumer’s personal information.

    Pomer and Boccia Professional Corporation will be as specific as possible in providing an account of third parties to which personal information has been disclosed, and will provide a list of organizations to which personal information has been disclosed.

    Pomer and Boccia Professional Corporation will respond to the Customer's request to access their personal information within a reasonable time, and not later than 30 days after receipt of the request. Pomer and Boccia Professional Corporation may be entitled to a 30 day extension to respond, in limited circumstances, in which case the Customer will be notified of such an extension, the new time limit, the reasons for extending the time limit, and their right to make a complaint to the Privacy Commissioner with respect to the extension.

    Pomer and Boccia Professional Corporation may charge a reasonable fee for responding to a request. This fee will be determined based on the request and any request specific administrative or system costs that may be incurred, and will advise the Customer, in advance, of the approximate cost. The personal information requested would be provided in a form that is generally understandable.

    A Customer will be able to challenge the accuracy and completeness of the personal information and have it amended as appropriate. Depending upon the nature of the personal information challenged, amendment may involve the correction, deletion or additional of information, and the amended information will be transmitted to third parties having access to the personal information, where appropriate.

    When a Customer's challenge to the accuracy and completeness of their personal information is not resolved to their satisfaction, Pomer and Boccia Professional Corporation will record the unresolved challenge and will transmit the existence of the unresolved challenge to third parties who have access to the personal information, where appropriate.

  10. Challenging Compliance
    A Customer will be able to address a challenge concerning compliance with the above principles to the Privacy Officer. Pomer and Boccia Professional Corporation will handle all complaints or inquiries about the policies and procedures relating to the handling of personal information in line with the processes that are in place.

    Pomer and Boccia Professional Corporation will inform Customers who make inquiries or lodge complaints of the existence of the relevant complaint procedures. Pomer and Boccia Professional Corporation will investigate all complaints, and if a complaint is justified, Pomer and Boccia Professional Corporation will take appropriate measures, including amending policies and procedures.

How to contact us

If you have any questions or comments about this Privacy Policy or you feel that your concerns or complaints have not been resolved to your satisfaction, please contact us

  • by calling our Head Office at 1-888-858-5529
  • by email
  • by fax to 905-850-9376
  • in writing to the Privacy Division:
    Pomer and Boccia Professional Corporation
    4000 Steeles Ave. West, Suite 215
    Woodbridge, Ontario
    L4L 4V9

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