At Soteria Policy Group Inc. (“Soteria Policy”) we respect your privacy and are committed to protecting personal information in accordance with applicable laws and regulations. Soteria Policy’s information practices comply with the fair information principles set out in Schedule 1 of the Personal Information Protection and Electronic Documents Act, 2000 (PIPEDA).

Accountability

Soteria Policy is responsible for personal information in its possession or under its control, and through its Chief Privacy Officer, ensures the organization’s legislative compliance. Soteria Policy’s privacy program is supported by:

Comprehensive policies and procedures to protect personal information, including any information transferred to third party service providers; Privacy and information security awareness training for employees; and Procedures to receive and respond to complaints, inquiries and requests to access personal information.

Identifying Purposes

Soteria Policy will make individuals aware of the purpose(s) for which personal information is being collected at or before the time the information is collected. When personal information that has been collected is to be used for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is required by law, the consent of the individual will be obtained before the information is used for that purpose.

Consent

Soteria Policy will only collect, use or disclose personal information with the individual’s knowledge and consent, and only for an explicitly specified and legitimate purpose. An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.

Limiting Collection

Soteria Policy will collect only the personal information needed to fulfill the purposes for which consent was obtained, and by fair and lawful means.

Limiting Use, Disclosure and Retention

Soteria Policy will only use or disclose personal information for the identified purposes for which it was collected, unless doing so is required by law or the individual provides consent for the new purpose(s).

Soteria Policy will only retain personal information for as long as necessary for the fulfilment of those purposes. Personal information that is no longer required will be securely destroyed.

Accuracy

Soteria Policy takes reasonable steps to ensure that personal information is sufficiently accurate, complete and up-to-date to fulfill the purposes for which the information was collected.

Safeguards

Soteria Policy implements and maintains safeguards to protect personal information against loss, theft, or any unauthorized access, disclosure, copying, use, or modification. Safeguards, which include physical, technological and organizational measures, are continually monitored and updated as required in response to new technologies and risks.

Openness

Through this policy, Soteria Policy endeavours to provide clear, understandable information about its privacy practices. We are also committed to providing the necessary information to obtain meaningful consent for the collection, use and disclosure of personal information.

Individual Access

Upon request, an individual will be informed of the existence, use and disclosure of their personal information, and be given access to that information, subject to limited exceptions under PIPEDA. An individual also has the right challenge the accuracy and completeness of the information, and have it amended as appropriate. Soteria Policy will respond to all requests for access or correction as quickly as possible and no later than 30 days after receiving it.

Challenging Compliance

Complaints or inquiries about Soteria Policy’s policies and practices relating to the handling of personal information can be made to its Chief Privacy Officer whose contact information is available on this page. Soteria Policy will investigate all complaints. If a complaint is found to be justified, Soteria Policy will take appropriate measures, including, if necessary, amending its policies and practices.