Association of Power Producers of Ontario
Policy on Protection and Management of Personal Information
The Association of Power Producers of Ontario (“APPrO” or “the Association”) respects the confidentiality of information, including any Personal Information, provided to us. In the course of its activities, APPrO does not generally collect Personal Information. However, to the extent that APPrO may do so, this policy has been prepared to express how the Association will organize itself to protect personal information; how its staff are expected to assist in this objective and to inform the public as to APPrO’s ongoing commitment to respecting privacy.
What is Personal Information?
APPrO considers "Personal Information" to mean any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information, other than business contact information (e.g. name, title, business address, phone, fax, email and website address).
Why APPrO May Collect Personal Information
APPrO may use the Personal Information provided verbally or in writing (including via electronic media) by Association members, consultants, strategic partners, agents, suppliers and contractors (including their employees) in order to:
1) Promote the objectives of the Association, including research and understanding of power production in Ontario;
2) Manage the Association’s relationship with its Members, including the provision of benefits and the administration of their membership accounts;
3) Communicate with individuals to
a) Inform them about APPrO events (e.g. conferences and meetings);
b) Invite involvement in the advocacy activities of the organization;
c) Distribute publications and information, including information from other organizations with similar purposes, to those who are involved in the work of the association;
d) Inform industry members and the public, wishing to learn more about the industry, about the power production industry in Ontario and those active in the industry;
e) Inform members about products and services of potential interest to the industry;
f) Supply or administer services of value to the industry, and to invite expressions of interest in receiving new services; and
g) Meet legal and regulatory requirements.
How APPrO Collects and Uses Personal Information
As an organization, APPrO attempts to inform as many people as possible to further our objectives and to make useful information available to people working in the field of power production. APPrO only collects, uses and discloses Personal Information for purposes that would be considered reasonable in the circumstances and only such information as is required for the purposes indicated in this policy statement. We use only fair and lawful methods to collect Personal Information.
Our use of Personal Information is limited to the purposes described in this Policy. APPrO will not collect any information, including personal information, expressly for the purpose of re-selling the data to others.
Except in connection with internal personnel purposes, APPrO does not knowingly collect Personal Information from anyone under the age of 18, especially children under 13, and does not use such information if it discovers that it is has been provided by a minor.
Unless permitted by law, no Personal Information is collected, without first obtaining the consent of the individual concerned to the collection, use and dissemination of that information. However, we may seek consent to use and disclose Personal Information after it has been collected in those cases where APPrO wishes to use the information for a purpose not identified in this Policy or not previously identified or for which the individual concerned has not previously consented.
The provision of Personal Information to APPrO means that the person concerned agrees and consents that we may collect, use and disclose their Personal Information in accordance with this Policy. In addition, where appropriate, specific authorizations or consents may be obtained from time to time.
In most cases and subject to legal and contractual restrictions, an individual is free to refuse or withdraw his or her consent at any time upon reasonable, advance notice. It should be noted that if an individual chooses not provide us with any Personal Information required in connection with any request for service or information, we may not be able to offer that service or provide the information requested. We will inform you of the consequences of the withdrawal of consent.
When APPrO May Disclose Your Personal Information
APPrO may disclose your Personal Information to individuals or organizations:
a) Who are other reputable organizations (where permitted by law) whose purpose and objectives are similar to our own and who wish to tell you about their products or services or to inform you about other opportunities, except when you indicate otherwise;
b) Who are advisers of the person concerned (e.g. legal, accountants), whether directly or to their service providers;
c) Involved in (i) providing, managing or administering products or services intended to inform individuals about APPrO products or services; or maintaining, reviewing and developing our business systems, procedures and infrastructure including testing or upgrading our computer systems.
In the event sensitive Personal Information is provided to APPrO, we will not disclose such Personal Information unless it is required in order to provide an individual with a requested service or information.
Where APPrO discloses Personal Information to organizations that perform services on its behalf, we will require those service providers to use such information solely for the purposes of providing services to the person concerned or APPrO and to have appropriate safeguards for the protection of that Personal Information
Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where APPrO is obliged to disclose information without consent. Such circumstances may include:
a) Where required by law or by order or requirement of a court, administrative agency or governmental tribunal;
b) Where APPrO believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
c) Where it is necessary to establish or collect monies owing to APPrO;
d) Where it is necessary to permit APPrO to pursue available remedies or limit any damages that we may sustain; or
e) Where the information is public.
Where obliged or permitted to disclose information without consent, APPrO will not disclose more information than is required.
The Accuracy And Retention Of Personal Information
APPrO endeavours to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary for the purposes for which we use that information. If we become aware that Personal Information is inaccurate, incomplete or out of date, APPrO will revise the Personal Information and, if necessary, use its best efforts to inform third parties which were provided with inaccurate information so that those third parties may also correct their records.
We keep your Personal Information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the product or service and the nature of the information. This period may extend beyond the end of a person’s relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. When your Personal Information is no longer required for APPrO’s purposes, we are developing procedures to destroy, delete, erase or convert it into an anonymous form.
Protection of Personal Information
APPrO endeavours to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This also applies to our disposal or destruction of Personal Information.
APPrO further protects Personal Information by restricting access to it to those employees that the management of APPrO has determined need to know that information in order that we may provide services or information.
If any employee of APPrO misuses Personal Information, this will be considered as a serious offence for which disciplinary action may be taken, up to and including termination of employment. If any individual or organization misuses Personal Information – provided for the purpose of providing services to or for APPrO - this will be considered a serious issue for which action may be taken, up to and including termination of any agreement between APPrO and that individual or organization.
We audit our procedures and security measures from time to time to ensure that they remain effective and appropriate.
Access To Your Personal Information
APPrO permits the reasonable right of access and review of Personal Information held by us about an individual and will endeavor to provide the information in question within a reasonable time and no later than 30 days following the request. To guard against fraudulent requests for access, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or making corrections.
We will provide information from our records in a form that is easy to understand. APPrO reserves the right not to change any Personal Information but will append any alternative text the individual concerned believes to be appropriate.
APPrO reserves the right to decline to provide access to Personal Information where the information requested:
a) Would disclose (i) Personal Information, including opinions, about another individual or about a deceased individual; or (ii) trade secrets or other business confidential information that may harm APPrO or the competitive position of a third party
b) Would interfere with contractual or other negotiations of APPrO or a third party;
c) Is subject to solicitor-client or litigation privilege;
d) Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information;
e) Does not exist, is not held, or cannot be found by APPrO;
f) Could reasonably result in (i) serious harm to the treatment or recovery of the individual concerned, (ii) serious emotional harm to the individual or another individual, or (iii) serious bodily harm to another individual;
g) May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by law to perform such functions; or
h) May be required to be released on any other grounds under applicable legislation.
Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.
APPrO will not respond to repetitious or vexatious requests for access and in making such a determination, we will consider such factors as the frequency with which information is updated, the purpose for which the information is used, and the nature of the information.
APPrO will not charge you for verifying or correcting your information, however, to the extent permitted by applicable law, there may be a charge imposed if you need a copy of records.
Resolving Your Privacy Concerns
APPrO will investigate all complaints and if a complaint is justified, we will take all reasonable steps to resolve the issue.
Further information on privacy and your rights in regard to your personal information may be found on the website of the Privacy Commissioner of Canada at www.privcom.gc.ca.