| 1. |
Accountability |
| |
PI has established policies and procedures to
comply with the
Privacy Code.
PI recognizes that it is responsible for personal
information in its possession or custody, including
information that has been transferred to a third
party for processing.
PI abides by the provisions of the Federal and any
Provincial privacy laws, and assumes responsibility
for doing so. |
| 2. |
Identifying
Purposes |
| |
As an agent involved in the transfer, rental,
sale or exchange of direct response lists and other
media, PI makes all reasonable efforts to ensure
that list and other media owners specify the nature
of the intended use of the data at or before the
time the
information is collected. |
| 3. |
Consent
|
| |
PI makes all reasonable efforts to ensure that
organizations providing personal information to
us or to our clients have obtained consent from
the consumer before disclosing this personal information.
PI ensures that all list and other media owners
have provided their consumers with a meaningful
opportunity to decline to have their name or other
information used for any further marketing purposes
by a third party. |
| 4. |
Limiting
Collection |
| |
As an agent involved in the transfer, rental,
sale or exchange of direct response lists and other
media, PI makes all reasonable efforts to ensure
that list and other media owners limit the collection
of the personal information on their lists to that
which is necessary for the intended use as identified
under Principle 2, Identifying Purposes. |
| 5. |
Limiting
Use, Disclosure, and Retention |
| |
As an agent involved in the transfer, rental,
sale or exchange of direct response lists and other
media PI agrees to keep personal information only
as long as necessary for the identified purposes. |
| 6. |
Accuracy |
| |
As an agent involved in the transfer, rental,
sale or exchange of direct response lists and other
media, PI defers to the obligation of marketers
to keep personal information on consumers as up-to-date
as possible for the defined need. |
| 7. |
Safeguards |
| |
As an agent involved in the transfer, rental,
sale or exchange of direct response lists and other
media, PI takes responsibility for the protection
of list data. As appropriate, divisions within PI
have individually developed.
This includes, but is not limited to, restricting
physical access to data, organizational restrictions
through security clearances on a "need-to-know"
basis, and technological measures such as passwords
and encryption. Care is also used in the disposal
or destruction of personal information so as to
prevent unauthorized parties from gaining access
to this information. |
| 8. |
Openness |
| |
PI is open and forthcoming about the policies
and procedures it uses to manage personal information.
Consumers have ready access to information about
these policies and procedures. PI makes every effort
to ensure that the consumer easily understands personal
information handling practices and procedures. |
| 9. |
Individual
Access |
| |
PI will work with consumers, list and other media
owners to fulfill the right of the consumer to know
of the existence, use and disclosure of his or her.
The consumer must recognize that they are required
to provide PI with sufficient personal information
that will allow us to determine whether we do hold
a personal information file pertaining to them.
The provision of this information shall not be used
for any other purpose. |
| 10. |
Challenging
Compliance |
| |
Consumers may challenge PI compliance with its
own privacy code. PI has policies and procedures
in place to receive, investigate and respond to
consumers' complaints and inquiries. |