Privacy Policy and Procedures

The protection of individual privacy is of fundamental importance to Équité Association (“Équité”). Équité has strict procedures and for protecting the privacy of individuals. It collects, uses and discloses only enough personal information to serve its members and clients/customers efficiently and fairly, while complying with all applicable federal, provincial and territorial legislation. Équité does not use or disclose personal information for reasons other than those for which the information was collected, except with the consent of the individual or as permitted or required by law.

Can an individual access personal information that Équité has about them?

Yes, Équité will provide an individual with access to their personal information records. However, there could be some limitations to our ability to respond to a particular request. Some examples may include:

• Some of the information may not be organized in a manner that makes personal information accessible.
• When providing the information, we may delete or redact portions that disclose personal information about other individuals’ to protect that individual’s privacy.
• In many cases, Équité merely has custody, not ownership of the information. If an individual has concerns with the accuracy of the information provided, Équité will direct the individual to the organization that had supplied the information so that the records can be corrected.

How can an individual gain access to the personal information Équité has about them?

• A request must be made in writing to Équité’s Chief Privacy Officer (CPO), who is responsible for sending you a written response to your request by no more than thirty days.
• The individual will must be able to fully establish and confirm their identity (e.g., driver’s licence, health card or other government document that contains a personal address).
• Équité may require the individual to pay a fee to offset the cost of retrieving the information.

This Privacy Policy outlines how Équité handles personal information about individuals from outside Équité that is in its possession or control. The Policy is based on applicable privacy laws including, Personal Information Protection and Electronic Documents Act (“PIPEDA”), Act respecting the protection of personal information in the private sector and Personal Information Protection Act, (“AB – PIPA”):

Staff Roles & Responsibilities

Access to information within Équité Association is limited only to persons whose access to information is necessary to carry out their duties, such as processing or investigations.

• Collection: In most cases, Équité does not collect information.  Rather, information is transferred from third parties to Équité’s information technology team and investigative services team for the purposes of processing the information and investigating as it relates to the prevention, detection, and suppression of fraud.
• Utilization: Information is used by the technology team and the investigative services team for the exclusive purpose of preventing, detecting, and/or suppressing fraud either through consent or exemption under the law. Équité does not sell information. The processing of information may be assisted by third party processors who are required to follow the same privacy standards as Équité. The processing of information may include technology that identifies behaviours; however, no decisions are based exclusively on automated processing.
• Communication: Information may be communicated to third parties including law enforcement and regulatory bodies for the exclusive purpose of preventing, detecting, and suppressing fraud. Information is only communicated with consent or by exemption under the law. Équité follows its obligations under applicable privacy laws when communicating information. It is possible that information originating from Quebec may be communicated outside of Quebec. In all cases, information is stored within Canada.
• Retention: See Limiting Use, Disclosure and Retention and Accuracy below. The Équité technology team and investigative services team along with the Chief Privacy Officer are responsible for retention of information.
• Destruction: See Limiting Use, Disclosure and Retention below. The Équité technology team and investigative services team along with the Chief Privacy Officer are responsible for destruction of information.

Accountability: Équité is responsible for personal information in its possession or control, including personal information that Équité transfers to service providers to perform functions on Équité’s behalf. Équité has designated a Chief Privacy Officer who is accountable for the handling of such personal information.

‍Identifying Purpose: Either before or at the time any personal information is collected, Équité identifies to the individual the purpose for collecting the personal information.

Consent: The collection, use and disclosure of personal information is only done with the knowledge and consent of the individual, except in circumstances permitted or required by law. Every reasonable effort is made to ensure that the individual understands how her or his personal information will be used.

Limiting Collection: The collection of personal information is limited to that which is necessary for Équité to accomplish the identified purposes.

Limiting Use, Disclosure and Retention: Équité only uses or discloses personal information for the purpose for which it was collected. Équité only retains personal information for as long as it is necessary to fulfill that purpose. Équité does not disclose an individual’s personal information to third parties, except if required in the course of fulfilling the purpose for which it was collected.

Accuracy: All personal information is kept as accurate, complete and up-to-date as necessary for the purposes for which it is to be used.  An individual may at any time ascertain the accuracy and completeness of the personal information held by Équité and have the information amended if it is determined to be inaccurate or incomplete.

Safeguards: An individual’s personal information is protected by security measures appropriate to the sensitivity of the information.  Équité ensures that personal information is stored in electronic and physical files that are secure. Security measures include secure locks on filing cabinets and restricted access to computers.

Openness: Équité makes readily available to individuals information about its privacy policy and practices related to Équité's management of personal information.

Individual Access: Upon the written request of an individual, Équité will inform the individual of the existence, use and disclosure of her or his personal information. An individual will be given reasonable access to her or his personal information, and will be able to ascertain its accuracy and completeness except in certain circumstances, consistent with personal information statutes across Canada.

Compliance: Any individuals having questions about how Équité handles personal information or wishing to inquire about compliance with the above principles may contact Équité's Chief Privacy Officer at:

Danielle Wilkinson, Chief Privacy Officer  
Équité Association
120 Adelaide St. West
Suite 2500
Toronto, Ontario
M5H 1T1

‍E-mail: privacy@equiteco.ca

Équité Association has procedures in place to receive and respond to complaints or inquiries about its policies and practices relating to the handling of personal information. The complaint procedures are easily accessible and straightforward. Équité will investigate all complaints; and if a complaint is found to be justified, Équité will take appropriate actions including, including amending its policies and practices where warranted.