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POLICY ON RESPECT OF PRIVACY AND CONFIDENTIALITY

This policy aims to ensure the operations of Capital-Image comply fully with the requirements of the Personal Information Protection and Electronic Documents Act (the Act). This policy will be updated from time to time if required. 

Capital-Image expects the members of its team to respect any personal information that may be disclosed in the course of their activities and that the security and confidentiality of such information are guaranteed in all respects. 
Generally, our activities do not require the collection or use of personal information other than basic contact information (personal information under this law does not include details that might appear on a business card, such as name, title, address, etc.).

This has the effect of limiting the provisions necessary to ensure compliance with the Act. Therefore, the practice of not collecting unnecessary personal information should be continued as a first step. This includes information that our customers may share with us.

This could include, but not be limited to such things as age, income, evaluation grades, and past employment. The law applies to outsiders, not to employees.

If you are collecting information of a personal nature, the individual's consent must be obtained and you must explain the reason for using that information. Consent can be explicitly given, or is implied if someone has voluntarily sent us the information (such as a CV). Once obtained, you must ensure that the information is kept in a secure location and only used for the purpose originally indicated. Our network server or a locked filing cabinet may be such places. Personal information like CVs should not be left on view and unprotected.

For the sake of clarity, personal information is defined as any factual or subjective information about an identifiable individual. Individual consent is not required to collect personal information that was already in your possession before January 1, 2004. However, in order to continue using or sharing that information, consent is now required. Once personal information is no longer needed, it should be destroyed using a confidential method, such as electronic file deletion or paper document shredding. Records should be reviewed regularly so that outdated information is removed.

If personal information is retained, it should be reviewed for fairness and accuracy. If you are not sure, delete it. Our policy recognizes the right of people outside our company to ask us for copies of the personal information we hold. Further, if personal information is retained, it should only be used for the purposes for which it was originally collected. It should not be shared for other reasons unless you have obtained the approval of the individual concerned with your responsibilities in the course of your work. Photos or files of client events or those of Capital-Image are also private. Capital-Image’s reputation for trust and integrity depends a lot on our discretion. A breach of confidentiality or privacy may be grounds for dismissal.

Your obligations in this regard also continue if you leave the company. For any questions regarding this policy or to obtain a personal information record, please contact Miriam Lauzon, the Privacy Officer at Capital-Image (mlauzon@capital-image.com).

Respect for private life is something that each of us benefits from in our society. It is a policy that we should be happy to support.