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/ PRIVACY POLICY
Grohe Canada Inc.
Third Party Privacy Commitment

Grohe Canada Inc. collects, retains and uses information about its customers, suppliers, contractors, and others with whom it has contact in the course of conducting its business activities. Grohe Canada Inc. is committed to protecting the privacy of its clients and customers and all confidential business information obtained in the course of doing business. To achieve this purpose Grohe Canada Inc. has appointed a Privacy Compliance Officer who can be contacted at:

Privacy Compliance Officer
Grohe Canada Inc.
1230 Lakeshore Rd East
Mississauga, Ontario
L5E 1E9
privacy@grohecanada.com

Grohe Canada Inc. is committed to maintaining the accuracy, confidentiality, security and privacy of the personal information that is in its possession, whether that personal information is about its customers, its suppliers or any other individuals whose personal information may have been collected for use (collectively the customers).

Grohe Canada Inc. expects all employees to comply with the privacy principles set out in this policy and has undertaken training of its employees to satisfy the privacy commitment Grohe Canada Inc. has made to its customers. Employees shall not collect, disclose or use personal information of customers without explaining the purpose for collecting the information and obtaining the consent of the customer to use the information.

The Privacy Compliance Officer or designate is responsible for reviewing this policy with all employees on a regular and ongoing basis.

  1. DEFINITIONS
    1. Personal Information includes any factual or subjective information, recorded or not, that identifies or can be manipulated to identify an individual. This includes information in any form such as an individual's personal e-mail address, credit card numbers, home addresses, identification numbers, age, or date of birth. It generally does not include information normally found on a business card, such as name, title, company, business address, business e-mail address, business telephone or fax number. Nor does it normally include personal information that an individual collects, uses or discloses about another individual strictly for personal, non-commercial uses.
    2. Commercial Activity is a particular transaction, act or conduct (or a regular course of conduct) of a commercial character, specifically including the selling, bartering or leasing of donor, membership or other fundraising lists. It is the nature of the activity, not the nature of the organization that counts.
    3. Third Parties are individuals or organizations other than the subject of the records or representatives of Grohe Canada Inc. Note that in certain circumstances, the company may be entitled to provide personal information to an external party acting as an agent of Grohe Canada Inc.

  2. SUMMARY OF PRIVACY PRINCIPLES Grohe Canada Inc. is committed to ensuring that the following principles are embraced:
    1. Accountability: Grohe Canada Inc. is responsible for personal information in its care, custody and/or control. To this end, Grohe Canada Inc. is committed to educating its employees on their responsibilities. Furthermore, when we use trusted third parties to act on our behalf, we will ensure compliance to this policy by such third parties. In addition Grohe Canada Inc. has appointed a Compliance Privacy Officer who is responsible for the organization's compliance with PIPEDA and other provincial privacy legislation acceptable to PIPEDA.
    2. Identifying Purpose: Unless the purpose is self-evident, Grohe Canada Inc. will clearly explain to the customers identified the purpose for which information is collected, before or at the time of collection.
    3. Consent: Grohe Canada Inc. will only record, use or disclose such personal information with the customer's knowledge and consent except where required and permitted by law. Consent must be expressed, and may be given in writing, oral or electronic form. Grohe Canada Inc. will also ensure that customers understand the implications of not providing their consent, and what notice would be required if consent is withdrawn at any point. Grohe Canada Inc. will take the necessary steps to obtain consent from customers whenever previously collected personal information is put to a new use. Grohe Canada Inc. will not refuse service to a customer if consent is not given unless Grohe Canada Inc. is entitled to do so under a valid law of Canada.
    4. Limiting Collection: Grohe Canada Inc. will collect personal information only by fair and lawful means; limiting the collection of personal information to only those details necessary for the purpose(s) expressed when consent was given.
    5. Limiting Use, Disclosure and Retention: Personal information will only be used for the purposes for which it was collected unless additional consent has been obtained or when it is required or permitted by law. It will be retained only as long as necessary for these purposes or as required by law. When the personal information collected is no longer required to be retained by Grohe Canada Inc. it will be destroyed as appropriate for the medium it was stored in.
    6. Accuracy: Personal information will be maintained as accurately and completely as is necessary to fulfill the purposes for which it was collected.
    7. Safeguarding: Personal information is protected by physical, procedural and electronic security safeguards appropriate to the type of information collected. Safeguards will vary according to the sensitivity, format, location, amount, distribution and storage of the personal information. They may include locks on physical storage, restricted access, passwords, and employee training.
    8. Openness: Grohe Canada Inc. will make information available to individuals concerning the policies and practices that apply to the management of their information.
    9. Access: Upon request, Grohe Canada Inc. will inform customers of the existence, use and disclosure of personal information. Customers may at any time verify the accuracy and completeness of the information and request that it be amended if appropriate. Customers are also entitled to review the consent given and may request that consent be revoked at any time.
    10. Challlenging Compliance: Grohe Canada Inc. has appointed the Privacy Compliance Officer to serve as the contact point for all questions or concerns customers may have with respect to these principles. The Privacy Compliance Officer can be contacted at:
      1230 Lakeshore Road East
      Mississauga, Ontario
      L5E 1E9
      (905) 274-3323
      privacy@grohecanada.com.

      Customers can also direct their concerns about this policy or their personal information to the:
      Office of the Privacy Commissioner of Canada
      112 Kent Street
      Place de Ville
      Tower B, 3rd Floor
      Ottawa, ON
      K1A 1H3

  3. RESPONSIBILITY
    1. Privacy Compliance Officer is responsible for:
      • Internal compliance with applicable policies or legislation;
      • Cooperating with Supervisors, human resources and/or payroll personnel in developing internal policies for the collection, use and disclosure of personal information of clients;
      • Monitoring and responding to Third Party requests for personal information;
      • Ensuring appropriate consents are obtained for the collection, use and disclosure of personal information;
      • Where collection, use or disclosure is permitted without prior consent, notifying customers of the collection, use and disclosure of personal information and obtaining any necessary consent after such occurrence.
  4. PROCEDURE:
    1. Reinforcing understanding: Privacy Compliance Officer or designate:
      • Incorporates importance of confidentiality during regular in-services.
      • Reinforces importance of confidentiality during regular supervision.
      • Evaluates understanding and compliance in annual performance review.
      • Provides employees with new information regarding legislative changes and requirements in a timely manner.
    2. Ensuring Compliance:
      Internal Auditors:
      • Evaluate understanding and compliance during internal audits.

      Quality Program Manager:
      • Oversee compliance within the organization by ensuring adequate and ongoing training to all Grohe Canada Inc. employees.
      • Review all complaints with regard to breach and/or perceived breach of privacy.
      • Initiate improvement initiatives as a result of complaints.

  5. EXAMPLES OF INFORMATION CONSIDERED TO BE CONFIDENTIAL
    1. Grohe Canada Inc. and Customer Information This includes written or verbal information such as:
      • Information regarding application lists and resumes.
      • Customer lists and information pertaining to customer's business techniques and procedures, Grohe Canada Inc. business techniques and procedures, Grohe Canada Inc. financial information.

  6. PRACTICES THAT PROTECT CLIENT PRIVACY:
    • Work with a Clean Desk policy. During working hours, minimal information is left out in easy view of office traffic. After hours, all records and documents containing personal information are stored in locked filing cabinets out of view of cleaning or maintenance staff.
    • Conduct telephone conversations at a volume of voice that does not allow visitors to hear confidential information. Telephone conversations should be finished before allowing employees / clients to approach their desk.
    • Computer screens displaying personal information are kept out of view of individuals visiting the office, as much as possible.
    • Assignments are given to employees in a manner that ensures other employees cannot hear details of the assignment.
    • Shred all documents containing personal information and instruct employees to return documents no longer required to the office for shredding; these are not thrown away intact in the regular garbage or recycle bins.
    • Shred all client identifying information in a confidential manner when no longer required ex. billing slips, schedules, profiles, notes.
    • Refrain from discussing clients in public places.

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