AJILON’S COMMITMENT TO PRIVACY
Ajilon Canada Inc. and its divisions (collectively “Ajilon” or the “Company”) are committed to protecting the privacy and security of Personal Information (as defined below) provided to Ajilon. This Privacy Policy (“Policy”) explains Ajilon’s Personal Information handling practices. We encourage you to also read Ajilon’s website Terms of Use and Disclaimer, as it works in conjunction with, and is a part of this Policy.
- Personal Information is defined as information about an identifiable individual, but not aggregated information that cannot be used to identify a specific individual. However, business contact information (except business email addresses) and information available in public directories are not considered to be Personal Information.
Application
This Policy applies to Personal Information of candidates seeking job placement services (“Placement Services”), users of Ajilon’s web-site and applicants who seek employment with Ajilon (collectively “Individuals”).
Ajilon’s web-sites may contain links to third party web-sites that are not governed by this Policy. Although we endeavour to only link to web-sites with high privacy standards, this Policy does not apply once you leave Ajilon’s web-site. Additionally, Ajilon is not responsible for the privacy procedures employed by third party web-sites. Therefore, it is suggested that users of Ajilon’s web-site review the privacy policies of third party web-sites to learn how their Personal Information may be collected, used and disclosed.
PERSONAL INFORMATION HANDLING PRACTICES
Overview
Ajilon takes responsibility for Personal Information under its care and/or control and has a designated Privacy Officer who is accountable for Ajilon’s compliance with this Policy. Ajilon will make readily available to individuals specific information about its policies and procedures relating to the administration of Personal Information. If you have any questions relating to the handling of Personal Information by Ajilon and/or this Policy, please contact the Chief Privacy Officer at:
Via Phone: 416.367.2020
Via Fax: 416-941-5960
Ajilon has implemented policies and procedures to give effect to this Policy, including training and communicating to its employees about the Company’s policies and procedures relating to the handling of Personal Information. Ajilon transfers Personal Information to trusted third parties and/or affiliated companies for processing and storage purposes. Such information may be transferred across provincial and national borders, in which case, the information may become subject to the legislation of that jurisdiction. Ajilon will only transfer Personal Information to third parties who have executed contracts requiring them to protect the privacy and confidentiality of the Personal Information provided to them for purposes of performing their functions for Ajilon.
Collection
Prior to the collection of Personal Information, Ajilon will identify the purposes for which the Personal Information is being collected. Ajilon will limit the collection of Personal Information to that which is reasonably required for the purposes described to the individual providing such information.
Ajilon collects Personal Information only for the following purposes:
Unless required or permitted by law, Ajilon shall not use or disclose Personal Information for a new purpose that has not been previously identified and for which consent has not been obtained.
Ajilon may share Individual’s Personal Information with third party organizations so that they may offer goods and services that may be of interest to you. You may modify or withdraw your consent to this practice at anytime.
Ajilon may update this Policy, including the Terms of Use and Disclaimer http://www.ajilonconsulting.ca from time to time. As such, Ajilon encourages you to review these documents periodically. You may determine when this Policy was last updated by referring to the “revision date” found at the top of this Policy.
Ajilon collects Personal Information only for the purposes identified in this Policy. Ajilon shall only collect Personal Information by fair and lawful means.
Individuals provide Ajilon their Personal Information voluntarily. Individuals may choose whether or not to provide Ajilon their Personal Information; however, without some Personal Information, Ajilon will not be able to register such Individuals to receive Placement Services or be considered for employment with Ajilon.
Ajilon collects usage pattern information from users of Ajilon’s web-site. Clickstreaming is a technology that allows Ajilon to track the paths that web-site users take as they access Ajilon’s web-site and as they use links to other sites.
Ajilon will not routinely update Individuals’ Personal Information unless such a process is necessary to fulfill the purposes for which the information was collected.
Consent
In the majority of cases, Ajilon shall obtain express consent directly from Individuals to collect, use and/or disclose their Personal Information. For example, when a candidate registers with Ajilon for Placement Services:
- Express Consent: Ajilon shall obtain written, electronic or oral consent from the individual before collecting, using or disclosing Personal Information that is sensitive in nature, such as financial and health information.
- Implied Consent: Ajilon may rely on implied consent when consent may reasonably be inferred from the action or inaction of the individual.
Ajilon will only require Individuals to consent to the collection, use and disclosure of Personal Information as a condition to the supply of services if such collection, use and disclosure are necessary to fulfill the identified purposes.
Individuals may modify or withdrawal their consent at any time upon reasonable notice to Ajilon, subject to legal and contractual restrictions. If an individual requests his or her name to be removed from Ajilon’s marketing lists, such individual will not be made aware of certain new services and programs offered by Ajilon.
Consent may be withdrawn or modified by simply contacting Ajilon at the contact information provided in this Policy. Please be advised that it may take up to 30 days to complete such request. Prior to the changes taking effect, Individuals may still be contacted due to marketing efforts that commenced prior to the modification of consent.
Use of Personal Information
Ajilon restricts the use of Personal Information to the purposes identified in this Policy and for which Ajilon has obtained implicit or explicit consent from the individual. In accordance with established practices and industry standards, Ajilon retains Personal Information for only as long as necessary to fulfill the stated purposes and in accordance with applicable legislation.
In accordance with established practices and industry standards, Ajilon will destroy, erase or make unidentifiable any Personal Information that is no longer required.
Disclosure to Third Parties
Ajilon discloses Personal Information to third parties only for the purposes identified in this Policy and with the appropriate consent of the individual in accordance with applicable legislation. For example, Ajilon may be required to disclose certain information to regulatory authorities, such as the Canada Revenue Agency. In these circumstances, only the information specifically requested will be disclosed, and Ajilon shall take reasonable measures to ensure that such authorities who make the request are entitled to receive the Personal Information.
Access to Personal Information
Ajilon provides Individuals with access to their Personal Information for review and update. Upon request, Ajilon will inform an individual of the existence, use and disclosure of his or her Personal Information and shall give access to that information. An individual may challenge the accuracy of the Personal Information in Ajilon’s care and control, provided that the individual can reasonable demonstrate the inaccuracy of such information.
An individual may access his or her Personal Information by writing to Ajilon’s Privacy Officer at the contact information provided in this Policy. Access to Personal Information shall be provided in accordance with Ajilon’s established policies and procedures.
Normally, there is no cost for reasonable access to Personal Information. Ajilon shall advise Individuals of the cost, if any, prior to providing access to the Personal Information. In order to provide access to Personal Information, Ajilon may require additional forms of information, including other Personal Information to validate the requester’s entitlement to the Personal Information. Such other Personal Information collected will only be used to process the access request.
Ajilon will assist any individual who needs help in preparing an access request to his or her Personal Information. For example, if the requester has a sensory disability and upon request, Ajilon will provide access to Personal Information in an alternative format.
Ajilon will provide a response within 30 days of receiving an access request to Personal Information. Except where prohibited by law, if Ajilon is unable to provide the requested access to Personal Information, Ajilon will explain the reasons and any recourse an individual may have. For example, if Ajilon is unable to separate the requester’s Personal Information from that of others, Ajilon will not be able to provide access to such information.
Where Personal Information has been used to make a decision about a specific individual, Ajilon shall retain the Personal Information for a period of time that is reasonably sufficient to allow such individual to access his or her Personal Information.
Ajilon has procedures in place to address privacy related issues. Individuals may request access to their Personal Information in writing or address their privacy related concerns by contacting Ajilon’s Privacy Officer who is accountable for Ajilon’s compliance with this Policy.
Ajilon shall respond to all inquiries relating to this Policy within a reasonable amount of time, not exceeding thirty (30) days. The regulatory authority that oversees Ajilon’s administration of Personal Information is the Office of the Privacy Commissioner of Canada.
Ajilon takes privacy matters very seriously. As such, Ajilon shall respond to every privacy related complaint. On such complaint, Ajilon shall acknowledge, record and investigate the substance of the privacy complaint. If a complaint is found to be justified, appropriate measures will be taken, including but not limited to, amending this Policy.
Safeguards
Ajilon protects Personal Information against unauthorized access. In accordance with established practices and industry standards, Ajilon has security measures in place to protect Personal Information. Personal Information shall be protected by security measures appropriate to the sensitivity of the information.
Ajilon’s security measures include:
Individuals are reminded to take reasonable measures to protect themselves against unintended access to their Personal Information. For example, individuals should only disclose Personal Information to organizations they trust.