The Privacy Policy

The privacy of our members, clients and employees is of great importance to Lunchbox Consulting Inc. (Lunchbox). Lunchbox is committed to collecting, using and disclosing personal information in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA).

Personal information is any information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization. It does include such things as a person’s home address, date of birth, social insurance number, medical and financial information and email address. With respect to members and clients, personal information may be collected primarily in connection with services and products provided by Lunchbox In all instances, Lunchbox is committed to protecting the privacy of individuals by ensuring that their personal information is accurate, confidential and secure.

10 Principles of PIPEDA

Principle #1 - Accountability

Lunchbox Consulting is accountable for all personal information it collects or that is in its possession including any personal information disclosed to third parties for processing or administrative functions. Lunchbox has designated one or more persons who are accountable for Lunchbox’s compliance with PIPEDA and this Policy.

1.1 Lunchbox’s senior management are ultimately accountable for compliance with this policy and privacy legislation, however day-to-day compliance is delegated to all Lunchbox employees. Lunchbox has designated a Chief privacy Officer to oversee compliance with this Policy.

1.2 Personal information that is transferred to third parties for processing will be safeguarded by way of contracts or agreements with the third parties to ensure that the third parties are also safeguarding this information.

1.3 Lunchbox has established practices and procedures to comply with this Policy and PIPEDA as follows:

a) procedures to protect the privacy of personal information

b) procedures to receive and respond to inquiries and complaints

c) materials that explain Lunchbox’s privacy policy

d) trains staff and communicates to staff information about Lunchbox’s policies and procedures.

Principle #2 - Identifying Purposes for Collection of Personal Information

Lunchbox will identify the purpose for which personal information is collected at or before the time the information is collected unless the purpose is obvious.

2.1 Lunchbox collects personal information from you with your knowledge and consent for the following purposes only:

a) to communicate Lunchbox / industry information

b) to communicate information about and to promote Lunchbox events

c) to summarize the results of our Exam Prep services

d) to develop, enhance, market or provide products or services

e) to meet legal and regulatory requirements

Principle #3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information

Lunchbox will not collect, use or disclose an individual’s personal information without their knowledge and consent except in certain instances where permitted by law.

3.1 Lunchbox will reasonably seek to obtain consent either express or implied for the collection and subsequent use and disclosure of personal information at the time of collection of the information. In certain circumstances, consent for the use and disclosure will be sought after the information has been collected, but before it is used, in particular if Lunchbox wants to use the information for a purpose not previously identified.

3.2 Lunchbox will ensure that meaningful consent is obtained for the collection, use and disclosure of personal information. To attain this, the purpose for which the information will be used will be stated in such a manner that the individual can reasonably understand how the information will be used or disclosed.

3.3 Lunchbox will require individuals to consent to the collection, use and disclosure of personal information as a condition of the supply of product or service only if such collection, use or disclosure is required to fulfill the identified purpose.

3.4 Lunchbox will determine the type of consent required based on the type of information collected, its intended use and the sensitivity of the information.

3.5 Consent may be expressed or implied, given orally, electronically or in writing.

3.6 An individual may withdraw consent at any time on sufficient notice to Lunchbox subject to legal and contractual limitations. The individual will be notified by Lunchbox of the implications of this withdrawal.

Principle # 4 - Limiting Collection of Personal Information

Lunchbox will limit the collection of personal information to that which is necessary for the purposes identified by Lunchbox. This information will be collected by fair and lawful means at all times.

4.1 Lunchbox primarily collects personal information from its members and clients and employees but may also collect personal information from other sources, with the consent of the individual.

Principle #5 - Limiting Use, Disclosure, and Retention of Personal Information

Personal information will not be used or disclosed by Lunchbox for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information will be retained only as long as reasonably necessary for the fulfillment of those purposes or as required by law.

Principle # 6 - Accuracy of Personal Information

Lunchbox will make reasonable efforts to ensure that personal information of individuals is kept accurate, complete and up-to-date as is necessary for the purpose for which it is to be used.

6.1 Lunchbox will make reasonable efforts to obtain information from individuals in order to update information on hand if required to fulfill the purpose for which the information was collected. If Lunchbox is informed that the information that they hold for an individual is incorrect, Lunchbox will update this information as soon as possible.

6.2 Personal information will not be updated without the consent of the individual.

Principle #7 - Safeguards

Lunchbox will protect personal information by security safeguards appropriate to the sensitivity of the information.

7.1 Lunchbox will use security safeguards to protect personal information against loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, regardless of the format in which it is held.

7.2 The nature of the safeguards used by Lunchbox will vary depending on the sensitivity of the personal information that has been collected.

7.3 Lunchbox will make reasonable efforts to ensure that third parties use safeguards comparable to Lunchbox’s to protect personal information that has been disclosed to them for the purpose of processing or other administrative purposes.

7.4 Lunchbox will ensure all employees are aware of the importance of maintaining confidentiality of personal information and will be trained as how to safeguard this information. Employees of Lunchbox are required to abide by this policy.

Principle #8 - Openness Concerning Policies and Practices

Lunchbox will make readily available to individuals specific information about its policies and practices relating to the management of personal information.

8.1 Lunchbox will make this specific information readily available to individuals in a form that is generally understandable

8.2 Lunchbox will provide information about its policies and practices in various ways.

Principle #9 - Individual Access

Upon the receipt by Lunchbox of a written request, an individual will be informed, within a reasonable period of time following such request, of the existence, use and disclosure of his or her personal information and will be given access to that information. In certain limited circumstances, as permitted or required by law, certain information will not be disclosed to the individual.

9.1 Subject to applicable laws, upon receipt of a written request from an individual, Lunchbox will inform him or her whether or not Lunchbox holds personal information about the individual and make reasonable efforts to indicate the source of the information as well as a summary of the use of the information.

9.2 An individual may be required to provide sufficient information to permit Lunchbox to provide an account of the existence, use and disclosure of personal information. The information provided will be used only for this purpose.

9.3 Lunchbox may charge a reasonable fee to cover its cost of providing the information. Lunchbox will notify the individual of the estimated cost of providing the information prior to doing so and will afford the individual the opportunity to withdraw his or her request.

9.4 Upon receipt of written request, Lunchbox will provide an individual a list of third parties to which it may have disclosed personal information about the individual and the purpose for which the information may have been disclosed

9.5 When an individual successfully demonstrates the inaccuracy or incompleteness of personal information held by Lunchbox, Lunchbox will amend the information as required.

9.6 Lunchbox may decline to provide an individual access to his or her personal information in accordance with applicable laws

Principle # 10 - Challenging Compliance

An individual can address a challenge concerning Lunchbox’s compliance with the above principles to the designated person accountable for compliance within Lunchbox.

10.1 Lunchbox has procedures in place to receive and respond to inquiries or complaints about this policy and its handling of personal information.

10.2 Questions and complaints regarding Lunchbox’s compliance with this policy may be made in writing to:

By mail: Chief Privacy Officer
Lunchbox Consulting
1409 - 324 Laurier Avenue West,
Ottawa, ON, K1P 0A4
Tel: 613.796.3922
e-mail: info@lunchboxconsulting.ca

10.3 If an individual is not satisfied that Lunchbox is operating in compliance with requirements of PIPEDA, the individual may file a written complaint with the Commissioner at the following address:

Federal Privacy Commissioner
112 Kent Street
Place de Ville
Tower B, 3rd Floor
Ottawa, Ontario
K1A 1H3
Tel: 1-613-995-8210
Toll free: 1-800-282-1376
fax: 1-613-947-6850
e-mail: info@privcom.gc.ca