- First Access
Principle One - Accountability
Principle Two - Identifying Purposes
Principle Three - Consent
Principle Four - Limiting Collection
Principle Five - Limiting Use, Disclosure and Retention
Principle Six - Accuracy
Principle Seven - Safeguarding Client Information
Principle Eight - Openness
Principle Nine - Client Access
Principle Ten - Handling Client Complaints and Suggestions
First Access is responsible for personal information under its control. In fulfilling this mandate, we have designated an individual or individuals who is/are accountable for compliance with our Ten Privacy Principles.
The knowledge and consent of the client are required for the collection, use or disclosure of client personal information, except where inappropriate or permitted by law. Depending on the sensitivity of the information, this consent can be implied or expressed; however, wherever commercially feasible First Access shall attempt to obtain express consent. First Access complies with this principle by, among other steps, structuring its Sales Contracts (including the Disclosure Statement and Agreement for Installation component) to provide easily accessible and understandable consent language. Consent to our use of personal information can be withdrawn at any time by following the directions at the end of this policy; however, a client may not withdraw his or her consent following an application for a First Access product or service for which credit worthiness verification is a prerequisite.
Client personal information collected must be limited to those details reasonably necessary for the purposes identified and must be collected by fair and lawful means. Accordingly, First Access neither collects information which pertains to client health, race or ethnic origin.
Client personal information may only be used or disclosed for the purpose for which it was collected unless the client has otherwise consented, or when it is required or permitted by law. As client personal information is only to be retained for the period of time required to fulfill the purpose for which it was collected First Access has established and implemented guidelines and procedures for retaining and destroying such information.
Client personal information must be protected by security safeguards that are appropriate to the sensitivity level of the information. For example, Sales Contracts are kept in cabinets within the applicable office that are kept locked after business hours to avoid/prevent unauthorized access. All First Access computer systems are password protected for this same reason.
We collect, use and disclose client personal information in order to:
"Personal information" is any information that identifies a client, or by which a client identity could be deduced. Please note that "personal information" does not include either aggregate information that does not allow an individual to be identified, information about a visit to our website(s) which is not linked to the client, information about a client's computer operating system and web browser software (this technical information is verified to ensure that our website(s) are optimized to serve our clients) or, information that is used for the purpose of communicating or facilitating communication with an individual in relation to their employment, business or profession. We use anonymous/non-personal information to improve our products and services to our clients.
We only collect non-prohibited personal information which is related to our business such as client name, address, date of birth, social insurance number and employment information. We collect social insurance numbers as they provide the most reliable basis for us to conduct accurate searches of credit rating databases. We likely will also require information about client income, assets and liabilities. If applicable, we will collect GPS based locations information via the consent to installation of a device in the client's vehicle.
Wherever possible we collect personal information in an active fashion directly from the client. Please note that we may elect to record a conversation with a client for quality control and accuracy purposes.
Sometimes we may obtain information about clients from other sources for example:
First Access does not disclose your personal information to any third party to enable them to market their products and services. We are obliged to keep client personal information confidential except under the following circumstances:
We implement commercially reasonable industry standard policies, procedures, technologies and security standards to ensure that client personal information is protected against unauthorized access, and inappropriate disclosure, alteration or misuse. All safety and security measures which are implemented are designed to be appropriate to the sensitivity level of the stored client personal information. Among the steps taken to protect your information are:
First Access cannot, however, guarantee that loss, misuse or unauthorized use will never occur (for example, someone could conceivably overcome our security measures). If you receive any electronic communication which purports to be from First Access that you have any questions or concerns about, please contact us. Spam, improper use, and pirating of domain names and email addresses is a growing problem, so we appreciate hearing about incidents in order that we may investigate them and provide you the best client service.
Rights to access personal information are not absolute. We may deny access to a client when:
If we deny a request for access to, or refuse a request to correct information, we shall do so in writing and explain why.
Any channel of communication, such as e-mail, is not 100% secure, and you should be aware of this when contacting us to send personal or confidential information. With respect to Canada's Anti-Spam Legislation (commonly referred to as CASL), clients hereby expressly consent to receiving, during and after our business relationship, electronic messages from First Access, including via emails and through social media, providing information to you including newsletters, updates, alerts, other publications, news and communications, other information of interest to you and/or information on our services. You can withdraw this consent or modify your preferences as to the types of electronic messages which you wish to receive from us, at any time, simply by notifying us or by using the unsubscribe mechanism on any of our electronic messages.
Address: 10109-106 Street, Edmonton, Alberta, T5J 3L7
Attention: Privacy Officer
If you are not satisfied with our response, the Office of the Privacy Commissioner of Canada which oversees PIPEDA can be reached at:
Place de Ville
112 Kent Street, 3rd Floor
Ottawa Ontario, K1A 1H3