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our firmWatson Wyatt Canada External Privacy Policy |
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Watson Wyatt Canada External Privacy PolicyThis Policy outlines the continued commitment of the Canadian offices and operations of Watson Wyatt Canada ULC (Watson Wyatt Canada) to safeguarding the privacy of personal information supplied to us by our clients, prospective clients, employees of such clients and the general public, and the rights of these groups regarding the personal information supplied to us. It covers personal information supplied to us directly by the groups mentioned above, and personal information concerning their employees supplied to us by clients utilizing our consulting services. This Policy applies to all Watson Wyatt employees in Canada who deal with the personal information of clients, prospective clients and the general public. The contents of this policy also fully comply with the Federal Personal Information Protection and Electronic Documents Act, which applies to the personal information collected, used or disclosed in connection with commercial activities as of January 1, 2004, and all applicable provincial privacy legislation. Accountability To the extent required by law and as governed by this Policy, Watson Wyatt Canada is responsible for personal information under its control, in most circumstances, as the agent of our clients, and we have designated a Privacy Officer who is responsible for ensuring the company’s compliance with this Policy. Information regarding how to contact Watson Wyatt Canada’s Privacy Officer can be found under “Openness Concerning Policies and Practices” below. Identifying Purposes Watson Wyatt Canada will only use personal information collected from clients, prospective clients, employees of such clients and the general public to respond to requests, to provide information about our company and our services and to provide consulting services to our clients, unless we obtain specific permission to use that personal information for other purposes. If prospective clients, employees of such clients and the general public do not wish to receive general e-mails or communications from our office, we will discontinue the communications on request. Obtaining Consent for the Collection, Use and Disclosure of Personal Information Except where inappropriate, Watson Wyatt Canada requires the knowledge and consent (whether express or implied) of clients, prospects and the general public to the collection, use and disclosure of personal information provided to us. It is the responsibility of clients utilizing our consulting services to use appropriate means to obtain consent to the collection of the personal information that they provide to us. Watson Wyatt Canada does not collect any personal information about users of our web site (www.watsonwyatt.com) unless they take advantage of its customization features. We collect only aggregate information about the behavior of web visitors in order to improve the quality of the site. Additional information about privacy on our web site can be obtained by viewing the Privacy Policy at www.watsonwyatt.com/privacy/ Wyatt Canada reserves the right to disclose personal information to the extent required by law or court order, to cooperate in a criminal investigation, or to enforce or protect our property or contractual rights legal process, subject to compliance with any written agreements pertaining to such personal information and to reasonable efforts to contact the client for instructions regarding such disclosure. Limiting Collection of Personal Information It is the responsibility of clients utilizing Watson Wyatt Canada’s consulting services to follow fair and lawful means in collecting personal information that they provide to us. The personal information collected directly by Watson Wyatt Canada will be limited to that which is reasonably necessary to respond to requests, to provide information about our company and our services and to provide consulting services to our clients. All personal information Watson Wyatt Canada collects for these purposes shall be collected by fair and lawful means. Limiting Use, Disclosure and Retention of Personal Information Watson Wyatt Canada will retain personal information we receive only for as long as is required to fulfill the purposes for which it was collected, as required by law, or pursuant to Watson Wyatt’s Records Retention Policy. We do not sell personal information with parties outside of Watson Wyatt Worldwide, with the following exceptions: to fulfill user requests for publications; for event registrations; and for surveys. As used in this Policy, “Watson Wyatt Worldwide” means, collectively, Watson Wyatt Worldwide, Inc. and all of its subsidiaries, affiliates, and alliance partners with respect to their worldwide operations. Any data collected by Watson Wyatt Canada may be transferred internationally throughout Watson Wyatt Worldwide, but only for internal purposes. By submitting personal information to Watson Wyatt Canada electronically, Watson Wyatt Canada assumes that explicit consent is provided to this trans-border transmission of data for these purposes. Accuracy of Personal Information Watson Wyatt Canada assumes that the personal information provided by clients, prospective clients, employees of such clients and the general public for the purposes identified in this Policy is accurate. We will permit clients, prospective clients and the general public to review, correct or update their personal information. However, in the case personal information that has been transferred to us by our clients, our Privacy Officer will direct the individual to the appropriate contact within the transferring organization. Access to Personal Information Following the receipt of a written request from a member of the general public for access, our Privacy Officer will, within a reasonable time, respond to the request advising what personal information Watson Wyatt Canada has, the purposes for which it is being used, and to whom it has been disclosed. In the case of an access request from an individual relating to personal information that has been transferred to us by our clients, our Privacy Officer will direct the individual to the appropriate contact within the transferring organization. In certain situations, access may not be provided to all the personal information Watson Wyatt Canada possesses about an individual. If this is the case, our Privacy Officer will advise the individual of the reasons for this lack of access and any recourse the individual may have, except where prohibited by law. Information regarding how to contact Watson Wyatt Canada’s Privacy Officer can be found under “Openness Concerning Policies and Practices” below. Security Safeguards To prevent unauthorized access, to maintain data accuracy, and to ensure the correct use of personal information, Watson Wyatt Canada has implemented appropriate physical, electronic and managerial procedures. These procedures are designed to safeguard and secure the information we collect on-line from loss, misuse, unauthorized alteration or unintentional destruction. Openness Concerning Policies and Practices Additional information about Watson Wyatt’s privacy policies and practices can be obtained by contacting our Privacy Officer at the address below, or by e-mail at canprivacyofficer@watsonwyatt.com. Privacy Officer Our Privacy Officer has ultimate responsibility for Watson Wyatt Canada’s compliance with this policy and with applicable privacy legislation. Challenging Compliance Any complaints or concerns about the treatment of personal information by Watson Wyatt Canada, should be addressed, in writing, to our Privacy Officer. Privacy Officer A response will be provided within 30 days of our receipt of written notification of the complaint or concern. If matters are not satisfactorily resolved, a complaint may be filed with the appropriate privacy commissioner, whether federal or provincial, at the addresses below. Federal: |
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