Policy Statement
Angus Neil is committed to protecting the privacy, confidentiality and security of the personal information that it holds by adhering to the requirements of the Privacy Act with respect to the management of personal information. Angus Neil is equally committed to ensuring that all employees and agents of Angus Neil uphold these obligations.
Violation of this Policy through intent or neglect may result in disciplinary action up to and including termination of employment or association with Angus Neil. Where appropriate, legal sanctions may also be pursued.
Policy Requirements
Angus Neil is responsible for the personal information that it collects as a result of its mandate under the Privacy Act and PIPEDA and which it subsequently retains, uses, discloses, and destroys. Angus Neil has and will continue to develop and implement policies and practices to ensure that personal information is handled in strict accordance with the Privacy Act. Angus Neil’s Chief Privacy Officer is designated as responsible for overseeing the implementation of those policies and practices to ensure compliance, including:
- providing the same and simultaneous training for all Angus Neil staff (including temporary staff and contractors) as outlined in the Employee Privacy Policy concerning the Privacy Act, this Policy and Angus Neil’s practices and expectations with respect to the handling of personal information;
- ensuring open, full and timely communication to employees and individuals about the Angus Neil’s policies, practices and expectations with respect to the handling of personal information;
- the establishment of standards for classifying the sensitivity of personal information, to determine the appropriate level of security required for the information;
- ensuring that personal information is safeguarded from improper access, loss, use, disclosure or destruction through;
- the implementation of systems to ensure that only Angus Neil employees (including temporary staff) whose Angus Neil responsibilities require access to personal information, are granted access to that information;
- the inclusion of specific confidentiality provisions in contracts or other arrangements with third parties, which require adherence to the Privacy Act as well as to this Policy and internal procedures;
- ensuring procedures are in place under which individuals may request access to their personal information, request correction of their personal information, and file complaints concerning the management of their personal information;
- ensuring procedures are in place under which individuals are notified of an improper collection, retention, use, disclosure or destruction of their personal information; and
- monitoring the degree of compliance with this Policy annually and, where required, initiating action to correct any deficiencies.