Privacy at Crayola Canada
Privacy of personal information is an important principle to Crayola Canada. Crayola Canada is committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the goods and services we provide. It is Crayola Canada’s objective to be open and upfront with how personal information is to be handled.
What is personal information?
Personal information is any information, which relates to a natural person and allows that person to be identified. Personal information includes information that relates to personal characteristics (e.g. gender, age, income, home address or phone number, ethnic background, family status), health (e.g. health history, health conditions, health services received) or activities and views (e.g. religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual).
Who Crayola Canada is
Crayola Canada consists of approximately 90 employees including field personnel and temporary employees. Crayola Canada also uses a number of consultants and agencies that include payroll, marketing and promotion house personnel, community resource personnel, auditors, retail technology consultants, credit check service consultants, etc. Access to Crayola Canada’s personal information by such consultants and agencies is limited and Crayola Canada is given their assurance that the appropriate privacy principles are adhered to.
Crayola Canada’s Commitment to Privacy
Crayola Canada is committed to the protection, accuracy and confidentiality of personal information. Crayola Canada’s personal information policies and practices are based on the ten principles set out by Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA). These principles include:
Crayola Canada has appointed a Chief Privacy Officer in addition to a Privacy committee whose primary objective is to develop, implement and review Crayola Canada’s privacy policies and procedures and ensure compliance with the privacy legislation.
2. Identifying the purposes for which personal information is collected.
Like all companies, Crayola Canada collects, uses and discloses personal information in order to operate the business effectively. Crayola Canada’s customers include: wholesale customers, agents and retail consumers.
For wholesale customers, the primary purposes for collecting personal information are as follows:
- To verify credit worthiness
- To open trade receivables accounts and establish credit
- To invoice and receive payment for stock
- To facilitate ongoing business communications
The types of personal information collected for these purposes include:
- Financial information (bank information)
For agents, in addition to the above purposes, Crayola Canada collects personal information to:
- Evaluate the ability of the potential agent to operate a particular geographic area to a standard that will ensure the integrity of our programs.
The types of personal information collected include:
- Occupation or profession
- Education or training
- Language skills
For Crayola Canada retail consumers, the primary purpose for collecting personal information includes:
- To communicate upcoming retail promotions and events
- To establish customer eligibility for special offers or discounts
- To contact winning participants in retail contests.
The types of personal information collected include:
- Home address
- Home telephone numbers
- Email address
3. Obtaining consent for the use, collection and disclosure of personal information from the individual, except where the law provides an exemption.
Consent from an individual must be obtained before personal information can be collected, used or disclosed. Consent may be obtained directly from the individual or by an authorized representative. Express or direct consent can be in writing (e.g. signature on an application, consent form or email) or verbally, in person or on the telephone. Consent to provide Crayola Canada with your personal information is always your choice; however choosing to withhold or withdraw your consent may impact Crayola Canada’s ability to provide necessary services to you. Once provided, your consent is valid even upon termination of your relationship with Crayola Canada. Consent may be withdrawn upon receipt of written notice. There are some legal exceptions where consent does not have to be obtained in order to collect personal information or where consent cannot be withdrawn. Examples of this would be where there is a life threatening emergency or when compliance with a court order is necessary.
4. Limiting collection of personal information to that which is necessary.
Only personal information that is necessary in order to conduct business or provide services will be collected. The individual will be advised of the reason/uses for the personal information being provided. Should a new use/reason arise in the future, the individual will again be requested to provide consent.
5. Personal information will only be used and disclosed for the purposes of which it was collected and will only be retained for as long as necessary to fulfill those purposes.
Personal information will be used or disclosed only for the purpose(s) for which it is collected. Crayola Canada is required to retain personal information for a number of years in order to ensure that we can answer any questions you might have about the services provided and for Crayola Canada’s own accountability to external regulatory bodies. Crayola Canada retains customer files for approximately 7 years. Information on customer directories is systematically removed once it is determined that there is no need to contact you again. Upon request, however, your contact information can be removed immediately. Crayola Canada retains employee files for approximately 7 years.
Paper files containing personal information are destroyed by being shredded. Electronic information is destroyed by being deleted, and when the hardware is discarded, the hard drive is physically destroyed.
6. Accuracy of personal information will be maintained.
Crayola Canada, to the best of its ability, will strive to collect and maintain the most accurate personal information available. It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of your employment, please keep us informed of such changes. You may cause information which is contained in a file concerning you and which is inaccurate, incomplete or equivocal to be rectified; you may also cause obsolete information or information not justified for the purpose of the file to be deleted, or you may deposit your written comments in the file. This right pertains to factual information and not to any professional opinions Crayola Canada has formed. Documentation may be requested from you in order to correct the information. If rectification is made of information in a file, the correction will be promptly made and notification sent out about the correction to every person who received the information in the preceding six months and where applicable, to the person who provided that information. Similarly, if an agreement on the rectification is not reached, Crayola Canada will file a brief statement from you concerning your claim and promptly forward the statement to anyone who had received, in the preceding six months, the earlier information. In circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions). Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
7. Safeguards appropriate to the sensitivity level of the personal information will be employed.
Crayola Canada employs a number of procedural practices, both physical and electronic, to safeguard any personal information that it collects. These practices include:
- Paper information is either under supervision or secured in a locked or restricted area;
- Electronic hardware is either under supervision or secured in a locked or restricted area at all times. Computers are password protected;
- Cell phones are digital as digital signals are harder to intercept;
- Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies;
External consultants and agencies with access to personal information must enter into privacy agreements with Crayola Canada.
If Crayola Canada becomes aware of a breach of our security safeguards that compromises the privacy of the personal information retained by the company, the following action shall be taken:
- The Chief Privacy Officer is responsible for coordinating the response to the breach and ensuring that all reasonable action is taken to address the breach.
- The Chief Privacy Officer will notify the Privacy Commissioner of the breach in the prescribed form and manner as soon as feasible once Crayola Canada has determined that a breach has occurred.
- Crayola Canada will comply to the greatest extent possible and in a timely manner with any requests, orders, or other instructions from the Office of the Privacy Commissioner in order to respond to and address the security breach.
- Crayola Canada shall maintain records of every breach of security safeguards, and will provide the Privacy Commissioner with access to, or a copy of, a record of a breach, at the request of the Commissioner.
Notifying Affected Individuals
Determining Whether a Real Risk of Significant Harm Exists
Crayola Canada will assess the following factors when determining whether a security breach constitutes a real risk of significant harm to an individual or individuals:
- The sensitivity of the personal information involved in the breach;
- The probability that the personal information has been, is being, or will be misused; and
- Any other prescribed factor.
The Chief Privacy Officer is responsible for ensuring that all individuals affected by the breach for whom the breach creates a real risk of significant harm are notified at the earliest available opportunity, subject to any legal restrictions. Notifications shall:
- Contain sufficient information to allow the individual to understand the significance to them of the breach and to take steps, if any are possible, to reduce the risk of harm from it or to mitigate that harm.
- Contain any other prescribed information.
- Be conspicuous and given directly or indirectly to the individual in the prescribed form and manner as legislatively required as the situation dictates.
- Be given as soon as feasible after the organization determines that the breach has occurred.
In addition to the individual(s) affected by the breach, Crayola Canada may notify other parties of the breach or disclose personal information relating to the breach, subject to the following guidelines:
- Crayola Canada shall notify other organizations, government institutions, or part(s) of government institutions if it is believed that doing so can reduce or mitigate the harm from the breach.
Crayola Canada will provide information in regards to its policies and procedures of privacy to interested individuals.
9. Individuals may request access to their personal information and the purposes for which it is being retained
You have the right to see what personal information Crayola Canada has retained about you and to verify the use and disclosure of the information. No request for access may be considered unless it is made in writing by a person who proves that he is the person concerned, his representative, heir or successor. Once your identity has been confirmed you will be assisted in identifying what records Crayola Canada has about you, in addition to assisting your understanding of any information that you would like clarified. Where you make a request for access to your personal information, Crayola Canada will allow you to view your personal information at no cost, however, Crayola Canada may charge a reasonable fee for any transcription, reproduction or transmission of the information that the individual requests. If Crayola Canada intends to require a charge, you will be informed in advance, of the approximate amount that will be charged for the transcription, reproduction or transmission of information.
If for some reason your request for access to your personnel information or for rectification is denied, in accordance with the law, you will be notified within 30 days with an explanation.
10. Recourse and contact information
Any questions, concerns or complaints about Crayola Canada’s privacy policies and procedures should be directed to Crayola Canada’s Chief Privacy Officer.
Crayola Canada’s Chief Privacy Officer, Mike Soehner, can be reached by telephone at
(705) 324 – 6105 ext 2204 or in writing to Crayola Canada, 15 Mary St. W., P.O. Box 120, Lindsay, Ontario, K9V 4R8 or by email at firstname.lastname@example.org.
For more general inquiries, The Office of the Privacy Commissioner of Canada (www.priv.gc.ca) provides advice and information for individuals about protecting personal information. The Office of the Privacy Commissioner of Canada can be reached by telephone at (819) 994 – 5444; TTY (819) 994-6591; Tool Free 1-800-282-1376 or by fax (819) 994-5424.