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Harpe & Associates recognizes the importance of privacy and the
sensitivity of personal information. As an organization that
administers licensure examinations, Harpe acknowledges its obligation to
serve a number of constituencies while ensuring that matters of
confidentiality are recognized and adhered to. The protection of private
information has always been an important part of Harpe & Associates'
operation. Harpe & Associates is committed to protecting any personal
information that it holds. The employees and representatives of Harpe
and Associates have been instructed as to what policy the organization
has established to handle personal information. This Privacy Policy
outlines how Harpe & Associates manages personal information and
safeguards privacy.
Harpe & Associates Privacy Policy sets out Harpe & Associates'
commitment to, and policy on, privacy. It sets out the ways the
organization ensures privacy and the confidentiality of the personal
information that is collected by Harpe & Associates.
Privacy Rights:
From January 1, 2004, all businesses engaged in commercial activities
must comply with the Personal Information Protection and Electronic
Documents Act, and the Canadian Standards Association Model Code for the
Protection of Personal Information, which it incorporates. These
obligations extend to administrative and test organizations. The Act
sets out rights concerning the privacy of your personal information. The
following is the website at:
http://laws.justice.gc.ca/en/P-8.6/index.html.
Harpe & Associates is responsible for the personal information that it
collects and holds. To ensure this accountability, it has developed this
policy, and trained its staff and administration about its policies and
practices.
Why Harpe and
Associates Needs Personal Information:
Harpe & Associates has a number of functions. Its primary mandate is
to create licensure examinations for various professional bodies. It
also functions as a research facility and provides information related
to the psychometric profession. In doing so, it produces applicant and
registrant lists, annual reports, and a website.
What Personal
Information Is Collected?
If
Harpe & Associates did not collect and use personal information it
could not hire staff or report information that is necessary to be
received by contracted clients, regulatory bodies, and others who
require information related to the operation of Harpe & Associates.
How Does Harpe and
Associates Collect Personal Information?
Harpe & Associates collects information only by lawful and fair means
and not in an unreasonably intrusive way. Wherever possible, it collects
personal information directly from an individual, at the application
process, during the examination process, and at the time of hiring of
staff. Sometimes information is obtained from other sources, for
example:
·
Educational institutions
·
Previous employers
·
Licensing boards
Consent
In
most cases, Harpe & Associates will ask individuals to consent if it
collects, uses, or discloses personal information. Normally, Harpe and
Associates will ask for consent in writing, but in some circumstances,
it may accept oral consent. Sometimes, consent may be implied through
conduct with Harpe & Associates.
Use of Information
Harpe & Associates uses personal information to provide services with
respect to such matters as testing and notice to clients of results of
processed examinations. If Harpe & Associates is advised that an
individual or organization no longer wishes to receive information from
Harpe & Associates, it will not send any further material.
Harpe & Associates does not disclose personal information to any third
party to enable them to market their products and services.
Disclosure of Personal
Information
Under certain circumstances, Harpe & Associates will disclose personal
information;
Ø
When a client has consented to
the disclosure.
Ø
When Harpe & Associates is
required or authorized to do so, for example, if a court issues a
subpoena.
Ø
When the services Harpe and
Associates is providing requires it to give personal information to
third parties, consent will be implied unless Harpe & Associates is
advised otherwise.
Ø
Where it is necessary to
collect clients fees or accounts owing.
Ø
If Harpe & Associates
engages a third party to provide administrative services to us (such as
file storage) and the third party is bound by Harpe and Associate's
privacy policy.
Ø
If Harpe & Associates
engages proctors on a contract basis.
Ø
If Harpe & Associates
undergoes any accreditation process for the purposes of continuing to
carry out the service it provides.
Ø
If the information is already
publicly known.
Updating Information
Since Harpe & Associates uses personal information to provide
services, it is important that the information be accurate and up to
date.
If,
as a client any information changes, it is important that Harpe and
Associates be advised of any changes so that is records can be up-dated.
Is Personal
Information Secure?
Harpe & Associates takes all reasonable precautions to ensure that
personal information is kept safe from loss, unauthorized access,
modification or disclosure. Among the steps taken to protect the
information are:
Ø
Premises security
Ø
Restricted file access to
personal information
Ø
Deploying technological
safeguards like security software and firewalls to prevent hacking or
unauthorized computer access
Ø
Internal password and security
policies
Access to Personal
Information
An
individual may ask for access to any personal information that Harpe and
Associates holds about the individual.
Summary information is available upon request. More detailed requests
which require archive or other retrieval costs may be subject to
professional and disbursement fees.
Correcting Errors
If
Harpe & Associates holds information about an individual and he or she
can establish that it is not accurate, complete and up-to-date, Harpe
and Associates will take reasonable steps to correct it.
Can Access to Personal
Information be Denied?
An
individual's right to access personal information is not absolute.
Harpe & Associates may deny access when:
Ø
Denial of access is required
or authorized by law (for example, when a record containing personal
information about an individual is subject to a claim of legal
professional privilege).
Ø
Information relates to
existing or anticipated legal proceedings against an individual.
Ø
When granting an individual
access would have an unreasonable impact on other people's privacy.
Ø
When to do so would prejudice
negotiations with an individual.
Ø
To protect Harpe and
Associates' rights and property.
Ø
Where the request is frivolous
or vexatious.
Ø
If Harpe & Associates denies
a request for access to, or refuses a request to correct information, it
shall explain why.
Communicating with
Harpe & Associates
Individuals should be aware that email and voicemail are not 100% secure
mediums, and should be aware of this when contacting Harpe and
Associates to send personal or confidential information.
Changes to this
Privacy Policy
Since Harpe & Associates regularly reviews all of its policies and
procedures, it may change its Privacy Policy from time to time.
Requests for Access
For
the purposes of dealing with any questions, or with respect to access to
personal information, please write to Harpe & Associates' Privacy
Contact at:
Harpe & Associates
28
Patterson Crescent S.W.
Calgary, AB T3H 2C4
Attention: Privacy Officer
If
you are not satisfied with your response, the Privacy Commissioner of
Canada can be reached at:
112
Kent Street
Ottawa, ON K1A 1H3
1-800-282-1376
Employment Inquiries
If
you apply to Harpe & Associates for a job, Harpe & Associates will
need to consider an applicant's personal information, as part of its
review process. Harpe & Associates normally retains information from
candidates after a decision has been made, unless it is asked to not
retain the information and Harpe & Associates determines it
appropriate to refrain from retaining the information. If an offer of a
position is provided to an individual who accepts same, the information
will be retained in accordance with Harpe & Associates' privacy
procedures for employee records.
Web Site
The
Harpe & Associates web site contains links to other sites, which are
not governed by this privacy policy. On the Harpe & Associates web
site, like most other websites, there is a monitoring of traffic
patterns, site usage, and related site information in order to optimize
the web services. Harpe & Associates may provide aggregated
information to third parties, but these statistics do not include any
identifiable personal information.
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