NEW PHASE TRAINING INC.
PERSONAL INFORMATION PROTECTION POLICY
New Phase Training Inc. (“New Phase Training”) is committed to the protection and safe keeping of the personal information entrusted to us by our users. We manage your personal information in accordance with Alberta’s Personal Information Protection Act and other applicable laws. This policy applies to both New Phase Training as well as any person or entity providing services on our behalf and at our direction. A copy of this policy will be provided to any user upon request.
The definition of personal information
Personal information means information about an identifiable individual. This includes an individual’s name, home address and phone number, email address, age, gender, marital or family status, an identifying number, financial information, educational history, photos and pictures, and any other similar information.
What personal information do we collect?
We collect only the personal information that we require for the purposes of providing services to our users, including personal information needed to:
- Enable users to have access to our website, courses, and to any resources provided by New Phase Training;
- Enable us to understand a user’s business, needs and goals, where applicable;
- Enable us to ensure we are providing students with all the relevant material they require for their educational training;
- Enable us to set up a student’s internet;
- Enable us to ship manuals or laptops to students;
- Allow us to communicate with students;
- Enable us to take payment from a user, where applicable;
- Track the use of trends present on the website and ensure its proper functionality.
The information that may be collected directly from the user by New Phase Training will be information such as the individual’s name and email address, login information and password, shipping address, credit card number, billing address, phone number, case number, and business name where applicable. While not required, individuals also have the option to post additional personal information on New Phase Training’s social media channels.
All information collected will be kept fully confidential. We will not share your private information with any third parties unless we are required as a result of our express obligations to do so (in which case it will be provided with strict obligations of confidentiality under the terms of a Non-Disclosure Agreement), or unless disclosure is necessary to fulfill the express purpose for which the information was disclosed (such as providing a user’s address to a third party shipping company). Your information will not be sold to third parties at any time or for any reason.
We attempt to inform our users, before or at the time of collecting personal information, of the purposes for which we are collecting the information. When such notification is not provided it is because the user has provided information for an obvious purpose – such as providing their name to set-up their account – or for a purpose as listed and agreed to in this policy.
We will make a reasonable effort to ensure that any personal information collected, used or disclosed is accurate and complete to the extent that is reasonable for our organization’s purpose.
We will only use personal information for purposes that are reasonable, and we will not disclose your personal information beyond what is necessary to provide the item or service that you have requested.
How do we collect the personal information about you?
We collect your personal information in the following ways:
- Where you provide the personal information directly to us, for example by way of email correspondence, phone conversation, or by submitting a form on our website;
- Where we track the use of trends on our website or email communications sent to you by New Phase Training;
- Where we receive information from third party companies regarding the students who will be attending our courses; and
- By way of information received about you from other sources or third parties, such as public databases.
New Phase Training may use cloud-computing services for data processing, storage and backup of your personal information, and is accountable for protecting your personal information that is within New Phase Training’s immediate control. We do not currently utilize cookies. New Phase Training will do its best to ensure your personal information is handled in accordance with this policy by working with providers who handle personal information consistent with privacy obligations under the relevant Alberta privacy legislations. However, since New Phase Training may outsource its cloud computing solutions and it has no control over the operations of the cloud provider, New Phase Training cannot take responsibility for how the cloud provider handles your personal information if it is not done so in accordance with this policy once it is moved to the provider. New Phase Training will not be liable for any direct, indirect, special, incidental or consequential damages arising from the improper handling of your personal information.
We ask for consent to collect, use or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law, or by our specific obligations to release this information. We may assume your consent in cases where you volunteer information for an obvious purpose.
We assume your consent to continue to use and, where applicable, disclose personal information that we have already collected, for the purpose for which the information was collected. We also assume your consent to provide personal information back to the third party with whom you are working with to obtain services.
There may be situations where your express consent will be required. In those situations, we will typically request that you provide your consent orally or in writing through the signing of a consent form.
User consent may be withdrawn at any time; however, such consent may be necessary for us to satisfy our obligations to you, or our obligations to third parties who work with you. In those situations, we will inform you if the withholding of such consent will prevent us from being able to provide you with certain products and services. We will at all times respect your decision.
We may collect, use or disclose personal information without consent only as authorized by law.
How do we use and disclose personal information?
We use and disclose personal information only for the purposes for which the information was collected, except as authorized by law.
For example, the use of your personal information is required if:
- It is necessary to perform our contract with you, such as providing your shipping information to a third party who will deliver a package to you;
- It is needed to comply with our legal obligations;
- To better understand our business and develop our services to suit our clients’ needs;
- To comply with our legal obligations to third party entities, or our obligations directly or indirectly under the Freedom of Information and Protection of Privacy Act (FOIP);
- To comply with any required provincial or federal COVID-19 regulations.
If we wish to use or disclose your personal information for any new purpose, we will ask for your consent, unless otherwise not required by law.
How do we safeguard personal information?
We make every reasonable effort to ensure that personal information is accurate and complete. We rely on individuals to notify us if there is a change to their personal information that may affect their relationship with our organization. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible. In some cases, we may ask for a written request for correction.
We protect personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information.
We use appropriate security measures when destroying personal information, including shredding email records and permanently deleting electronic records.
However, if at any time, through no fault of New Phase Training, our website is hacked in any way and personal information is released, or our offices are broken into and personal information is releasd, so long as New Phase Training has taken reasonable and appropriate methods to safeguard its personal information, New Phase Training shall not be held liable for these results.
We retain personal information only as long as is reasonable to fulfill the purposes for which the information was collected, or for legal or business purposes.
Your rights in relation to your personal information internationally
In accordance with the European Union data protection laws that currently apply globally, you have the following additional rights, which include but are not limited to the following:
- to request we provide you with more details on how we use your personal information;
- to request we provide you access to the personal information we hold about you;
- to request your personal information be amended or updated where it is inaccurate or incomplete;
- to require us to delete any of your personal information;
- to withdraw your consent (opt-out) of us processing your personal information relating to a particular situation where you previously provided consent, or for direct marketing purposes;
- to restrict how we use your personal information;
- to request a copy of your personal information and request it be transmitted for use in another party’s service; and
- to not be subjected to automated decision-making where the decision may have legal effect on you or a similarly significant effect.
Access to records containing personal information
Clients of New Phase Training have a right to access their own personal information in a record that is in the custody or under the control of New Phase Training, subject to some exceptions. For example, organizations are required under the Personal Information Protection Act to refuse to provide access to information that would reveal personal information about another individual.
If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that specific private information and provide you with the remainder of the record.
You may make a request for access to your personal information by writing to New Phase Training at 11710 Kingsway NW Suite 101, Edmonton, AB T5G 0X5. You must provide sufficient information in your request to allow us to identify the information you are seeking.
You may also request information about our use of your personal information and any disclosure of that information to persons outside our organization. In addition, you may request a correction of an error or omission in your personal information.
Questions and complaints
If you have a question or concern about any collection, use or disclosure of personal information by New Phase Training, or about a request for access to your own personal information, please contact Thabani Conrad at [email protected]
If you are not satisfied with the response you receive, you may contact the Information and Privacy Commissioner of Alberta:
Office of the Information and Privacy Commissioner of Alberta
Suite 2460, 801 – 6 Avenue, SW
Calgary, Alberta T2P 3W2
Phone: 403-297-2728 Toll Free: 1-888-878-4044
The Privacy Procedures of New Phase Training Inc.
In order to ensure the safekeeping of all private information that we receive, we have implemented a number of specific procedures regarding the handling of this information.
These procedures include, but are not limited to, the following:
- All of New Phase Training’s computers and laptops that hold private information are password protected and secure;
- All independent contractors who obtain private information and utilize their own laptops commit to ensure their personal laptops are password protected and secure;
- Yearly training is provided to all employees and independent contractors of New Phase Training to assist in ensuring compliance with all privacy regulations and policies;
- New Phase Training has Non-Disclosure Agreements in place with third parties to whom disclosure of private information is required;
- New Phase Training’s wireless internet is password protected;
- Virus software and firewalls are encouraged on New Phase Training computers; and
- All of our Human Resource documents are stored in a locked metal drawer.
We are constantly seeking to improve our processes and our handling of private information, and we strive to follow best practices when it comes to private information. These procedures listed above are subject to change at any time.
Last updated November 3rd, 2020