Table of Contents
- WHAT IS PERSONAL INFORMATION?
- ORGANIZATIONS TO WHICH THE POLICY APPLIES
- WHY JROSS RECRUITERS COLLECTS AND USES PERSONAL INFORMATION
- LIMITS ON COLLECTION, USE, AND DISCLOSURE
- HOW JROSS RECRUITERS DISCLOSES PERSONAL INFORMATION REQUIRED BY LAW
- HOW JROSS RECRUITERS OBTAINS CONSENT TO COLLECT, USE, AND DISCLOSE PERSONAL INFORMATION
- HOW LONG JRoss Recruiters RETAINS PERSONAL INFORMATION
- HOW JROSS RECRUITERS KEEPS PERSONAL INFORMATION SECURE
- HOW JROSS RECRUITERS ENSURES THAT PERSONAL INFORMATION IS ACCURATE
- HOW JROSS RECRUITERS PROVIDES INDIVIDUALS WITH ACCESS TO THEIR PERSONAL INFORMATION UNDER JROSS RECRUITERS CONTROL OR CUSTODY
- HOW INDIVIDUALS CAN COMPLAIN, ASK FOR ACCESS OR ASK QUESTIONS
As providing our services requires the collection, use and disclosure of some personal information about our candidates, protecting their personal information is one of our highest priorities.
Personal Information means recorded information about an identifiable individual. Examples of personal information include: name, address, telephone number, race, etc. Personal information also includes an individual’s personal history regarding health, finances, education, and current and historical employment.
Candidate personal information is information that is collected, used or disclosed solely for the purposes reasonably required to establish an employment relationship between a candidate and a client organization. This information is usually provided by the candidate in the form of a resume and may include information such as name, home address, education history and employment history. This does not include contact information.
Employee personal information is information that is collected, used or disclosed solely for the purposes reasonably required to establish, maintain, manage or terminate an employment relationship between an employee and an organization. This may include information such as name, home address, education history and employment history. This does not include contact information (see below).
Contractor personal information is information that is collected, used or disclosed solely for the purposes reasonably required to establish, maintain, manage or terminate a contractor relationship between a contractor and an organization. This may include information such as name, home address, education history and employment history. This does not include contact information or work product information (see below).
Client personal information is information that is collected, used or disclosed solely for the purposes reasonably required to establish, maintain, manage or terminate a client relationship between a client and an organization. This may include information such as name and employment history. This does not include contact information.
Contact information means information that allows an individual to be contacted at work. It includes the name, position name or title, business telephone number, business address, business e-mail and business fax number for the individual.
Work product information is information that is prepared or collected by an employee as part of that individual’s work responsibilities, but does not include information about an individual who did not prepare or collect the information.
The Act also extends to include anyone else’s opinion about the individual. This definition of personal information is not exhaustive.
This policy extends to JRoss Recruiters Retail Recruiters Inc., its corporate affiliates and subsidiaries, and its contractors.
As a recruiting firm, JRoss Recruiters collects personal information about candidates for the purpose of determining their degree of “fit” with client requirements. Personal information and resumes are kept in a database and in other paper and electronic forms to be used solely for the purposes of recruitment. Examples include name, home/work address, telephone number(s) and email address(es), employment information (current, historical and future goals), references, etc. or other information that is necessary to fulfill the following purposes, among others:
- To verify past employment by collecting reference and past work history information.
- To verify education by collecting educational information and contacting the institutions
- To identify candidate preferences by collecting information regarding candidate interests and aspirations
- To understand the financial needs of our candidates by collecting past salary information as well as salary expectations.
This does not include contact information.
4.2 Employees & Contractors
JRoss Recruiters collects personal information for the purpose of establishing, maintaining, managing and terminating employee and contractor relationships. Personal information is kept in a database and in other paper and electronic forms to be used solely for the purposes of employment and contracting. Examples include name, home/work address, telephone number(s) and email address(es), employment information (current, historical and future goals), Social Insurance Number, GST and tax information, references, etc. or other information that is necessary to fulfill the following purposes, among others :
- To verify suitability for tasks, by collecting performance, work history and education information
- To comply with statutory requirements by collecting Social Insurance Numbers, GST numbers, and tax statuses
This does not include contact information.
JRoss Recruiters collects personal information for the purpose of establishing, maintaining, managing or terminating client relationships. Personal information is kept in a database and in other paper and electronic forms to be used solely for the purposes of business development and recruitment. This may include information such as name, current and historical employment history, preferences, or other information that is necessary to fulfill the following purposes, among others:
- To establish and build client relationships
- To promote appropriate JRoss Recruiters services
- To manage the delivery of services
This does not include contact information.
4.4 Anonymous Web Browsing
Visitors to the JRoss Recruiters web site do not have to reveal who they are, or any other information about themselves. In this case, we may collect the IP address used to access the web site, the type and version of web browser and operating system used, the number, duration and frequency of visits to the web site, the starting and next web sites, etc. This anonymous information cannot be traced to a specific individual and is used for the following purposes, among others:
- To monitor web site performance for systems administration
- To make the web site more effective, easier and more convenient to use
- To improve JRoss Recruiters’ services
- To track information
- Candidate names, contact information and/or resumes will not be provided to clients without the prior consent of the candidate, although work history and qualifications may be described to the client in general terms, so as to determine the level of “fit” to client requirements at a high level
- Information regarding visits to the JRoss Recruiters web site of a particular IP address will not be disclosed except as required by law
6.2 Employees and Contractors
Personal information will be disclosed to government bodies based on statutory requirements.
6.4 Required by Law
JRoss Recruiters will disclose personal information where authorized by PIPA or required by law (ex. - a legal requirement to disclose include a court order, subpoena or search warrant, etc.), but will make all reasonable efforts to ensure the individuals affected are notified of such disclosure.
JRoss Recruiters will get individuals’ consent to collect, use or disclose their personal information, except where legally authorized or required by law to do so without consent.
JRoss Recruiters may collect, use or disclose personal information without an individual’s knowledge or consent – as allowed under PIPA sections 12, 15 and 18 - in the cases of verification of employment history, references, and credit and other background checks.
Consent may be given orally, in writing or electronically, and consent may be implied or express depending on the nature and sensitivity of the personal information. This specifically includes submission of a resume and/or covering letter or other inquiry to JRoss Recruiters regarding employment opportunities, which constitutes implied consent.
Individuals are also considered to have given implied consent when JRoss Recruiters’ purpose for collecting, using or disclosing personal information would be considered obvious and the individual voluntarily provides personal information for that obvious purpose.
JRoss Recruiters will tell individuals the purpose for collecting personal information and give them a chance to refuse to provide their personal information or a chance to withdraw their consent later.
Individuals may withdraw consent for their personal information to be used in certain ways at any time by giving JRoss Recruiters reasonable notice, but not where doing so would frustrate performance of a legal obligation (such as a contract between the individual and JRoss Recruiters). When individuals tell JRoss Recruiters they are withdrawing consent, PIPA requires us to inform them of the likely consequences of withdrawing consent, which will typically include reducing or eliminating our ability to provide them with new employment opportunities.
In the case of employee personal information, PIPA allows JRoss Recruiters to collect, use or disclose employee personal information without consent if it is reasonable for the purposes of establishing, managing or terminating an employment relationship between JRoss Recruiters and the individual. In this event, JRoss Recruiters will still notify employees of the collection, use or disclosure.
JRoss Recruiters will keep personal information used to make a decision that directly affects individuals for at least one year after that decision is made, as required by PIPA.
Subject to the above one-year retention requirement, JRoss Recruiters will only retain personal information for as long as necessary to fulfill the identified purposes or as long as required for a legal or business purpose.
JRoss Recruiters has appropriate security arrangements in place to prevent against risks such as unauthorized access, collection, use, disclosure, copying, modification or disposal of personal information. These include, but are not limited to:
- Physically secured premises
- Individual ID’s and password protected electronic storage
- Use of Adobe Acrobat and other document protection systems to guard against alteration of personal information
- Non-disclosure Agreements signed by all JRoss Recruiters employees and contractors
In addition, JRoss Recruiters is committed to continually reviewing and updating our security policies and controls as technology changes to ensure ongoing personal information security.
9.2 Client and Other Organization Security
9.3 Web site and the Internet
The JRoss Recruiters web site contains links to other sites, and JRoss Recruiters is not responsible for the privacy practices or the content of these web sites.
Emails sent over the Internet are routinely used for communication between candidates, clients and JRoss Recruiters representatives, as they are by most organizations and individuals around the world. However, the Internet is an inherently insecure communications medium, and the use of it can lead to inadvertent discovery or disclosure of such communications. JRoss Recruiters cannot take any responsibility for any such discovery or disclosure or the consequences.
Any individual submitting personal information to JRoss Recruiters has the sole responsibility for ensuring that information is accurate when submitted.
JRoss Recruiters will make reasonable efforts to ensure that the personal information we collect, use or disclose is accurate and complete, and individuals may email us at firstname.lastname@example.org to request we correct any errors or omissions in their personal information that is under JRoss Recruiters’ control. That request must be timely and have enough detail to enable us to identify the personal information and the correction being requested. If we are satisfied that an individual’s request for correction is reasonable, we will correct the personal information as soon as reasonably possible.
JRoss Recruiters will, as soon as reasonably possible, also send an individual’s corrected personal information to each organization it was disclosed to, where the correction would materially affect that individual. If JRoss Recruiters does not correct an individual’s personal information, we will note the requested correction on copies of the personal information under our custody or control.
Part 11: How JRoss Recruiters provides individuals with access to their personal information under JRoss Recruiters control or custody
Individuals have the right to access their personal information under JRoss Recruiters’ custody or control. The request for access must be made in writing, and JRoss Recruiters may require individuals to prove their identity before giving them access to their personal information.
JRoss Recruiters will give individuals their personal information under our control, information about the ways in which their information is or has been used, and the names of the individuals and organizations to which their personal information has been disclosed.
As per PIPA guidelines, a “minimal” fee will be charged for providing an individual with access to his or her personal information, and a written fee estimate will be provided in advance of such access. At JRoss Recruiters’ discretion, payment of a deposit or the whole fee may be required before releasing the requested information.
Once the request and appropriate payment has been received, JRoss Recruiters will provide requested personal information within 30 business days after it is requested, or we will give written notice if we need more time to respond. However, in some cases, JRoss Recruiters may not give an individual access to certain personal information where authorized or required by PIPA to refuse access.
If JRoss Recruiters refuses an access request, we will tell the applicant in writing, stating the reasons for our refusal and outlining further steps that are available to the applicant (including an internal review by JRoss Recruiters and the right to ask the Office of the Information and Privacy Commissioner for British Columbia to review the decision).
If individuals are not satisfied with JRoss Recruiters’ response, they can complain to the Office of the Information and Privacy Commissioner for British Columbia.