Transient (or per-session) Cookies
These only exist for the duration of your site visit and are deleted on exit. They recognise you as you move between pages, for example recording the items you add to an online shopping basket. These cookies also help maintain security.
Persistent (or permanent) Cookies
These stay on your machine until they expire or are deleted. Many are built with automatic deletion dates to help ensure your hard drive doesn’t get overloaded. These cookies often store and re-enter your login information, so you don’t need to remember login details.
We use both types of cookies. Additionally, cookies can be first- or third-party cookies. First-party cookies are owned and created by the website you’re viewing. Third-party cookies are owned and created by an independent company, usually a company providing a service to the owners of the website.
• Gather customer journey information on our public site only
• Temporarily store input information in our calculators, tools, illustrations and demonstrations
• Store details of your marketing, product preferences to improve our targeting and enhance your journey through our sites and partner sites
• Evaluate our sites’ advertising and promotional effectiveness (we own the anonymous data collected and don’t share it with anyone)
What Is Personal Information?
What Personal Information Do We Collect?
We collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes:
• contact and identification information, such as your name, address, telephone number and e-mail address;
• product and service related information concerning the products and services that we provide to, or receive from, you;
• credit and financial information such as your direct deposit and banking information; and
• business relationship information, including information related to your agreements, preferences, advisors and decision-makers, feed-back and information requested by or provided to you.
We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business. This information may include contract terms, financial information and other information for the purpose of market analysis and strategic planning.
eCompliance’s operations include activities related to providing health, safety and environment (HSE) programs; as such, eCompliance may also collect personal information from individuals participating in and / or impacted by those activities, including information related to obtaining permits and licenses, emergency planning and environmental stewardship.
As a general rule, eCompliance collects personal information directly from you. In most circumstances where the personal information that we collect about you is held by a third party, we will obtain your permission before we seek out this information from such sources (such permission may be given directly by you, or implied from your actions).
From time to time, we may utilize the services of third parties and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
Why Do We Collect Personal Information?
eCompliance collects personal information to enable us to manage, maintain, and develop our operations, including:
How Do We Use and Disclose Your Personal Information?
We may use or disclose your personal information:
• for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information.
We may use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
When Do We Disclose Your Personal Information?
We may share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including third parties that provide services to us or on our behalf.
For example, our third party service providers may provide certain information technology and data processing services to us from time to time so that we may operate our business, and as result, your personal information may be collected, used, processed, stored or disclosed in the United States of America.
Further, your personal information may be disclosed:
• as permitted or required by applicable law or regulatory requirements;
• to comply with valid legal processes such as search warrants, subpoenas or court orders;
• as part of eCompliance’s required reporting activities to its affiliates;
• to protect the rights and property of eCompliance;
• during emergency situations or where necessary to protect the safety of a person or group of persons;
• where the personal information is publicly available; and with your consent.
Your Consent is Important to Us
It is important to us that we collect, use or disclose your personal information where we have your consent to do so. Depending on the sensitivity of the personal information, your 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 reasonably be inferred from your action or inaction. For example, when you enter into an agreement with us, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to the performance of that agreement and for any other purposes identified to you at the relevant time.
We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
How is Your Personal Information Protected?
eCompliance will endeavor to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction. The security of your personal information is important to us, please advise our Privacy Officer immediately of any incident involving the loss of or unauthorized access to or disclosure of personal information that is in our custody or control.
Updating Your Personal Information
It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of our relationship, please keep us informed of such changes. In some circumstances we may not agree with your request to change your personal information and will instead append an alternative text to the record in question.
Access to Your Personal Information
You can ask to see your personal information. If you want to review, verify or correct your personal information, please contact our Privacy Officer. Please note that any such communication must be in writing. When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact our Privacy Officer.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.
Inquiries or Concerns?
eCompliance is committed to providing a respectful, accessible, and inclusive environment for all our employees and clients in the Province of Ontario. Our goal is to meet the standards outlined in the province’s Accessibility for Ontarians with Disabilities Act (AODA) and to break down barriers to services and employment opportunities provided by eCompliance.
The purpose of the Accessibility for Ontarians with Disabilities Act (AODA) is to remove barriers for people with disabilities and to work towards achieving a fully accessible Ontario by 2025. All organizations in Ontario with one or more employees must adhere to the following Accessibility
Standards as compliance dates come into effect:
• Integrated Accessibility Standards Regulation (IASR) (Ontario Regulation 191/11)
• Customer Service ○ Information and Communications
• Design of Public Spaces (Built Environment)
What is Considered a Disability Under the AODA and It’s Standards?
The AODA uses the same definition of “disability” as the Ontario Human Rights Code, which includes both visible and invisible disabilities. All disabilities – whether temporary, short-term, long-term, or permanent – are included in this definition. It is important to understand that the emphasis of the AODA is not on specific disabilities but is on removing barriers to accessibility of goods and services.
Some Examples Of Types Of Disabilities Covered By The Aoda Include:
• Speech or communication
• Mental health
• Developmental or intellectual
• Chronic diseases or conditions
The principles of the AODA assist eCompliance and its employees in taking reasonable efforts and making decisions to ensure that services are as accessible and inclusive as possible. The four guiding principles of the AODA focus on recognizing that all people with disabilities are entitled to:
• Independence – Independence means creating an environment in which people with disabilities are able to do things on their own, without unnecessary help or interference from others.
• Dignity – Treating people with dignity means not treating people with disabilities as an afterthought or forcing them to accept lesser quality or convenience, but instead enabling people with disabilities to maintain self-respect and the respect of others.
• Integration – Integration allows people with disabilities to benefit from the same interactions in the same place and in the same or similar ways as people without disabilities.
• Equal opportunity – Equal opportunity means ensuring that people with disabilities are afforded the same choices, benefits, and opportunities as people with disabilities.
This Accessibility Policy is intended to fulfill the policy requirements of the Integrated Accessibility Standards Regulation (IASR) (Ontario Regulation 191/11).
This policy applies to all employees and others who are working with eCompliance and involved in delivering goods and services.
Availability of AODA Accessibility Policy
All relevant documents required by the Customer Service Standard, including the Accessibility Policy, will be made available upon request. The Accessibility Policy is included as part of employee training.
eCompliance employees will provide and communicate reasonable measures so that clients with disabilities may use their own personal assistive devices (for example, hearing aids, wheelchairs, walkers, oxygen tanks) as required to access eCompliance facilities and services.
In addition, staff are provided with training regarding how to operate and provide support with any assistive devices provided by eCompliance.
Communication and Format Of Documents
eCompliance employees will communicate with people with disabilities in a manner that considers their disability.
Documents will be provided to people in accessible formats that consider their disability and information needs.
Notice of Disruption of Services
In the event of temporary disruptions to the accessibility of eCompliance facilities or services, all reasonable efforts will be made to provide advance notice. This will include communicating information about the reason for the disruption, its anticipated length of time, and a description of alternative facilities or services, if available.
In some circumstances, such as in a situation of unplanned or emergency temporary disruptions, advance notice might not be possible, but notice will be provided as soon as possible.
When disruptions occur, eCompliance staff will make every effort to provide notice by:
• posting Notice of Disruption of Services notices in conspicuous places including at the point of disruption, at the main entrance, at the nearest entrance to the service disruption, and/or on the eCompliance website; and by
• any other method that may be reasonable under the circumstances.
A procedure addressing Notice of Disruption of Services will include relevant information describing:
• under what circumstances notice will be provided about a temporary disruption,
• where notice will be posted,
• what steps will be taken when an unexpected disruption occurs,
• information that will be included in the notice of a temporary disruption, and
• any alternative facilities or services, if any, can be made available during the temporary disruption to continue to provide service to people with disabilities.
Feedback regarding accessibility to services and the manner in which eCompliance employees interact with people with disabilities is welcome and appreciated. Feedback and questions can be submitted to 1.800.686.1915 or by email to the Joint Health & Safety Committee at email@example.com.
Both the employees and management at eCompliance recognize the importance of understanding how to provide accessible customer service. All employees are required to receive training regarding how to provide accessible customer service.
eCompliance management will also ensure that the following persons receive AODA and accessibility training or confirm that they have received such training:
• contractors who act on behalf of the eCompliance; and
• individuals who participate in developing eCompliance policies.
Training will be provided to each eCompliance employee as soon as possible and reasonable based on assigned duties.
At minimum, training will cover the following:
• the purposes of the AODA and requirements of the customer service standard;
• how to interact and communicate with people with various types of disabilities;
• how to interact with people with disabilities who use assistive devices or require the assistance of a guide dog, other service animal, or a support person;
• how to use equipment or devices available at eCompliance premises that are provided to help people with disabilities access eCompliance facilities or services (for example, entrances, lifts, or scooters); and
• what to do if a person with a disability is having difficulty accessing eCompliance services.
Guide Dogs and Service Animal
eCompliance allows people with disabilities to bring a guide dog or service animal with them to eCompliance facilities open to the public or required for delivery of goods and services, unless otherwise prohibited by law.
Each individual who is accompanied by a guide dog or service animal is responsible for maintaining care and control of the animal at all times.
If a health or safety concern presents itself (for example, another client or staff member has a severe allergy to the guide dog or service animal), eCompliance employees will make all reasonable efforts to meet the needs of all individuals involved.
eCompliance permits people with disabilities who are accompanied by a support person to bring that person with them, at no fee, to access facilities and services open to the public or required for delivery of goods and services. eCompliance will communicate to the public and staff that, when requested, eCompliance will accommodate disabilities during recruitment and assessment processes and when people are hired. eCompliance will provide individualized workplace emergency response information to employees who have a disability. If using performance management, career development, and redeployment processes, eCompliance staff will take into account the accessibility needs of employees with disabilities.
Modifications to This or Other Policies
Any eCompliance policies that do not respect and promote the dignity and independence of people with disabilities will be modified or removed.