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Community Futures DevelopmentGovernment of Canada

Privacy Policy

1.0  Purpose of Privacy Policy

GCFDC is a federally supported not-for-profit community organization with a volunteer board of directors and professional staff whose purpose is to develop and diversify local economies. GCFDC supports community economic development and small business growth by developing and implementing strategic community plans, delivering a range of counselling and information services to small business and operating locally controlled investment funds to provide repayable financing to new and existing businesses.

This privacy policy has been developed to comply with Canada’s Personal Information Protection and Electronic Documents Act ("PIPEDA"). PIPEDA sets out rules for the collection, use and disclosure of personal information in the course of commercial activity as defined in the Act.

1.1 The Ten Principles of PIPEDA Summarized

The ten Principles of PIPEDA that form the basis of this Privacy Policy are as follows:

  1. Accountability: organizations are accountable for the personal information they collect, use, retain and disclose in the course of their commercial activities, including, but not limited to, the appointment of a Chief Privacy Officer;
     
  2. Identifying Purposes: organizations are to explain the purposes for which the information is being used at the time of collection and can only be used for those purposes;
     
  3. Consent: organizations must obtain an Individual’s express or implied consent when they collect, use, or disclose the Individual’s personal information;
     
  4. Limiting Collection: the collection of personal information must be limited to only the amount and type that is reasonably necessary for the identified purposes;
     
  5. Limiting Use, Disclosure and Retention: personal information must be used for only the identified purposes, and must not be disclosed to third parties unless the Individual consents to the alternative use or disclosure;
     
  6. Accuracy: organizations are required to keep personal information in active files accurate and up-to-date;
     
  7. Safeguards: organizations are to use physical, organizational, and technological safeguards to protect personal information from unauthorized access or disclosure;
     
  8. Openness: organizations must inform their clients and train their employees about their privacy policies and procedures;
     
  9. Individual Access: an Individual has a right to access personal information held by an organization and to challenge its accuracy if need be; and
     
  10. Provide Recourse: organizations are to inform clients and employees of how to bring a request for access, or complaint, to the Chief Privacy Officer, and respond promptly to a request or complaint by the Individual.

This Privacy Policy applies to GCFDC's Board of Directors, members, employees and contracted employees. As well; GCFDC ensures that all third party service providers sign confidentiality agreements prior to any transfer of an Individual's personal information in the course of providing the business loans, business development advice, and other related information and/or services.

1.2 Definitions

"Personal information" means any information about an identifiable Individual. It includes, without limitation, information relating to identity, nationality, age, gender, address, telephone number, e-mail address, Social Insurance Number, date of birth, marital status, education, employment health history, assets, liabilities, payment records, credit records, loan records, income and information relating to financial transactions as well as certain personal opinions or views of an Individual.

"Business information" means business name, business address, business telephone number, name(s) of owner(s), officer(s) and director(s), job titles, business registration numbers (HST, source deductions), financial status. Although business information is not subject to PIPEDA, confidentiality of business information will be treated with the same security measures by GCFDC staff, members and Board members, as is required for Individual personal information under PIPEDA.

"Client" means the business that is applying for or has been granted a loan, (including sole proprietorships and Individuals carrying on business in a partnership);

"Individual" means the client’s owner(s) or shareholders, co-signors, and/or any guarantor associated with a client.

"Member" means a person who volunteers on a GCFDC committee, but who is not a current or active board member, or chair of the committee.

"Application" means the application form or related forms completed by the Individual(s) to request financing for the client through the Investment Fund of GCFDC.

"Data base" means the list of names, addresses and telephone numbers of clients and Individuals held by GCFDC in the forms of, but not limited to, computer files, paper files, and files on computer hard-drives.

"File" means the information collected in the course of processing an application, as well as information collected/updated to maintain /service the account.

"Express consent" means the Individual signs the application, or other forms containing personal information, authorizing GCFDC to collect, use, and disclose the Individual's personal information for the purposes set out in the application and/or forms.

"Implied Consent" means the organization may assume that the Individual consents to the information being used, retained and disclosed for the original purposes, unless notified by the Individual.

"Third Party" means a person or company that provides services to GCFDC in support of the programs, benefits, and other services offered by GCFDC, such as other lenders, credit bureaus, persons with whom the Individual or client does business, but does not include any Government office or department to whom GCFDC reports in the delivery of such programs, benefits or services.


2.0  Purposes of Collecting Personal Information

Personal information is collected in order to assess the eligibility of the Individual completing an application for financial assistance, as well as to report to Industry Canada. The Individual is the main source of information but GCFDC will also ask to obtain information directly from a third source where the Individual does not have the required information.

Only that information which is required to make a determination of an Individual's eligibility will be collected. Although the Individual's Social Insurance Number may be requested in the application for confirming identification of the Individual to the credit reporting agency, provision of this personal information is optional. The Individual may provide alternative forms of identification, such as date of birth and driver's license number.


3.0  Consent

An Individual’s express, written consent will be obtained before or at the time of collecting personal information. The purposes for the collection, use or disclosure of the personal information will be provided to the Individual at the time of seeking his or her consent. Once consent is obtained from the Individual to use his or her information for those purposes, GCFDC has the Individual's implied consent to collect or receive any supplementary information that is necessary to fulfil the same purposes. Express consent will also be obtained if, or when, a new use is identified.

By signing the application and/or other forms, implied consent is granted by the Individual to obtain and/or to verify information from third parties such as banks, credit bureaus, other lenders, and insurance companies in the process of assessing the eligibility of an Individual or client. Implied consent is also granted by the Individual to permit GCFDC to report or otherwise disclose information to Industry Canada that is the government department that oversees GCFDC's activities.

An Individual can choose not to provide some or all of the personal information at any time, but if GCFDC is unable to collect sufficient information to validate the request for financing, the Individual's Application for such financing may be turned down.

A client or an Individual can withdraw consent to GCFDC’s use of personal information at any time prior to the application being approved, by making such request in writing. Once a loan has been approved, an Individual cannot withdraw consent authorizing GCFDC to use and disclose the personal information for the purposes set out in this Privacy Policy. Express consent will be obtained from the Individual prior to disclosing the Individual's personal information to other lenders, credit insurers and credit bureaus.

This Privacy Policy does not cover statistical data from which the identity of Individuals cannot be determined. GCFDC retains the right to use and disclose statistical data as it determines appropriate.


4.0  Limiting Collection

Personal information collected will be limited to the purposes set out in this Privacy Policy, GCFDC applications, and/or other forms.


5.0  Limiting Use, Disclosure and Retention

5.1 Use of Personal Information

Personal information will be used for only those purposes to which the Individual has consented with the following exceptions, as permitted under PIPEDA:

GCFDC will use personal information without the Individual's consent, where:

  • the organization has reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law and the information is used for that investigation;
     
  • an emergency exists that threatens an Individual’s life, health or security;
     
  • the information is for statistical study or research;
     
  • the information is publicly available;
     
  • the use is clearly in the Individual’s interest, and consent is not available in a timely way;
     
  • knowledge and consent would compromise the availability or accuracy of the information, and
     
  • collection is required to investigate a breach of an agreement.

5.2 Disclosure and Transfer of Personal Information

Personal information will be disclosed to only those GCFDC employees, members of GCFDC committees, and the Board of Directors that need to know the information for the purposes of their work or making an assessment as to the Individual's eligibility to the loan program.

Personal information will be disclosed to third parties with the Individual's knowledge and consent.

PIPEDA permits GCFDC to disclose personal information to third parties, without an Individual's knowledge and consent, to:

  • a lawyer representing GCFDC;
     
  • collect a debt owed to GCFDC by the Individual or client;
     
  • comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction;
     
  • a law enforcement agency in the process of a civil or criminal investigation;
     
  • a government agency or department requesting the information; or,
     
  • as required by law.

PIPEDA permits GCFDC to transfer personal information to a third party, without the Individual's knowledge or consent, if the transfer is simply for processing purposes and the third party only uses the information for the purposes for which it was transferred. GCFDC will ensure, by contractual or other means, that the third party protects the information and uses it only for the purposes for which it was transferred.

5.3 Retention of Personal Information

Personal information will be retained in client files as long as the file is active and for such periods of time as may be prescribed by applicable laws and regulations.

A file will be deemed inactive if the Investment Committee rejects an application, when a loan is repaid in full and securities are discharged, or when a guarantee is terminated. Information contained in an inactive file will be retained for a period of seven (7) years, except in the case where an application is rejected. Where an application has been rejected, the file and all personal information contained in the file will be retained for a period of two (2) years.


6.0  Accuracy

GCFDC endeavours to ensure that any personal information provided by the Individual in his or her active file(s) is accurate, current and complete as is necessary to fulfill the purposes for which the information has been collected, used, retained and disclosed. Individuals are requested to notify GCFDC of any change in personal or business information.

Information contained in inactive files is not updated.


7.0  Safeguards

GCFDC will use physical, organizational, and technological measures to safeguard personal information to only those GCFDC employees, volunteers, or third parties who need to know this information for the purposes set out in this Privacy Policy.

Organizational Safeguards: Access to Personal information will be limited to the Loans Officer, the Administration Officer, and/or the Executive Director who have to make a determination as to the Individual's eligibility for a business loan. Personal information provided to members of GCFDC committee(s) will be limited to only that information required to carry out the mandate of that committee. Members of the GCFDC committee(s) and/or Board of Directors are not permitted to copy or retain any personal information on Individuals or clients and must return for destruction all such information given to them to review once the purpose for being provided with this information has been fulfilled.

Employees and members of GCFDC committee(s) and/or Board of Directors are required to sign a confidentiality agreement binding them to maintaining the confidentiality of all personal information to which they have access.

Physical Safeguards: Active files are stored in locked filing cabinets when not in use. Access to work areas where active files may be in use is restricted to GCFDC employees only and authorized third parties.

All inactive files or personal information no longer required are shredded prior to disposal to prevent inadvertent disclosure to unauthorized persons.

Technological Safeguards: Personal information contained in GCFDC computers and electronic data bases are password protected in accordance with GCFDC's Information Security Policy. Access to any of the GCFDC's computers also is password protected. GCFDC's Internet router or server has firewall protection sufficient to protect personal and confidential business information against virus attacks and "sniffer" software arising from Internet activity. Personal information is not transferred to volunteer committee members, the Board of Directors, or third parties by e-mail or other electronic form.


8.0  Openness

GCFDC will endeavour to make its privacy policies and procedures known to the Individual via this Privacy Policy as well as the GCFDC Privacy Statement. This document will also be available on GCFDC’s website: http://www.grenvillecfdc.com/.


9.0  Individual Access

An Individual who wishes to review or verify what personal information is held by GCFDC, or to whom the information has been disclosed (as permitted by the Act) may make the request for access, in writing, to the Chief Privacy Officer. Upon verification of the Individual's identity, the Chief Privacy Officer will respond within 60 days.

If the Individual finds that the information held by GCFDC is inaccurate or incomplete, upon the Individual providing documentary evidence to verify the correct information, GCFDC will make the required changes to the Individual's active file(s) promptly.


10.0 Complaints / Recourse

If an Individual has a concern about GCFDC's personal information handling practises, a complaint, in writing, may be directed to the Chief Privacy Officer.

Upon verification of the Individual's identity, GCFDC's Chief Privacy Officer will act promptly to investigate the complaint and provide a written report of the investigation's findings to the Individual.

Where GCFDC's Chief Privacy Officer makes a determination that the Individual's complaint is well founded, the Chief Privacy Officer will take the necessary steps to correct the offending information handling practise and/or revise GCFDC's privacy policies and procedures.

Where GCFDC's Chief Privacy Officer determines that the Individual's complaint is not well founded, the Individual will be notified in writing.

If the Individual is dissatisfied with the finding and corresponding action taken by GCFDC's Chief Privacy Officer, the Individual may bring a complaint to the Federal Privacy Commissioner at the address below:

The Privacy Commissioner of Canada
112 Kent Street, Ottawa,
Ontario K1A 1H3
Tel 1-800-282-1376
Email: www.privcom.gc.ca 


11.0 Questions / Access Request / Complaint

Any questions regarding this or any other privacy policy of GCFDC may be directed to the Chief Privacy Officer. Requests for access to information, or to make a complaint, are to be made in writing and sent to the Chief Privacy Officer at the address below:

Chief Privacy Officer
Grenville Community Futures Development Corporation
197 Water Street, Suite 405, Box 309
Prescott, ON
K0E 1T0

Tel: 613.925.4275
Toll Free: 877.925.4275
Fax: 613.925.3758
Email:  


12.0 Amendment to GCFDC's Privacy Policies

This GCFDC Privacy Policy is in effect as of August 2004 and is retroactive to January 1, 2004. This policy is subject to amendment in response to developments in the privacy legislation. The Chief Privacy Officer will review and revise the Privacy Policy from time to time as required by changes in privacy law. Notification of any changes in the Privacy Policy will be posted on GCFDC's website, as well as in GCFDC's Privacy Statement. Any changes in the Privacy Policy will apply to Personal information collected from the date of the posting of the revised Privacy Policy on GCFDC's website: http://www.grenvillecfdc.com/


13.0 Employment Ontario Privacy Policy

The Ontario Self-Employment Benefit Program (OSEB) is funded by the Ministry of Training, Colleges and Universities (Ministry), in part with funds provided by Canada under Part II of the Employment Insurance Act. Under the Labour Market Development Agreement between Canada and Ontario (LMDA), the Ministry is required to collect personal information to provide reports to Canada to allow it to monitor and assess the Employment Insurance Program as required under the Employment Insurance Act. 

For more information  about the collection and use of personal information to administer and finance OSEB, contact the Manager, Employment Ontario Hotline, in writing at the Ministry of Training, Colleges and Universities, 33 Bloor Street East, 2nd Floor, Toronto, Ontario, M4W 3H1, or by phone at 1-800-387-5656. 

Customer Comment Policy

Customer Comment Policy

Introduction

The Grenville Community Futures Development Corporation (GCFDC) works to provide the highest quality service to Grenville County. Our Customer Comment Policy can help if you wish to comment on the quality of GCFDC service or the conduct of our staff or Board.  It also provides the opportunity to provide comment on GCFDC’s operational policies and procedures. GCFDC is committed to treating everyone involved in this process in a fair and respectful manner.

Things to think about when submitting comments

  • Is the comment about GCFDC’s quality of service, denial of service, or conduct of its staff or Board?
  • Is the comment about GCFDC’s policies and procedures or the failure of GCFDC to apply its operational policies or procedures?
  • Was the matter raised directly with the involved staff and/or the staff’s supervisor?
  • Did you try to resolve the matter informally with the staff or the supervisor?
  • Any information you give us will be kept confidential except where it involves interactions with the involved staff.

How to make a comment

Comments about GCFDC Staff

  1. Comments about GCFDC staff should be directly raised with the involved staff member. The involved staff member and if required, their supervisor, will make every attempt to resolve the issue informally.
  2. If a matter is not resolved you should:

    Fill out the comment form (Appendix A) and send it to the Executive Director of GCFDC. Describe what happened, where and when it occurred and the names of any witnesses. Please suggest how you would like the matter to be settled.

    If you need help writing your comments, contact the Executive Director at 613-925-4275 ext. 21.

  3. The Executive Director will send you an acknowledgement letter within 30 days of receiving your comment. The letter will acknowledge receipt of the comment and may ask for more information.
  4. The Executive Director or her representative will tell the involved staff person about the comment and share all relevant documents, including the comment, with the staff person.
  5. The Executive Director or her representative will investigate the comment and attempt to resolve it within 60 days from the date of the acknowledgement letter.
  6. The Executive Director or her representative may request the staff person or the supervisor to provide a written response to the comment.
  7. The Executive Director or her representative will send you a written decision, including the reasons, within 60 business days of the acknowledgement letter. If the matter involves a staff member, a copy of the decision will be given to the staff member.

Comments about a GCFDC Service, Policy or Operational Procedure

  1. If the comment is about a GCFDC service, operational policy or procedure or the failure to apply an operational policy or procedure you should:

    Fill out a comment form (Appendix A) and send it to the Executive Director of GCFDC. Describe the issue. Please suggest how you would like the comment to be settled.

    If you need help writing your comments, call the Executive Director at 613-925-4275 ext. 21.

  2. The Executive Director will send you an acknowledgement letter within 30 days of receiving the comments. The letter may ask for more information.
  3. The Executive Director or her representative will investigate the comment and attempt to resolve it within 60 days from the date of the acknowledgement letter.
  4. The Executive Director or her representative will send you a written decision, including reasons within 60 days from the date of the acknowledgement letter.
  5. If you are satisfied with the Executive Director’s decision, the comment will be closed. If you are not satisfied with the decision, you can ask, in writing, that the Chairman of the GCFDC Board of Directors review the decision.
  6. The Chairman of the GCFDC Board of Directors will review the matter and may:

    Discuss the comment with the Executive Director or her representative and try to resolve the matter;

    Offer you an opportunity to provide more information or comments or take part in a conference call; and/or

    Make a decision based upon the information received.

  7. The Chairman of the GCFDC Board of Directors will send you his/her written decision.

Comments about the Executive Director

Comments about the Executive Director should be sent to the Chairman of the GCFDC Board of Directors.

Comments about the Chairman of the GCFDC Board of Directors

Comments about the Chairman of the GCFDC Board of Directors should be sent to the Vice Chairman of the GCFDC Board of Directors.

Decision to not deal with a comment

The Executive Director or the Chairman of the GCFDC Board of Directors will not deal with a comment if:

  •   You do not identify yourself or give us your address and telephone number;
  •   You do not reply if we ask for more information; or
  •   The matter has already been raised and addressed by GCFDC.

GCFDC Executive Director
Grenville Community Futures Development Corporation
197 Water Street, Suite 405
PO Box 309
Prescott, ON   K0E 1T0

 

Chairman / or Vice Chairman of the GCFDC Board of Directors
Grenville Community Futures Development Corporation
197 Water Street, Suite 405
PO Box 309
Prescott, ON K0E 1T0

 

Appendix A

Public comment form for GCFDC

  • To file a comment about GCFDC quality of service, denial of service, policies, procedures or the conduct of its staff or Board of Directors please complete this Comment Form.
  • The comment will only be accepted if this form is signed and dated by the person making the comment. If the comment is an organization, a signing officer representing the organization must sign and date the Comment Form.

Your contact information:

Full Name:

Name of Organization (if applicable):

Address:

Home phone number:

Work phone number:

Fax number:

Email address:

Note: Your contact information will be kept confidential. Please tell us if you have any concerns receiving calls or emails from us.

Information about your comment:

1. Is the comment about a staff member or member of the Board of Directors? If so, please provide their name.

2. Is the comment about a:

  • Service of GCFDC?
  • Policy of GCFDC?
  • Procedure of GCFDC?

3. Please comment in your own words and describe what happened, where and when it occurred and the names of any witnesses.

4. How would you like to resolve this matter?

5. List and attach copies of any supporting documents you think we should know about. Do not send originals.

Privacy:

I understand that:

The comment that I have submitted and all the documents I have provided will be shared with GCFDC Executive Director and/or Chairman and/or Vice Chairman of the GCFDC Board of Directors to allow him/her/them to respond to the comment and that  GCFDC may disclose relevant documents to the parties in its possession.

I agree that documents that I obtain from GCFDC during the course of the investigation of this comment will be used only for the purpose of this comment and that any other use is prohibited.

 

 

________________________

Signature

 

 

________________________

Date