PRIVACY POLICY

Purpose of this Policy
1. Privacy of personal information is governed by the Personal Information Protection and Electronics Documents Act (“PIPEDA”). CCST's Privacy Policy describes the way that CCST collects, uses, and discloses personal information in the course of commercial activities, and states the CCST's commitment to collecting, using and disclosing personal information responsibly. The CCST Privacy Policy is based on the standards required by PIPEDA, and the CCST's interpretation of these responsibilities.

Personal Information
2. Personal information is information about an identifiable individual and includes information that relates to their personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status), their health (e.g., health history, health conditions, health services received by them) or their activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information, however, does not include business information (e.g., an individual's business address and telephone number), which is not protected by PIPEDA.

Accountability
3. Richard Bowlby is the Privacy Officer and is responsible for the monitoring of personal information collection, use, disclosure, data security and ensuring that all staff receives appropriate training on privacy issues. The Privacy Officer also handles personal information access requests and complaints. The Privacy Officer may be contacted at the following address:
Castor Canada

PO Box 401
Munster, ON
K0A 3P0
Tel: (613) 715-0804
Email: richard@castorcanada.com

Purpose
4. Personal information will only be collected by CCST to meet and maintain the highest standard of training. CCST collects personal information from prospective student, students, client, employers, managers, staff and volunteers for purposes that include, but are not limited to, the following:

a) Name, address, phone number, cell phone number, first language, fax number and e-mail address for the purpose of receiving information from CCST.

b) Individuals providing their addresses or e-mail addresses to CCST will receive advertisements from the CCST,  an e-mail bulletin and notifications of upcoming training.

Use of IP Addresses
5) We collect IP addresses to obtain aggregate information on the use of www.castorcanada.com An IP address is a number assigned to your computer by a Web server when you're on the Web. When you are on our site, we have a back-end server that logs your computer's IP address. We only use the information we find out from tracking IP addresses in the aggregate, such as how many users entered a specific area of our site, and not to track a specific IP address to identify an individual user. However, we may use such information to identify a user if we feel that there are or may be safety and/or security issues or to comply with legal requirements.

Cookies
Cookies are small text files that a Web browser transfers to and from your hard drive for record keeping purposes. Cookies make life easier for you by saving your passwords, purchases, and preferences while you're at our site. The use of cookies is an Internet standard, and you'll find cookies at most major Web sites.

The use of cookies is an industry standard and many major browsers are initially set up to accept them. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie. However, if you refuse to accept cookies, you may not be able to use some of the features available on websites.

CCST does not use cookies to identify specific individuals.

6. If a purpose has not been identified herein, CCST will seek consent from individuals when personal information is used for a purpose not already consented to. This consent will be documented as to when and how it was received.

Consent
7. CCST will obtain consent by lawful means from individuals at the time of collection, prior to the use or disclosure of the personal information. If the consent to the collection, use or disclosure was not obtained upon receipt of the information, consent will be obtained prior to the use or disclosure of that information. The CCST may collect personal information without consent where reasonable to do so and where permitted by law.

8. By providing personal information to CCST, individuals are consenting to the use of the information for the purposes identified in this policy.

9. CCST will not, as a condition of a product or service, require an individual to consent to the collection, use or disclosure of information beyond that required to fulfill the specified purpose.

10. An individual may withdraw consent to the collection, use or disclosure of personal information at any time, subject to legal or contractual restrictions, provided the individual gives one week's notice of such withdrawal to CCST. The Privacy Officer, or our staff will advise the individual of the implications of such withdrawal.

Limiting Use, Disclosure and Retention
11. Personal information will not be used or disclosed by CCST for purposes other than those for which it was collected as described herein, except with the consent of the individual or as required by law.

12. Personal information will be retained for certain periods of time in accordance with the following:

a) Personal information including address, phone number, cell phone number, first language and fax number will be retained for a period of ten years after training;

b) Personal Information collected via application forms will be retained for a period of six months to provide communications from CCST;s;

c) E-mail addresses will be retained for a period of 5 years in order to communicate with former client, staff and applicants.

d) As otherwise may be stipulated in federal or provincial legislation.

13. Personal information that is used to make a decision about an individual will be maintained for a minimum of one year of time to allow the individual access to the information after the decision has been made.

14. CCST may disclose personal information to a government authority that has asserted its lawful authority to obtain the information or where the CCST has reasonable grounds to believe the information could be useful in the investigation of an unlawful activity, or to comply with a subpoena or warrant or an order made by the court or otherwise as permitted by applicable law.

15. Documents will be destroyed by way of shredding and electronic files will be deleted in their entirety.

Accuracy
16. CCST will use accurate and up-to-date information as is necessary for the purposes for which it is to be used, to minimize the possibility that inappropriate information may be used to make a decision about an individual.

Indivduals have a right to access and correct any information about them in thier file.

Safeguards
17. Personal information is protected by security safeguards appropriate to the sensitivity of the information against loss or theft, unauthorized access, disclosure, copying, use or modification.

18. Methods of protection and safeguards include, but are not limited to, locked filing cabinets, restricted access to offices, security clearances, need-to-know access and technological measures including the use of passwords, encryption and firewalls.

19. The following steps will be taken to ensure security:

a) Paper information is either under supervision or secured in a locked or restricted area.

b) Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers.

c) Paper information is transmitted through sealed, addressed envelopes or in boxes by reputable courier/delivery companies.

d) Electronic information is transmitted either through a direct line or is encrypted.

e) Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with this policy.

f) External consultants and agencies with access to personal information will provide the CCST with appropriate privacy assurances.

Openness
20. CCST will publicize information about its policies and practices relating to the management of personal information. This information is available through the CCST's web site or upon request by contacting the Privacy Officer.

21. The information available to the public includes:
a) The name or title, address and telephone number of CCST's Privacy Officer.
b) The forms that may be used to access personal information or change information.
c) A description of the type of personal information held by the CCST, including a general statement of its approved uses.

Individual Access
22. Upon written request, and with assistance from CCST, an individual may be informed of the existence, use and disclosure of his or her personal information and will be given access to that information. As well, an individual is entitled to be informed of the source of the personal information along with an account of third parties to whom the information has been disclosed.

23. Requested information will be disclosed to the individual within 30 days of receipt of the written request at no cost to the individual, or at nominal costs relating to photocopying expenses, unless there are reasonable grounds to extend the time limit.

24. If personal information is inaccurate or incomplete, it will be amended as required.

25. An individual may be denied access to his or her personal information if:
a) This information is prohibitively costly to provide;
b) The information contains references to other individuals;
c) The information cannot be disclosed for legal, security or commercial proprietary purposes;
d) The information is subject to solicitor-client or litigation privilege.

28. Upon refusal, CCST will inform the individual the reasons for the refusal and the associated provisions of PIPEDA.

Applicable Law
This site is created and controlled by CCST in the province of Ontario. As such, the laws of the province of Ontario will govern these disclaimers, terms and conditions, without giving effect to any principles of conflict of laws.