D+H LIMITED PARTNERSHIP, COMMITMENT TO PRIVACY
D+H Limited Partnership (D+H) has been a trusted provider of products and services for over 100 years. The right to privacy and the protection of personal information collected by D+H about our customers and others with whom we do business as well as our obligations to protect personal information entrusted to us by our customers for processing are important to D+H. We understand the obligations for our customers to comply with the provisions of the Personal Information Protection and Electronic Documents Act (PIPEDA), other applicable privacy legislation and any U.S. privacy laws that may be applicable to their business. D+H will meet its responsibilities to protect our customers’ personal information in accordance with legal requirements and current best practices. When our customers contract with us to process personal information on their behalf, we recognize our obligations to protect that information and to collect, use and disclose it exclusively on their behalf in accordance with the provisions of their service contracts.
As a trusted partner to our customers and others with whom we do business, we take our responsibilities as a custodian of information very seriously and, as such, we adhere to the following key principles:
We are accountable for all information under our control or provided to us by our customers, including any information transferred to service providers for the purpose of providing the Services for which we have been contracted to provide. When using service providers, we use contractual or other safeguards to provide a comparable level of protection.
COLLECTING AND USING PERSONAL INFORMATION
Identification of purpose for collecting and using personal information
The nature of the information we collect or receive from our customers or on behalf of our customers varies depending on the Service being provided. D+H will only collect personal information on its behalf or on behalf of our customers for identified purposes. We request that only the information necessary to fulfill the Services requested be supplied to us. D+H ensures that each customer contract identifies the purposes for which personal information may be collected, used or disclosed by D+H on behalf of our customers.
D+H shall obtain the consent of individuals to the collection, use or disclosure of their personal information by D+H for its own purposes. Consent may be obtained in written or oral form and may be implied or express. An individual can withdraw consent at any time; however, the withdrawal of consent may affect our ability to provide the requested Services or information.
D+H may collect, use or disclose personal information held by us for our own purposes without consent in circumstances of emergency or as permitted or required by law. D+H’s customers are responsible for obtaining the consent of individuals to the collection, use and disclosure of their personal information processed by D+H. D+H may, as part of its Services to its customers, obtain on their behalf consents for personal information that it processes for such customers.
Limiting the collection, use and disclosure of personal information
D+H shall limit the collection, use and disclosure of personal information for our own purposes to that which is reasonably necessary for the purposes identified. D+H shall ensure that the collection, use and disclosure of personal information on behalf of our customers is limited to the purposes specified in our customer contracts. D+H shall not collect, use or disclose for our own purposes any personal information that is provided to us by or on behalf of our customers.
Limiting retention of personal information
D+H will only retain personal information collected for its own purposes for so long as is required or appropriate for such purposes. D+H will establish minimum and maximum retention periods for personal information held by us for our own purposes. D+H will retain and destroy personal information provided to us on behalf of our customers as stipulated in our customer contracts or as it is otherwise instructed by our customers. The destruction of information is performed by specially designed software, degaussing, and shredding of documents.
ACCURACY OF PERSONAL INFORMATION AND ACCESS
D+H shall keep the personal information that it collects for its own purposes as accurate, complete and up to date as reasonably required for the purposes for which it is to be used.
D+H’s customers are responsible for the accuracy and completeness of the personal information that has been provided to us to perform the Services requested. D+H may, as part of its Services to its customers, update on their behalf personal information that it processes for such customers.
D+H will provide individuals with access to their personal information which D+H holds for its own purposes. D+H will refer to our customers any requests that it receives for access to information held by us on behalf of our customers. D+H will assist our customers in responding to requests for access received by us.
D+H will protect personal information held by us for our own purposes as well as personal information provided to us on behalf of our customers by implementing reasonable physical, technological and administrative safeguards. D+H will protect information held by us on behalf of our customers against accidental disclosure, unauthorized publication, damage, or other breach of privacy. We have comprehensive physical and logical security policies and procedures, based on industry best practices, to address practices for the secure access, storage, transmission, and disposal/destruction of information. D+H will maintain appropriate security upon the disposal and destruction of records containing personal information.
We restrict access to personal information held by us for our own purposes as well as personal information provided to us on behalf of our customers to those employees who need to know that information to provide the Services. In addition, we train our employees about the importance of confidentiality and maintaining the privacy and security of personal information. We commit to taking appropriate disciplinary measures to enforce our employees' privacy responsibilities.
D+H shall make available information about its general policies and practices relating to the processing of personal information for our own purposes and on behalf of our customers. D+H will not make available information respecting its processing or management of personal information for a specific customer except to that customer or as directed by that customer.
QUESTIONS OR CONCERNS
D+H has procedures in place to receive and respond to complaints and inquiries about our policies and practices relating to the handling of personal information. D+H will investigate all complaints respecting personal information held by us for our own purposes. If a complaint is found justified, D+H will take appropriate measures, including, as necessary, amending our policies and practices. D+H will assist our customers in responding to questions and complaints respecting personal information maintained by us on behalf of our customers.
For further information on our privacy policies, contact our Privacy Officer at:
Suite 201 – 939 Eglinton Ave East
Toronto, Ontario M4G 4H7