BrandActive International Inc. and its subsidiary BrandActive (USA) Inc. (“BrandActive”) respects the privacy right of our clients and team members. We are committed to protecting all information in our possession or control. This policy guides how we collect, use and disclose personal information we require in the course of fulfilling our responsibilities and operating our business. This policy covers providing services to our clients and performing activities that form part of the operation of our business. There is a separate policy on our website usage that can be found here.
As outlined in BrandActive’s Code of Conduct, we comply with all applicable laws. Certain practices detailed in this policy are reflective of the requirements set out in the Personal Information Protection and Electronic Document Act (PIPEDA) and the General Data Protection Regulation (GDPR). At all times will BrandActive adhere to the requirements of the applicable law and respond to clients or team members regarding the protection of their personal information and privacy. If you have any questions about BrandActive’s privacy practices, contact the Privacy Officer, Sarah Icely at firstname.lastname@example.org.
We are accountable for the personal information in our possession or control.
This includes any personal information received directly (i.e. from team members) and indirectly (i.e. through corporate clients). To demonstrate our accountability, we:
- Appointed an individual to be responsible for our organization’s compliance and oversee any privacy issues
- Educated our team members about the policy and their role in protecting the personal information of our clients and team members
- Established policies and procedures aimed at protecting the personal information of our clients and team members
- Regularly assess our privacy management program to address any shortcomings
We will identify why we are collecting personal information at or before the time that the information is collected, subject to limited exceptions.
Client personal information
In most instances, BrandActive will collect, use or disclose personal information about clients only for the purpose of providing professional services, to comply with applicable laws or for the purpose of obtaining or support for technology or administrative purposes.
BrandActive may also collect, use or disclose personal information about clients and prospective clients the purpose of blogs, articles or other marketing related collateral. In these instances, BrandActive will request approval prior to using or disclosing this information.
BrandActive may also aggregate personal information with information from other sources for the purpose of improving our offering, and for use in presentations. In these instances, the information will be unidentifiable to any individual or organization.
You can withdraw your consent to the use and disclosure of your personal information by contacting our Privacy Officer or any member of the team assigned to your account.
Team member or potential team member personal information
BrandActive collects, uses and discloses personal information about its team members in order to establish manage or terminate the employment relationship. This includes critical processes such as payroll, compliance, benefit administration, performance management and other BrandActive programs, policies and employee relations.
BrandActive may also collect, use or disclose BrandActive team member personal information to develop business metrics and analytics, and to evaluate the effectiveness of our policies, programs and processes.
We may also collect, use or disclose BrandActive team member personal information in the course of regular business transactions, such as sales.
We also collect, use and disclose personal information from individuals seeking employment with BrandActive for the purpose of evaluating their application, to communicate with them regarding employment opportunities that may be of interest, and for the purpose of evaluating or monitoring BrandActive policies, programs and practices.
At or before the time that BrandActive collects personal information, we will inform BrandActive team members of the reasons why we require such information, what use will be made of it, and with whom it may be shared, except where we are permitted or required by law to collect, use or disclose personal information without providing such notice. For example, collection may occur without notice or consent as permitted by law in the course of an investigation.
BrandActive will collect, use or disclosure personal information about you with your freely given, specific, informed and unambiguous consent except where collection, use or disclosure without consent is permitted or required by law.
Client personal information
All clients who engage with BrandActive for professional services are provided with a SOW and Terms and Conditions documents (collectively the “engagement documents”). These engagement documents include information about how BrandActive may collect, use and disclose client personal information. By signing the engagement documents, the client is providing its consent to the collection, use and disclosure of personal information described in the engagement documents. If a client provides us with personal information relating to a third party, by signing the engagement documents the client represents and warrants that they have obtained consent from the third party to allow us to collect, use and disclose their personal information as described in the engagement documents.
Clients always have the option not to provide consent to the collection, use and disclosure of their personal information or to withdraw consent at a later stage, subject to contractual or legal restrictions and reasonable notice. It should be noted that where a client chooses not to provide us with the permission to collect, use or disclose personal information, we may not be able to provide services to that client.
Team member and potential team member personal information
Forms and documents (e.g. program documents, policies, etc.) used to provide services will describe the purpose for which personal information is collected and to whom it will be disclosed. If this information is not provided on the form or document, it will be provided by the requestor.
Employment candidates will also be advised of the purposes for which their personal information is being collected, used and disclosed.
In the event a team member or employment candidate does not provide us with permission to collect, use or disclose personal information, we may not be able to employ them.
BrandActive limits the amount and type of personal information we collect.
We will limit the collection of personal information to that which is reasonably required to provide our services and operate our business.
BrandActive 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.
If BrandActive uses or discloses 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. Examples of such scenarios include emergencies that threaten the safety of an individual or group, to comply with a subpoena or other circumstances.
BrandActive keeps files regarding its team members, including personal information required for employment laws and standards. These files will be retained until such information and documents are no longer required for legal, administrative or professional purposes; at which time they are destroyed.
Personal information is collected from potential BrandActive team members and retained by BrandActive for 24 months so that BrandActive may contact the applicant about other positions that may be of interest. This period may be lengthened if mutually agreed upon with the potential BrandActive team member and the human resources team. If the potential team member joins BrandActive, the personal information collected during the application process will be retained in order to establish, manage and terminate the employment relationship.
Additional information on this requirement can be found in BrandActive’s Data Retention Policy. For a copy of the policy, contact the Privacy Officer mentioned above.
BrandActive will seek to ensure the accuracy of the personal information in our possession.
Personal information collected from BrandActive team members and client must be accurate, complete and current in order to provide appropriate services. From time to time, clients and BrandActive team members may be asked to update their personal information. Individuals are encouraged to advise us of any changes to their personal information. Clients are encouraged to contact their consulting team to update their personal information. BrandActive team members and/or potential team members should review their profiles in our HRIS to ensure accuracy or contact human resources.
BrandActive will use the appropriate safeguards to ensure the security of your information.
BrandActive will protect personal information by using physically secure facilities, industry best practices technological tools and relevant organizational controls in which team members will be trained both on the importance and confidentiality of the personal information. The physical measures used include locked cabinets or rooms, restricted access to offices and otherwise secure environments that are not available to the public. To protect unauthorized electronic access to personal information, any information stored in electronic form is protected in a secure electronic environment. These practices, tools and controls are regularly reviewed to ensure they are up-to-date, and vulnerabilities are assessed. In the event there is a data breach, impacted individuals will be notified within 72 hours, unless technological safeguards are put in place to render data useless to the attacker.
BrandActive is open about the procedures used to manage your personal information.
A copy of this policy is available on our website and for our team members on our intranet. In addition, individuals can contact the Privacy Officer mentioned above. The Privacy Officer is also available for questions or complaints related to this policy.
BrandActive will advise individuals of what personal information we have in our possession about them, what it is used for and to whom it has been disclosed.
Personal information in our offices, on our servers or those of our service providers are accessible by authorized team members who require the access in connection with their role and responsibilities.
The right to access personal information is subject to legal restrictions and BrandActive will take reasonable steps to verify an individual’s identity before providing access. Individuals requesting this type of access must provide enough information for BrandActive to be able to respond. Clients can access a copy of their personal information on record by contacting a member of their consulting team. BrandActive team members or potential team members can obtain a copy of their personal information by contacting the human resources department. These requests for access will be provided at little to no cost to the requestor.
All requests for this type of information will be responded to as quickly as possible and within thirty days. If there are concerns with access, individuals may contact the Privacy Officer mentioned above. If BrandActive takes more than thirty days to respond to a request, the requestor will be notified and may complain to the Privacy Commissioner of Canada.
Individuals may challenge BrandActive’s compliance with this policy.
BrandActive will respond to complaints and questions relating to privacy. We will investigate and attempt to resolve all complaints.