Privacy PolicyDate created: November 19, 2004 Introduction Our Privacy Policy is based on the Canadian Personal Information Protection and Electronic Documents Act (PIPEDA - see http://www.privcom.gc.ca for more information). This policy describes how Thinkwell Research adheres to the ten principles of privacy set out in this Act. Definition Of Terms Used In This Privacy Policy "Sub-contractor" means a non-affiliated service provider contracted to provide research-related activity on Thinkwell Research's behalf. Examples of such activity include sample development, Computer Assisted Telephone Interviewing (CATI) programming, and data collection activity such as telephone and Internet surveys. "Personal Information" means information that individually or in combination could identify a specific individual. Examples include first and last name, home postal address or personal email address. "Privacy Officer" means the person at Thinkwell Research who is responsible for ensuring the protection of individuals' personal information. "Respondent" means a member of the public who is contacted by Thinkwell Research or a sub-contractor for the purpose of conducting Survey Research. "Survey Research" means telephone surveys, mail surveys, Internet surveys, door to door surveys, panel, mall intercept surveys, business-to-business surveys, qualitative surveys, one-on-one interviews, and all other types of survey research. The Ten Principles Of Privacy 1. Accountability Thinkwell Research has designated the office of the Privacy Officer to be responsible for overall personal information protection and Thinkwell's compliance with the PIPEDA. 2. Identifying Purposes When our interviewers contact respondents by telephone or in-person, they state the purpose of their contact. When Thinkwell Research sends written invitations and/or questionnaires to respondents, the invitation/questionnaire clearly identifies us as Thinkwell Research and explains the purpose of our contact, which is that Thinkwell Research is conducting survey research and would like the respondent to participate in a survey. Our interviewers advise respondents that their responses are used strictly for research purposes. Thinkwell Research may provide information from any survey, in aggregate form, to clients who sponsor that survey or to other third parties. Since this information is in aggregate form, clients or other third parties will be unable to identify an individual's specific personal information. 3. Consent Participation in our survey research is voluntary. Consent is obtained when a respondent agrees to participate in survey research. When this happens, and the method of data collection is by telephone or in-person, our interviewers then conduct an interview with the respondent. When the method of data collection is by mail, computer or via the Internet, the respondent completes a questionnaire himself/herself. Survey responses may be collected, stored or processed by Thinkwell Research or a non-affiliated service provider, both within and outside Canada. They will keep any information they collect and disclose to us or we collect and disclose to them confidential and will protect it with security standards that are broadly equivalent to our own. Generally, personal information collected is not disclosed to other parties. Occasionally, however, a client conducting a survey research project may want to contact respondents directly. In these cases, Thinkwell Research does not disclose a respondent's personal information to another party unless it has first clearly explained to the respondent the purpose of such disclosure and has obtained the respondent's express or written consent. An individual may refuse to answer certain questions, discontinue participation in a study, or withdraw consent at any time. 4. Limiting Collection Thinkwell Research limits the amount and type of personal information it collects. We collect only the amount and type of information needed for the purposes identified to the individual. Thinkwell Research collects personal information about an individual primarily from that individual or a member of that individual's household. Except as permitted by law, Thinkwell Research will only collect personal information from external sources, such as client organizations, if individuals have consented to such collection. 5. Limiting Use, Disclosure, and Retention Thinkwell Research uses or discloses personal information only for the reasons it was collected, unless an individual gives consent to use or disclose it for another reason. Thinkwell Research keeps personal information only as long as necessary for the identified purposes. Personal information that is no longer needed for its identified purposes or for legal requirements is destroyed, erased or made anonymous. 6. Accuracy Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. Thinkwell Research makes reasonable efforts to keep personal information it uses on an on-going basis accurate, complete, current and relevant, based on the most recent information available. Thinkwell Research updates personal information only if it is necessary for the purposes for which it was collected. 7. Safeguards Thinkwell Research safeguards personal information in its possession or control from loss or theft and from unauthorized access, disclosure, duplication, use or modification. Some information is stored electronically. Recent paper records containing individuals' personal information are stored onsite at our office. Older records containing individuals' personal information may be stored at an offsite storage facility. Thinkwell Research safeguards personal information in its possession or control through security measures, such as:
Thinkwell Research uses care when disposing of or destroying personal information in order to prevent unauthorized access to the information. 8. Openness Thinkwell Research is open about its procedures used to manage personal information. Individuals have access to information about these procedures through this Privacy Policy or by contacting the Privacy Officer. If we make a material change to this policy or our privacy practices, we will post a prominent notice on our website (www.thinkwellresearch.ca) for 30 calendar days prior to the implementation of the material change. Following the implementation of the material change, we will record at the introduction of this policy when the policy was last revised. 9. Individual Access When an individual makes a written request to the Privacy Officer, Thinkwell Research will advise the individual what personal information it has in its possession or control about the individual, what it is being used for, and to whom it has been disclosed. When an individual requests it, Thinkwell Research will give an individual access to personal information about them which is in the possession or control of Thinkwell Research. In certain situations, however, Thinkwell Research may not be able to give individuals access to all of their personal information. This may occur when:
If Thinkwell Research denies the individual's request for access to personal information, it will advise the individual of the reason for the refusal. 10. Provide Recourse Individuals may challenge Thinkwell Research's compliance with this Privacy Policy. Individuals are advised to direct their complaints and questions in writing to the Privacy Officer. Thinkwell Research will investigate all complaints and attempt to resolve those that it finds are justified. If necessary, Thinkwell Research will amend its policies and procedures. If individuals are not satisfied with the way Thinkwell Research responded to their complaint, they can contact the Federal Privacy Commissioner. They can also contact The Marketing Research and Intelligence Association (MRIA), a Canadian not-for-profit association representing all aspects of the market intelligence and survey research industry. Contacting Us Correspondence can be mailed to: Privacy Officer All contents © 2004-2009 Thinkwell Research |