Last Revised: December 19, 2017
DES has developed policies and procedures consistent with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and other relevant privacy laws.
Personal Information that DES may collect includes, but is not limited to:
• contact information (e.g. name, physical address, e-mail address, and telephone number);
• any other Personal Information that You may provide when You submit Your resume to DES (e.g. academic records, employment history);
• details of DES’s assessments and interviews with Candidates on behalf of Clients, or about Candidates with Clients;
• any other Personal Information that You may provide when You contact DES with questions and/or inquiries;
• any other Personal Information that You may enter when You use the Website or provide when you use or participate in DES’s services; and
• any information that DES collects from You that is intended to improve and personalize DES’s Website and/or services.
b. Non-Personally Identifiable Information
How does DES use Personal Information?
DES collects Personal Information for the following purposes:
• to provide the Website to You and other Website users;
• to provide DES’s services;
• to facilitate communication between Candidates and Clients;
• to establish and maintain responsible commercial relations and to communicate with You, Candidates, Website users, and DES’s clients;
• to respond to correspondence directed to DES;
• to understand the needs and preferences of You, Website users, Candidates, and Clients;
• to provide service or administrative messages;
• to meet legal and regulatory requirements; and
• for any other reasonable purposes for which You may have provided Your express consent or in which Your consent can be reasonably implied.
In addition, We may use Personal Information, on a de-identified basis, for research purposes to improve the Website and services.
How does DES use, collect and share NPI?
DES uses NPI in an ongoing effort to better understand and serve Website users, to better serve Clients, to customize the Website, to improve the content and functionality of the Website, and to improve DES’s services.
For instance, DES uses NPI to collect statistical data and to monitor Website traffic. DES analyzes Website users’ size, usage patterns, demographics, interests and behaviors. DES uses this information to provide the Website and to conduct internal research on the Website’s users, in each case to better understand and serve them.
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Where appropriate, DES will generally seek consent for the use or disclosure of the information at the time of collection. In certain circumstances, consent with respect to use or disclosure may be sought after the information has been collected but before use (for example, when DES wants to use information for a purpose other than those identified above). In obtaining consent, DES will use reasonable efforts to ensure that a customer is advised of the identified purposes for which Personal Information collected will be used or disclosed.
The form of consent sought by DES may vary, depending upon the circumstances and type of information disclosed. In determining the appropriate form of consent, DES shall take into account the sensitivity of the Personal Information and the reasonable expectations of DES’s Users. DES will seek express consent when the information is likely to be considered sensitive. Implied consent will generally be appropriate where the information is less sensitive.
You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. In order to withdraw consent, You must provide notice to DES in writing.
Limiting Use, Disclosure and Retention
DES shall not use or disclose or transfer Personal Information for any purpose other than those described above without first identifying and documenting the new purpose and obtaining Your consent, where such consent may not reasonably be implied.
If You are a potential Candidate, DES may share Your Personal Information with Clients. However, DES will not disclose any Personal Information about a Candidate to a Client without first obtaining the Candidate’s prior consent.
In the event Your Personal Information is disclosed to a third party pursuant to a business transaction, DES will ensure that it has entered into an agreement under which the collection, use and disclosure of the information is related to those purposes that relate to the transaction.
Subject to the foregoing, only DES’s and DES’s Affiliates’ employees, agents and contractors with a business need to know, or whose duties reasonably so require, are granted access to Personal Information about DES’s Users. All such employees, agents and contractors will be required to respect the privacy of Your Personal Information.
DES will retain Personal Information for only as long as required to fulfill the identified purposes or as required by law. Personal Information that is no longer required to fulfill the identified purposes will be destroyed, erased or made anonymous according to the guidelines and procedures established by DES.
Law Enforcement Requests
DES will disclose Personal Information without Your knowledge or consent if DES receives an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of Your Personal Information. If DES receives a written request from a police officer or other law enforcement agency with authority to request access to Your Personal Information in the course of an actual or potential investigation into a breach of a law, DES’s policy is to provide the requested information.
Storage Outside of Canada
Your Personal Information may be used or stored by DES or DES’s service providers outside of Canada. DES requires that DES’s service providers safeguard Your Personal Information. However, if Your Personal Information is used or stored outside of Canada, it will also be subject to the laws of the country in which it is used or stored.
Children and Minors
DES’s Website and services are not directed to children under the age of 13 years. DES will not knowingly collect Personal Information about a child under the age of 13.
Links to Other Websites
You may be able to access third-party websites through links available on DES’s Website.
How can I Access my Personal Information?
Upon request, DES will provide You information regarding the existence, use and disclosure of Your Personal Information and You will be given access to that information. DES will respond to an application for individual access to Personal Information within a reasonable time and at minimal or no cost to the individual. You may challenge the accuracy and completeness of the information and have it amended as appropriate.
NOTE: In certain circumstances, DES may not be able to provide access to all of Your Personal Information that it holds. Exceptions may include information that is prohibitively costly to provide, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, or information that is subject to solicitor-client or litigation privilege. DES will provide the reasons for denying access upon request.
DES protects Your Personal Information by security safeguards appropriate to the sensitivity of the information. DES will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.
DES’s methods of protection include:
• Physical measures, such as filing cabinets which are kept locked when not in use and restricted access, both to DES’s place of business in general and to internal offices as well;
• Organizational measures, such as security clearances and limited access on a need to know basis; and
• Technological measures, such as the use of passwords, firewalls and encryption.
Inquiries; Challenging Compliance
The Privacy Officer will respond to all such inquiries or complaints within 14 business days of receipt. The Privacy Officer will make reasonable efforts to resolve all such complaints within 30 days of receipt of the initial complaint. If DES finds a complaint to be justified, it will take appropriate measures, including, if necessary, amending its policies and procedures.
For more information, please contact DES’s Privacy Office as follows:
Dean Services Corp. d/b/a Dean Executive Search
145 King Street West