Trotter & Morton is committed to protecting the privacy of the personal and business information which is collected, used and disclosed in the conduct of its business.
Trotter & Morton strives to protect and respect personal and business information of its customers, prospective employees, employees, business partners, and so on in accordance with all applicable provincial and federal laws. Every employee of Trotter & Morton must abide by this organization’s procedures and practices when handling personal information.
This policy shall apply to all entities in the Trotter and Morton Group of Companies, any individual conducting business on behalf of the Company, contractors, subcontractors, prospective employees, employees and former employees. Contractors and consultants are expected to develop and enforce policies and practices that are consistent with this policy.
3.0 AUTHORIZATION and REVISION
This Policy is the responsibility of the Human Resources Director and will be reviewed every 2 years.
This policy was created in July 2013.
Personal information means information about an identifiable individual and includes information about prospective, present or former employees and external parties such as subcontractors and contractors.
Business information means information about an identifiable business.
Business contact information means an individual’s name, position name or title, business telephone number, business address, business fax number and other similar business information.
The Company will only collect, use, and disclose personal information in compliance with applicable provincial or federal privacy legislation.
Where feasible, business information will be treated and handled with the same level of confidentiality, privacy, and respect as personal information.
This Policy does not apply to the collection use or disclosure of business contact information if the collection, use or disclosure, as the case may be, is for the purposes of enabling the individual to be contacted in relation to the individual’s business responsibilities and for no other purpose.
Trotter & Morton will obtain express or implied consent of individuals, except where otherwise permitted by law, to collect, use and disclose their personal information. When an individual signs a job application, new employee data form or other Trotter & Morton form containing personal information, they will be deemed to consent to allow Trotter & Morton to collect, use, and disclose the personal information for the purposes stated on the form or in the Appropriate Use section of this policy.
4.1 APPROPRIATE USE
Trotter & Morton collects and uses personal information solely for the purpose of conducting business and developing an understanding of its customers. Trotter & Morton hereby asserts that personal employee information will only be used for the following purposes:
1. Determining eligibility for initial employment, including the verification of references and qualifications
2. Credential verification
3. Payroll and benefit enrollment
4. Other reasonable purposes as required to manage the employment relationship
5. Municipal, provincial and federal requirements
4.2 POLICY STATEMENTS
1. Trotter & Morton assumes full accountability for the personal information within its possession and control. Trotter & Morton has appointed a custodian of all privacy matters and legal compliance with privacy laws.
2. Trotter & Morton obtains personal information directly from the individual to which the information belongs. Individuals are entitled to know how Trotter & Morton uses personal information and this organization will limit the use of any personal information collected only to what is needed for those stated purposes. Trotter & Morton will obtain individual consent if personal information is to be used for any other purpose. Trotter & Morton will not use that information without the consent of the individual except in situations that are permitted by applicable privacy legislation.
3. Under no circumstances will Trotter & Morton sell, distribute, or otherwise disclose personal information or contact lists to third parties. However, limited disclosure may be required as part of Trotter & Morton fulfilling its stated business duties and day-to-day operations. This may include consultants, suppliers, or business partners of Trotter & Morton, but only in compliance with applicable privacy legislation.
4. Trotter & Morton will retain personal information only for the duration it is needed for conducting business. Once personal information is no longer required, it will be destroyed in a safe and secure manner. However, certain laws may require that certain personal information be kept for a specified amount of time. Where this is the case, the law will supersede this policy.
5. Trotter & Morton vows to protect personal information with the appropriate security measures, physical safeguards, and electronic precautions. Trotter & Morton maintains personal information through a combination of paper and electronic files. Where required by law or disaster recovery/business continuity policies, older records may be stored in a secure, offsite location.
Access to personal information will be authorized only for the employees and other agents of Trotter & Morton who require the information to perform their job duties, and to those otherwise authorized by law.
Trotter & Morton’s computer and network systems are secured by complex passwords. Only authorized individuals may access secure systems and databases.
Active files are kept in locked, fireproof filing cabinets behind locked doors.
Routers and servers connected to the Internet are protected by a firewall and are further protected by virus attacks or “snooping” by sufficient software solutions.
Personal information is not transferred to volunteers, summer students, interns, or other non-paid staff by e-mail or any other electronic format.
7. In most instances, Trotter & Morton will grant individuals access to their personal information upon presentation of a written request to the Human Resources department and satisfactory identification. Trotter & Morton will respond to employees’ requests as soon as possible and no later than thirty (30) days after the request is made. If an individual finds errors of fact with his/her personal information, please notify the Human Resources department as soon as possible to make the appropriate corrections. To ensure the accuracy of Trotter & Morton’s employee personal information, employees are encouraged to immediately notify the Payroll department, in writing, of any changes such as name, address or telephone number changes. Should Trotter & Morton deny an individual’s request for access to his/her personal information, Trotter & Morton will advise in writing of the reason for such a refusal.
8. Trotter & Morton may use personal information without the individual’s consent under particular circumstances. These situations include, but are not limited to:
Trotter & Morton is under obligation by law to disclose personal information in order to adhere to the requirements of an investigation of the contravention of a provincial or federal law, under the purview of the appropriate authorities.
An emergency exists that threatens an individual’s life, health, or personal security.
The personal information is for in-house statistical study or research.
The personal information is already publicly available.
Disclosure is required to investigate a breach of contract or for purposes of a legal proceeding.
Disciplinary action up to and including termination of employment or service contracts will be taken for violations of this Policy and its related practices as per Trotter & Morton’s Progressive Discipline Policy.
Trotter & Morton reserves the right to amend or terminate this policy in whole or in part at any time, without prior notice to or consent of any employee or individual. The Company retains the sole and absolute discretionary authority to resolve all questions regarding the administration, application or interpretation of the policy. This authority includes construing the terms of the policy, including any disputed or ambiguous terms and determining the eligibility of any individual to self-nominate under this policy. The Company’s determination shall be conclusive and binding on all persons.