This policy applies to all Project Recover Inc. stakeholders including volunteers, committee members and other stakeholders as applicable.
3.2. Identifying Purposes
Personal information that Project Recover Inc. collects from clients includes:
• the client’s name
• the client’s address
• other contact information, such as telephone numbers, email address
• information about a client’s transactions such as account numbers, account balances, payment history;
• credit and reference information, such as date of birth, employment information, driver’s license, previous addresses, and general financial information;
• law enforcement and court reference numbers and court record.
• credit reports from Equifax and Trans Union or other reporting agencies
3.2.1. Limiting Collection
Project Recover Inc. limits the amount and type of personal information it collects to that which is necessary for the purposes of advocating on behalf of the client and as permitted by law.
3.2.2 Limiting Use, Disclosure and Retention
Project Recover Inc. will only use the personal information for the purpose for which it was collected as identified in principle #2, unless consent is given by the individual to use or disclose it for another purpose or as is required by law.
Only those individuals directly involved in the advocacy of a specific client will have access to the personal information of that client.
Other volunteers, committee members, media and the general public will not have access to personal information including but not limited to the client’s name.
Without the consent of a client no address or phone number is to be provided to a creditor, even where Project Recover is interacting with on behalf of a client.
Project Recover Inc. will develop explicit retention periods for closed accounts, after which the personal information will be destroyed or made anonymous. Under certain exceptional circumstances, Project Recover Inc. may have a legal duty or right to disclose personal information without the individual's knowledge or consent. Project Recover Inc. will only release such information after consultation with and only at the direction of its corporate counsel.
Project Recover Inc. shall take all reasonable steps to ensure that all personal
information will be kept accurate, complete and up to date.
Individuals may challenge the accuracy and completeness of personal information
about them and have it amended, as appropriate.
In executing its responsibilities with respect to the confidentiality of personal
information, Project Recover Inc. will employ a number of safeguards, appropriate to the sensitivity of the information, to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Such safeguards will include physical measures, organizational measures and technological measures, for example locked filing cabinets, restricted access to offices, security clearances, limiting access on a “need to know” basis and the use of passwords and encryption. Procedures for implementing these measures will be communicated to all employees and third parties to ensure compliance with this principle.
Project Recover Inc. will make its policies and practices relating to the protection of personal information available to its clients. Project Recover Inc. will keep its clients informed of these policies and practices and clients shall be provided access to all related policies and procedures via Project Recover Inc.'s web page. The information will be available in a format that is easy to understand.
4.0. Individual Access
Any client of Project Recover Inc. can have access to the personal information about them that Project Recover Inc. has in its possession or control. Any client may request that their personal information be amended for purposes of accuracy and completeness.
Customers can make their requests by telephone (416-302-2368), via email
(email@example.com) or in writing (231 Fort York Boulevard Unit 2102 Toronto, Ontario M5V 1b2, Attention: Executive Director).
Response to an individual’s request will be made in a timely and efficient manner.
5.0 Challenging Compliance