2. The Definition of Personal Information

Canadian privacy legislation defines “Personal Information” broadly as information about an identifiable individual or as information that allows an individual to be identified. For the purposes of this Policy, Personal Information means information about an identifiable individual as defined from time to time in applicable privacy legislation. Generally speaking, Personal Information does not include what is considered business contact information; i.e. an individual’s name, title or position, business address, telephone number, facsimile number, and e-mail address.

3. Collection of Personal Information

Outsource Solutions collects, uses and discloses Personal Information about our clients, employees of clients, and service providers in order to provide clients with consulting services. Personal Information is also collected, used and disclosed for client communication, marketing and internal professional development purposes. More specifically, we collect, use and disclose Personal Information for the following purposes:

• to establish and manage client relationships, provide services, and avoid conflicts of interest;
• to analyze in order to make specific recommendations for changes to employer practices;
• to organize and prepare Personal Information for submission to third parties designated and approved by clients. Such third parties may include the client’s legal counsel, accountants, group benefit providers, compensation surveyors, pension investment managers, authoritative governing bodies, and payroll services;
• to establish and maintain commercial relationships with clients, suppliers and other third parties, including to issue invoices, administer accounts, collect and process payments, and to fulfill contractual obligations;
• to understand and respond to client, supplier and other third party needs and preferences, including to contact and communicate with such parties and to conduct surveys, research and evaluations;

4. The Types of Personal Information We Collect

The types of Personal Information that Outsource Solutions may be privy to is an individual’s name, home address, telephone number, personal e-mail address, and billing and account information. In addition, in the course of providing services, we may be exposed to the client’s employees and workers’ compensation claim information. We do not sell, trade, barter or exchange any information obtained, including and especially any information obtained in the course of professional relationships.

5. Disclosure of Personal Information

In the course of providing services, Outsource Solutions may disclose Personal Information to:

• service providers, including an organization or individual retained by Outsource Solutions to perform functions on its behalf, such as marketing, data processing, document management and office services;
• an organization or individual retained by Outsource Solutions to evaluate your creditworthiness or to collect debts outstanding on an account;
• any third party or parties, where you consent to such disclosure or where disclosure is required or permitted by law.

6. Consent to Collection, Use and Disclosure

By submitting Personal Information to Outsource Solutions or its service providers and agents, you agree that we may collect, use and disclose such Personal Information in accordance with this Privacy Policy and as permitted or required by law. Subject to legal and contractual requirements, you may refuse or withdraw your consent to certain of the identified purposes at any time by contacting Outsource Solutions. If you refuse to consent or withdraw your consent, we may not be able to provide you or continue to provide you with certain services or information which may be of value to you. If you provide Outsource Solutions or our service providers and agents with Personal Information of another individual, you represent that you have all necessary authority and/or have obtained all necessary consents from such person to enable us to collect, use and disclose such Personal Information for the purposes set forth in this Privacy Policy and in accordance therewith.

There are circumstances where collection, use or disclosure may be justified or permitted or where we are obliged to disclose information without consent. These circumstances could include:

• Where the information is publicly available;
• Where required by law or by order of a court or tribunal;
• Where we believe, upon reasonable grounds, that there is an imminent risk of death or serious bodily harm to an identifiable person or group;
• Where it is necessary to establish or collect fees.

In such circumstances, we will not collect, use or disclose more information than is required.

7. Storage, Security and Protection of Personal Information

Outsource Solutions endeavors to store data in a secured location.

8. Privacy and Electronic Communication

• Exchange of Information Via E-mail – Outsource solutions does not guarantee the confidentiality of any communications made by you via e-mail or otherwise through our website and cannot guarantee that any such communications are confidential. If you wish to provide information of a confidential or sensitive nature to Outsource Solutions, please contact Judy Dulovic for the delivery of such information.
• Links - Our website may contain links to other websites which are provided as a convenience only. Visitors are advised that other third party websites may have different privacy policies and practices than Outsource Solutions, and Outsource Solutions has no responsibility for such third party websites.

9. Changes to the Privacy Policy

Outsource Solutions reserves the right to modify or supplement this Policy at any time. If we make a change to this Policy, we will post such changes on our website. However, Outsource Solutions will obtain the necessary consents required under applicable privacy laws if it seeks to collect, use or disclose your Personal Information for purposes other than those to which consent has been obtained, unless otherwise required or permitted by law.
If you are not satisfied with Outsource Solution’s response to a privacy related matter, you may contact the Office of the Privacy Commissioner of Canada at 1-800-282-1376 or at www.privcom.gc.ca.