Connect:
PIPEDA applies to private-sector organizations across Canada that collect, use or disclose personal information in the course of a commercial activity. The law defines a commercial activity as any particular transaction, act, or conduct, or any regular course of conduct that is of a commercial character, including the selling, bartering, or leasing of donor, membership, or other fundraising lists. Under PIPEDA, personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:
There are some instances where PIPEDA does not apply. Some examples include:
PIPEDA has 10 principles businesses must implement to be considered in compliance with the legislation:
The information collected by Simple Life Homes Ltd. consists of the following items: clients full names (including their first name, and surname), their email address, their primary phone number, their home address, and their driver’s license. The purposes of collecting a client’s name are to identify them accurately and create a client profile in Simple Life Homes Ltd.’s system to appropriately categorize their project according to its scope and current work capacity. The purposes of collecting a client’s email address are to provide us with a reliable avenue with which to communicate critical information regarding their project status. This includes documents, quotes, invoices, updates, and scheduling meetings. The purpose of collecting a client’s phone number is to provide us with a direct line with which to communicate with the client in the event of a critical update, emergency or to conduct a scheduled meeting. The purpose of collecting a client’s home address is to send the client merchandise in relation to their project, such as branded clothing items, or provide them physical copies of critical information such as purchase agreements, authorizations etc. The purposes behind the collecting of a client’s driver’s license are to confirm the client’s identity, and other facets of their personal information such as their full name, and current address. This provides Simple Life Homes Ltd. reassurance that the client is not assuming the identity of another for the purposes of damaging Simple Life Homes Ltd.’s reputation, or severely disrupting its normal course of business, possibly causing it to suffer financially as a result.
Consent will be obtained from by having the client select a check-box function which states the following: “Simple Life Homes Ltd. is committed to protecting and respecting your privacy, and we’ll only use your personal information to administer your account and to provide the products and services you requested from us. From time to time, we would like to contact you about our products and services, as well as other content that may be of interest to you. If you consent to us contacting you for this purpose, please tick below to say how you would like us to contact you.” The client will then be presented with a second check-box function that is a required field to submit the form: “In order to provide you the content requested, we need to store and process your personal data. If you consent to us storing your personal data for this purpose, please tick the checkbox below. You can unsubscribe from these communications at any time. For more information on how to unsubscribe, our privacy practices, and how we are committed to protecting and respecting your privacy, please review our Privacy Policy.” Included in the Privacy Policy page will be the policy in its entirety, and the contact information of the Privacy Officer should the client have any questions, or complaints. During the process in which a client’s project has been reviewed by the Simple Life Homes Ltd. design team, approved and has been moved into its active projects pipeline, the client will be asked to provide their driver’s license by a sales representative. When doing so, they will be explaining to the client the purposes of collecting this information, which is to confirm the identity of the client, and provide Simple Life Homes Ltd. reassurance that they are not assuming another individual’s identity which would damage the reputation of Simple Life Homes Ltd., and possibly cause severe disruption to its normal course of business. The client will then be asked for their express consent for this information to be collected.
Client information including their name, phone number, email address, home address and driver’s license are the only pieces of information that will be requested by Simple Life Homes Ltd. Simple Life Homes Ltd. requires only these pieces of information to accurately identify who the client is, how we can get into contact with them to proceed with project completion and confirm their identity. This information will only be used for the purposes identified above. Should we find that we need to use this information for different purposes than those aforementioned we will directly contact the client and obtain meaningful express consent and describe in detail the purposes for which we are using their information. Client information is not disclosed to any third parties. Should there be an instance in which client information must be divulged to a third party, a representative from Simple Life Homes Ltd. would contact the client to obtain express consent to do so.
Clients will be encouraged to review this policy during the process of collecting their contact information on www.simplelifehomes.ca. Within the policy, there are instructions which outline instructions for them in cases where the information they provided is inaccurate, or out of date. Should clients discover that the information they provided is inaccurate or out of date, they shall contact Simple Life Homes Ltd.’s Privacy Officer utilizing their contact information listed in this document, or in the “Privacy” tab listed on Simple Life Homes Ltd.’s website, www.simplelifehomes.ca for remediation and/or discussion. After being contacted by a client that has a concern regarding the validity and/or accuracy of their information provided, the client will be provided a document asking for their express consent to the use of this new information, and that the new information provided is accurate and up to-date to the best of the client’s knowledge. The situation will then be remedied by having the information updated to be an accurate reflection of the item collected to the best of the client’s knowledge.
Simple Life Homes Ltd. ensures that client information is protected by implementing a variety of electronic and physical control measures. Laptop, desktops, and tablets are password protected, and are accessed only by users with a level of managerial responsibility. During the workday, when members of staff leave their workstations, their equipment is locked to prevent unauthorized access, and all laptops, desktops, and tablets are left in the Simple Life Homes Ltd. facility at the end of each workday, which is then locked and monitored by a sophisticated security system. Lastly, Simple Life Homes Ltd. utilizes a web-based browser that automatically blocks and reports malware and spyware vehicles such as pop-up advertisements and unsecured websites, as well as internet tracking technology to further protect client information being processed and sent electronically.
All client personal information will be kept on record on Simple Life Homes Ltd.’s secure server for a period of 5 years in accordance with Simple Life Homes Ltd.’s record keeping policy. After this period of 5 years has passed, Simple Life Homes Ltd. will dispose of the information by deleting it permanently off their secure server and ensuring that no backup was taken of the information. If it is discovered that a backup of the information exists, it will be deleted as well.
Should a client have a complaint or inquiry about the process in which their information is collected, used, and disclosed, they are invited to contact Simple Life Homes Ltd.’s Privacy Officer whose contact information is listed in this document, and on the Simple Life Homes Ltd. website, www.simplelifehomes.ca, under the “Privacy” tab. The complaint or inquiry will then be reviewed, and Simple Life Homes Ltd.’s Privacy Officer will contact the client to discuss the complaint or inquiry in detail and propose a remedy to the situation. In addition, clients can also submit complaints directly to the Office of the Privacy Commissioner of Canada regarding Simple Life Homes Ltd.’s practices. Should a client desire access to their personal information we have on file, they are invited to contact Simple Life Homes Ltd.’s Privacy Officer whose contact information is listed in this document, and on the Simple Life Homes Ltd. website, www.simplelifehomes.ca, under the “Privacy” tab. They will then be contacted by Simple Life Homes Ltd.’s Privacy Officer to verify their identity, and the information will then be disclosed in a secure manner.
During instances in which security measures have been breached, or another incident has occurred in which client information is presumed to be at risk of theft, loss or unpredictable destruction, Simple Life Homes Ltd. will inform all clients that such an event has occurred. This will be done in writing via email for documentation purposes for both parties, in addition to a phone call being conducted to immediately and directly inform clients of this occurrence. Every effort will be made to recover client information in a timely and safe manner should it be stolen, or lost, and clients will be informed continuously throughout this process of any updates or developments. When client information is recovered, Simple Life Homes Ltd. will inform the clients of the recovery and will invite them to review Simple Life Homes Ltd.’s privacy policy and present them with a form to provide express consent to continue using their personal information for the purposes outlined in this document. In addition, Simple Life Homes Ltd.’s Privacy Officer will conduct an extensive review of security measures to discern what needs to be updated so that this event does not occur again. They will then reach out to affected clients and provide them a copy of the findings of said review, and the updated privacy policy.
As aforementioned in this document, Simple Life Homes Ltd. will not disclose client information to any third parties. Should an instance arise in which Simple Life Homes Ltd. desires to disclose a client’s personal information, the client will be contacted by a representative of Simple Life Homes Ltd. and asked for their express consent