For Clients – personal information may include information about their current employees (position, compensation, performance rating, length of service, employment history, career plans, assessment results or training), their former employees (use of our services), purchase orders, invoices or any records of dealings with us. This information is used to manage the business relationship with the Client and to allow StratHR Solutions to complete assignments on behalf of the Client.
For Candidates – this may include contact information, services provided, records of consultant meetings, resume information, employment preferences, job search plans, references or assessment results. For career transition candidates, this information is used to help the candidate to plan and execute an effective job search.
For Employees and Contractors of StratHR Solutions Inc., this may include contact information, performance evaluations, employment history, employment arrangements, benefit plan participation, career plans and assessment results.
Personal information does not include information that is publicly available, such as person´s name, address, telephone number and electronic address, when listed in a directory or made available through directory assistance or other similar sources or that is the name, title or business address or telephone number of an employee of an organization.
2. Identifying the purposes for collection of personal information: The purposes for which personal information is collected will be identified by StratHR Solutions at or before the time the information is collected, unless such purposes are obvious. StratHR Solutions will ensure that the purposes for which personal information is collected and the way in which the information may be used are clear to the individual. In some cases, the purpose will be clear from the context of the interaction, in other circumstances, a written or verbal explanation may be required. Generally, StratHR Solutions Inc. collects personal information only for the following purposes:
• To establish and maintain responsible commercial relations with clients and to provide ongoing service and offers;
• To understand clients and candidates’ needs;
• To develop, enhance, market or provide products and services;
• To manage and develop StratHR Solutions business and operations, including personnel and employment matters;
• To meet legal and regulatory requirements including requirements or requests of government agencies or pursuant to a subpoena or other legal proceedings.
3. Obtaining consent: StratHR Solutions will not collect, use or disclose the personal information of a person without the individual’s knowledge and consent, except in certain limited circumstances permitted by law, such as where immediate health of a person is at risk, or in connection with the breach of an agreement or a law. The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except where noted below. The consent may be expressed, implied, or given through an authorized representative. In determining the appropriate form of consent, the sensitivity of the information and reasonable expectations of the individual is taken into account. Implied consent is generally appropriate when the information is less sensitive. Any consent, including any implied consent, will apply to information already in the possession of StratHR Solutions as of the date of the consent. StratHR Solutions makes reasonable efforts to inform its clients, candidates, contractors and employees how any personal information collected will be used and disclosed. To achieve this aim, the purposes for which the information will be used, if not obvious, will be explained in such a manner that the individual can reasonably understand how the information will be used or disclosed. Generally, consent to use and disclose personal information is sought at the same time it is collected. In certain circumstances, however, StratHR Solutions may identify a new purpose and seek consent to use and disclose the personal information after it has been collected. An individual can withdraw consent to use personal information at any time, subject to any legal or contractual restrictions and reasonable notice. StratHR Solutions will inform individuals of the implications, if any, of withdrawing consent and how to do so. Exceptions for collection, use and disclosure without consent Personal information may be collected without the knowledge or consent of the individual if:
• The collection is clearly in the interests of the individual and consent cannot be obtained in a timely way;
• It is reasonable to expect that the collection with the knowledge or consent of the individual would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;
• The information is publicly available and is specified by the regulations.
Personal Information may be used without the knowledge or consent of the individual if:
• In the course of its activities, StratHR Solutions becomes aware of information that it has reasonable grounds to believe could be useful in the investigation of a contravention of the laws of Canada, a province or a foreign jurisdiction that has been, is being or is about to be committed, and the information is used for the purpose of investigating that contravention;
• It is used for the purpose of acting in respect of an emergency that threatens the life, health or security of an individual;
• It is used for statistical, or scholarly study of research purposes that cannot be achieved without using the information, the information is used in a manner that will ensure its confidentiality, it is impracticable to obtain consent and StratHR Solutions informs the Privacy Commissioner of the use before the information is used;
• It is publicly available and is specified by the regulations;
• It was collected under paragraph (a)(i) or (ii) above.
Personal information may be disclosed without the knowledge or consent of the individual if the disclosure is:
• Made to, in the Province of Quebec, an advocate or notary or, in any other province, a barrister or solicitor who is representing the organization;
• For the purpose of collecting a debt owed by the individual to StratHR Solutions Inc.;
• Required to comply with a subpoena or warrant issued or an order made by a court, person or body with jurisdiction to compel the production of information, or to comply with rules of court relating to the production of records;
• Made to a government institution or part of a government institution or an investigative body that has made a request for the information and identified its lawful authority to obtain the information.
• Made to a person who needs the information because of an emergency that threatens the life, health or security of an individual and, if the individual whom the information is about is alive, the organization informs that individual in writing without delay of the disclosure;
• Of information that is publicly available and is specified by the regulations;
• Made by an investigative body and the disclosure is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province;
Or • required by law.
4. Limiting collection of personal information: StratHR Solutions will collect only the amount and type of personal information needed for the purposes it has identified. Personal information is collected by fair and lawful means. Although, StratHR Solutions will collect personal information primarily from clients, candidates, contractors and employees, it may also collect personal information from other sources such as credit bureaus, or other third parties who represent that they have the right to disclose the information.
5. Limiting use, disclosure and retention of personal information: The personal information that StratHR Solutions collects is used or disclosed only for the purposes specified above or for which it was collected, unless the individual gives consent or as required by law. StratHR Solutions may disclose personal information without consent when it is required to do so by law, e.g. subpoenas, search warrants, other court and government orders, or demands from other parties who have a legal right to personal information, or to protect the security and integrity of its network or system. In such circumstances, the interests of the individual are protected by ensuring that: orders or demands appear to comply with the laws under which they were issued; and StratHR Solutions discloses only the personal information that is legally required, and nothing more. The client, candidate, contractor or employee may be notified that an order requiring disclosure has been received, if the law allows it. StratHR Solutions may disclose Information to:
• Any person who, in its reasonable judgment, is seeking the Information as the agent of the customer, client or employee concerned;
• A person involved directly or indirectly in supplying the product or service to a customer, client or employee, including, without limitation, our sales and marketing agents, our administration team for invoice printing and mailing, our employee benefits and pension providers, and provided that such person is required to keep the Information confidential;
• A person retained by StratHR Solutions to collect amounts which are owed to it or to enforce StratHR Solutions’ rights under its terms and conditions, if the Information is required for, and is to be used only for that purpose and that person is required to keep such Information confidential. StratHR Solutions may share Information with potential business contractors of, or potential investors in StratHR Inc. StratHR Solutions may provide Information, including client information, as security for an investment in StratHR Solutions Inc. StratHR Solutions may provide information, including client information, to third parties who purchase assets from StratHR Solutions where such information is relevant to the assets so sold. Only employees with a business need-to-know, or whose duties so require, are granted access to client, candidate, contractor and employee personal information. StratHR Solutions will retain personal information only as long as necessary to fulfill the identified purposes. Depending on the circumstances, personal information used to make a decision about a client, candidate, contractor or employee is kept long enough to allow the client or employee access to the information after the decision has been made. StratHR Solutions has established reasonable guidelines and procedures for information and records retention, and any personal information no longer needed for its identified purposes or for legal requirements will be destroyed, erased or made anonymous within a reasonable period of time.
6. Ensuring accuracy of personal information: StratHR Solutions will make reasonable efforts to ensure that personal information of individuals is as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. Personal information will not be updated without the consent of the individual and it will only be updated if it is necessary for the continued use of the personal information. StratHR Solutions will make reasonable efforts to obtain information from individuals in order to update information on hand if required to fulfill the purposes for which the information was collected. Once informed by a person that personal information held by StratHR Solutions about them is inaccurate, StratHR Solutions will update the information as soon as possible.
7. Safeguarding personal information: StratHR Solutions will protect personal information with safeguards appropriate to the sensitivity of the information. StratHR Solutions has implemented appropriate safeguards to protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction. StratHR Solutions’ employees and contractors are made aware of the need to maintain the confidentiality of all personal information. The methods of protection used by StratHR Solutions will include:
• Physical measures, for example, locked filing cabinets and restricted access to offices;
• Organizational measures, for example, limiting access on a “need-to-know” basis; and
• Technological measures, for example, the use of passwords and encryption.
9. Providing access to personal information: When clients, candidates, contractors or employees request it, StratHR Solutions will disclose to them what personal information StratHR Solutions has about the client, candidate, contractor or employee, what it is being used for, and to whom it has been disclosed, and will give them reasonable access to their information. StratHR Solutions will provide a list of the third parties to which it may have disclosed the personal information when it is not possible to provide an actual list. Wrong or incomplete information will be amended and the amended information transmitted to third parties where appropriate. Any dispute over amending a file will be recorded and details of disputed data provided to third parties where appropriate. However, in certain situations, StratHR Solutions may not be able to give candidates, contractors or employees access to all personal information it holds about the client, candidate, contractor or employee. This may, for example, be the case when the information is unreasonably costly to provide, the information contains references to other individuals, the information cannot be disclosed for legal, security or commercial proprietary reasons or the information is subject to solicitor-client or litigation privilege. StratHR Solutions will explain the reasons for denying access in writing, and the recourse available to the client, candidate, contractor or employee. StratHR Solutions will make reasonable efforts to respond to an individual’s request for access to his or her personal information no later than 30 days after receipt of the written request, and at minimal or no cost. The individual will be informed of any extensions to the time limit and his or her right to complain to the Privacy Commissioner. StratHR Solutions may not provide access to personal information to an individual if doing so would likely reveal personal information about a third party, unless:
• The information about the third-party can be severed from the record containing the information about the individual, in which case it will be severed prior to providing the access;
• The third-party consents to the access; or
• The individual needs the information because an individual’s life, health or security is threatened.
Access to personal information will not be given if:
a) the information is protected by solicitor-client privilege;
b) to do so would reveal confidential commercial information;
• To do so could reasonably be expected to threaten the life or security of another individual; or
• The information was generated in the course of a formal dispute resolution process.
• A customer or client can obtain information or seek access to his or her personal information by contacting a StratHR Solutions representative at the StratHR Solutions Inc. office.
• An employee can obtain information or seek access to his or her individual personal file by contacting the StratHR Solutions Privacy Officer.
StratHR Solutions Inc.
Unit #208-62 Hargrave street, Winnipeg, MB R3C 1N1
Phone: (204) 221-9757