Privacy Policy

Purpose and Scope 

AWSAM (Alliance of Women's Safety Apparel Manufacturers) is committed to maintaining the confidentiality, security, and accuracy of the Personal Information of the AWSAM’s Personnel and other third parties that is in its possession because of its normal business, including with respect to volunteer and charitable operations. 
 

AWSAM collects, uses, and discloses Personal Information about its Personnel, donors, customers, suppliers, and others with whom it has contact while conducting its normal business operations, including for purposes of establishing, managing, or terminating employment and contractual relationships between Personnel and AWSAM. This Policy describes and governs the collection, use and disclosure of Personal Information by AWSAM. 
 

This Policy applies to AWSAM, and to all Representatives. When a Representative, donor, customer, or supplier provides AWSAM with Personal Information, that individual consents to AWSAM’s collection, use and disclosure of their Personal Information for the designated purpose and agrees to the terms for accessing and correcting data as described below. 

The Policy governs AWSAM’s activities that are subject to the provisions of applicable privacy legislation, including the Personal Information Protection Act. However, as a not-for-profit organization, please note that certain of AWSAM’s activities may not be subject to applicable privacy legislation in all instances. 
 

Definitions 

Personal Information 
 

Information, recorded in any form, about an identifiable individual (including, (i) for employees: a home address and phone number, names of partners and spouses, a social insurance or security number, performance appraisals, medical and benefit information, or hobbies and interests, and (ii) for donors: any donation and billing information). 

This does not include the name, title, business address or telephone/facsimile number or business email address of an employee of an organization, when used for business communications. Also, it does not include anonymous, aggregated, or non-personal information or statistical data (i.e., information that cannot be associated with or tracked back to a specific individual). 
 

Personnel 

A director, officer, employee, volunteer, or independent contractor of AWSAM. 
 

Representative 
 

An employee or prospective employee of AWSAM, as well as any other individuals, including third parties that may provide and have access to Personal Information in AWSAM’s possession. 
 

AWSAM 

Alliance of Women's Safety Apparel Manufacturers and its divisions and affiliates, including all internal governance bodies. 

Questions 

If an individual has a question about (a) access to Personal Information, (b) the collection, use, management, or disclosure of Personal Information, (c) changing or withdrawing consent with respect to Personal Information, or (d) obtaining more information about this Policy or relevant legislation, please contact the office of our Privacy Officer by telephone or in writing or by e-mail at: 

  
Attention: Privacy Officer 
 

tel:  

email:  
 

AWSAM endeavors to answer all questions raised in a timely manner and advise in writing of any steps taken to address an issue brought forward. If an individual is not satisfied with AWSAM’s response, they may be entitled to make a written submission to the privacy authority applicable to their authority. 
 

Policy Statement 
 

Collection, Use and Disclosure of Personal Information 
 

Contents 

I. Personal Information 

II. Collection Rationale 

III. Use Or Disclosure Of Personal Information 

IV. Protection Of Personal Information 

V. Consent 

VI. Monitoring 
 

I. Personal Information 
 

AWSAM collects and maintains diverse types of Personal Information about individuals with whom it interacts (such as those who seek to be, are, or were employed by AWSAM, or volunteers, donors, customers, or suppliers of AWSAM), including: 
 

• identification and contact information: such as a Representative’s name, home address, telephone, personal email address, date of birth, social insurance or security number, marital and dependent status, videos, photographs, and beneficiary and emergency contact information. 

• employment information: such as a Representative’s job title, resumes and/or applications, interview notes, letters of offer and acceptance of employment, compensation and benefit information, background verification information, employment references, mandatory policy acknowledgement sign-off sheets and evaluations. 

• benefit information: such as forms relating to the application or change of employee health and welfare benefits, including but not limited to health care, life insurance, short- and long-term disability, medical and dental care. 

• payroll and financial information: including but not limited to social insurance numbers, wages, pay cheque deposit information, pension information, group savings plans, information, and tax related information. 

• business relationship and operations information: such as customer and supplier names, customer addresses and personal contacts, credit information, billing records, service and equipment records, any recorded customer complaints, investor contact information and requests, agreement terms, preferences, and information necessary to effect emergency response plans. 

• donor information: such as donor identities, donation amounts and banking information; and 

• other information necessary for AWSAM’s business purposes, which may be voluntarily disclosed or collected during a Representative’s application to and employment with AWSAM. 
   

As a rule, AWSAM collects Personal Information directly from the individual it pertains to. If third parties hold information AWSAM requires, AWSAM will endeavor to ensure the information has been collected with the appropriate consent. 
 

Where permitted or required by applicable law or regulatory requirements, AWSAM may collect Personal Information about an individual without their knowledge or consent. 
 

II. Collection Rationale 
 

AWSAM collects Personal Information to manage and develop its business and operations, and to support its volunteer and charitable activities, including: 
 

 
III. Use or Disclosure of Personal Information 

 
AWSAM may use and disclose Personal Information provided it is required in the following circumstances: 
 

AWSAM may use or disclose Personal Information without an individual’s knowledge or consent where it is permitted or required by applicable law or regulatory requirements to do so, including, but not limited to, circumstances relating to the establishment, maintenance, or termination of an employment relationship. 

AWSAM does not sell employee, volunteer, donor, or customer information to third parties. 

IV. Protection of Personal Information 

AWSAM endeavors to maintain physical, technological, and procedural safeguards that are appropriate to the sensitivity of the Personal Information in question. These safeguards are designed to prevent Personal Information from loss and unauthorized access, copying, use, modification, or disclosure. Examples of these safeguards include password, encryption, and other electronic security means; locked or limited access premises and file cabinets; and the security monitoring methods. AWSAM cannot guarantee the security of transferring information by virtual means, including via the Internet or telephone. 
 

Retention of Personal Information 
 

Except as otherwise permitted or required by applicable law or regulatory requirements, AWSAM endeavors to retain Personal Information only for as long as it believes is necessary to fulfill the purposes for which the Personal Information was collected (including, for the purpose of meeting any legal, accounting, or other reporting requirements or obligations). AWSAM may, instead of destroying or erasing Personal Information and where this is economically feasible, make it anonymous such that it cannot be associated with or tracked back to a specific individual. 
 

Updating Personal Information 
 

It is important that Personal Information contained in AWSAM’s records is both accurate and current. AWSAM asks that Personnel, donors, customers, and suppliers keep it informed of changes to Personal Information during the individual’s employment, charitable or business relationship with AWSAM. 

If an individual believes the Personal Information about them held by AWSAM is not correct, the individual may request an update of that information by making a request to our Privacy Officer using the contact information set out below. 

Accessing Personal Information 

An individual may ask to see the Personal Information that AWSAM holds about them. If individuals want to review, verify, or correct their Personal Information, they may contact our Privacy Officer at the coordinates set out below. Please note that any such communication must be in writing (whether by traditional or electronic means). 

When making an access request, AWSAM may require specific information from an individual to confirm their identity and right to access, as well as to search for, and provide that individual with, the Personal Information that it holds about them. AWSAM may charge a fee to access Personal Information; but it will advise of any fee in advance. If help is needed in preparing a request, please contact the office of our Privacy Officer. Where Personal Information will be disclosed to an individual, AWSAM will Endeavor to provide the information in question within a reasonable time, and in most cases, no later than 30 days following the request. 

An individual’s right to access the Personal Information that it holds about them is not absolute. There are instances where applicable law or regulatory requirements permit or require AWSAM to refuse a Personal Information access request. AWSAM also reserves the right to decline to provide access to Personal Information where the information requested: 

In addition, the Personal Information may no longer exist, may have been destroyed, erased, or made anonymous in accordance with AWSAM’s record retention obligations and practices. 

If AWSAM cannot provide an individual with access to their Personal Information, it will endeavor to inform that individual of the reasons why access has been denied, subject to any legal or regulatory restrictions. 

Out of Country Storage and Processing of Personal Information 

AWSAM will use data management systems and software solutions on a routine basis, to work with or provide its services to its Personnel, Representatives, donors, customers, suppliers, and others. As data processing technologies continually evolve, more systems and software solutions utilize “cloud-based” delivery models, where data processing and storage functionality is delivered from outside AWSAM’s premises and through the internet or similar connections to the service provider, and where AWSAM does not host the system or software solution within its physical premises. Accordingly, while AWSAM maintains its responsibility for the protection of this data and of the Personal Information contained within it, Personal Information collection, use, disclosure, processing, and storage may occur outside of USA. 

More specifically: 

V. Consent 

It is important to AWSAM that it collects, uses, or discloses Personal Information with consent to do so or as otherwise provided in this Policy. Depending on the sensitivity of the Personal Information, consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can be inferred from an individual’s action or inaction. For example, when financial information is requested for donation purposes, AWSAM will assume consent to the collection, use or disclosure of Personal Information for purposes related to that request for information or for other purposes identified by the requesting individual at the time. 

Typically, AWSAM will seek consent at the time that it collects the Personal Information. In some circumstances consent may be obtained after collection but prior to AWSAM’s use or disclosure of Personal Information. If AWSAM plans to use or disclose Personal Information for a purpose not previously identified (either in this Policy or separately), it will endeavor to advise an affected individual of that purpose before such use or disclosure. 

AWSAM may collect, use, or disclose Personal Information without an individual’s knowledge or consent where it is permitted or required to do so by applicable law or regulatory requirements. 

AWSAM assumes that, unless it is advised otherwise, by receiving a copy of this Policy or by continuing to engage in business with AWSAM, an individual will have consented to the collection, use and disclosure of their Personal Information as explained in this Policy. 

An individual is entitled to change or withdraw their consent at any time, subject to legal or contractual restrictions (and reasonable notice), by contacting our Privacy Officer using the contact information set out below. In some circumstances, a change in or withdrawal of consent may limit AWSAM’s ability to provide products or services to, or acquire products or services from, that individual. 

VI. Monitoring 

The work output of Personnel, whether in paper record, computer files, or in any other storage format belongs to AWSAM, and that work output, whether it is stored electronically, on paper or in any other format, and the tools used to generate that work product, are always subject to review and monitoring by AWSAM. 

While conducting AWSAM’s business, AWSAM may monitor Representative activities and its property. Pursuant to the Ownership of Computer Data, E-mail and Internet Use and Social Media policies, AWSAM has the capability to monitor all Personnel’s computer and e-mail use. 

Representatives should not have any expectation of privacy with respect to their use of AWSAM’s equipment or resources. This section is not meant to suggest that all Representatives will be monitored or their actions subject to constant surveillance – as AWSAM has no duty to monitor – it is meant to bring to each Representative’s attention the fact that such monitoring may occur and may result in the collection of Personal Information (e.g., through their use of AWSAM’s electronic resources). 

Any collection of Personal Information held or used while monitoring will not be more than is necessary for the purpose of the monitoring. Monitoring is or will be done on an “as required” basis and will be in proportion to the risks that AWSAM faces. AWSAM will conduct any monitoring in the least intrusive way possible. In some instances, when necessary, AWSAM may supplement this monitoring notice with more specific policies or statements as appropriate. 

Responsibility & Interpretation 

Any violation of this Policy will result in action by AWSAM. If any Representative misuses the Personal Information of another Representative, donor, or customer of AWSAM, it will be considered a serious offence for which appropriate disciplinary action may be taken, up to and including termination of employment. If any individual or organization misuses the Personal Information of a Representative – provided for the purpose of providing services to AWSAM – it will be considered a genuine issue for which appropriate action may be taken, up to and including termination of the service agreement or court action. 

Any interpretation associated with this Policy will be made by the Privacy Officer. This Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word ‘including’ is used, it shall mean ‘including without limitation’. 

Policy Revision 

AWSAM will review and revise this Policy from time to time to reflect changes in legal or regulatory obligations or changes in the manner in which it deals with Personal Information, and in any event, at least every 12 months. Any revised version of this Policy will be posted, and each Representative is encouraged to refer back to it on a regular basis. Any changes to this Policy will be effective from the time they are posted, provided that any change that relates to why AWSAM collects, uses or discloses Personal Information will not apply to a particular Representative, where their consent is required to such collection, use, or disclosure, until AWSAM has obtained that Representative’s consent to such change. 

This Policy does not create or confer upon any individual any rights, or impose upon AWSAM any rights or obligations outside of, or in addition to, any rights or obligations imposed by applicable privacy legislation. Should there be, in a specific case, any inconsistency between this Policy and relevant legislation, this Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy legislation.