CRi’s general policy is to try to collect information needed for our surveys without collecting personal information that would allow for the identification of the respondent.
Because our analysis looks at trends and aggregate numbers we do not look at individual responses.
The policy below has been developed to deal with those rare instances.
At CRi, respecting privacy is an important part of our commitment to respondents and the general public.
When you participate in survey research conducted by our organization, you can be confident that any personal information that you share with us will stay with us.
Any time you participate as a respondent in one of our surveys, whether by mail or internet, you can be assured that your individual responses will be kept confidential and never linked to your personal identifying information without your express permission. Your personal identifying information will never be sold to anyone. You are free to choose whether or not to participate in a survey, free to choose not to answer any specific questions and free to discontinue participation at any time.
In compliance with The EU General Data Protection Regulation (GDPR), you may even submit a request through the survey platform for us to delete your response. Once the request comes through to CRi, your survey will be deleted without question. An e-mail notification is not sent to notify you of this being done, but our survey platform is working on making that a part of the process.
If you have any concerns about how your privacy is protected at CRi, please contact us by e-mail firstname.lastname@example.org or by mail at 337 Rothesay, Unit 198, Saint john, NB, E2J 2C3.
1. Scope and Application
(a) non-personally identifiable information;
(b) the name, title, business address and/or telephone number of an employee of an organization;
(c) other information about an individual that is publicly available and is specified by regulation pursuant to the Personal Information Protection and Electronic Documents Act (Canada).
collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.
consent: Voluntary agreement for the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing, but is always unequivocal and does not require any inference on the part of CRi. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.
disclosure: Making personal information available to a third party.
employee: An employee of or independent contractor to CRi.
personal information: Information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization, and does not include descriptive, factual information about an organization.
respondent: A member of the public who provides personal information to CRi in the course of a survey conducted by CRi. For example, a respondent is an individual who discloses personal information to CRi in the course of quantitative or qualitative marketing or social research.
third party: An individual or organization outside of CRi.
use: The treatment, handling, and management of personal information by and within CRi or by a third party with the knowledge and approval of CRi.
3. The Ten Principles of Privacy
Principle 1 – Accountability
CRi is responsible for personal information under its control and shall designate one or more persons who are accountable for CRi’s compliance with the following principles.
Principle 2 – Identifying Purposes for Collection of Personal Information.
CRi shall identify the purposes for which personal information is collected at or before the time the information is collected.
CRi collects personal information from the public only for the following purposes: (a) to conduct quantitative or qualitative marketing and social research; (b) to understand respondent opinions to establish suitability for further quantitative and qualitative marketing; and (c) to meet legal and regulatory requirements. Further reference to “identified purposes” mean the purposes identified in this Principle.
CRi shall specify electronically or in writing the identified purposes to the respondent at or before the time personal information is collected in a survey. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within CRi who can explain the purposes.
When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is permitted or required by law, the consent of the respondent will be acquired before the information will be used or disclosed for the new purpose.
CRi may provide clients or other third parties with information from any survey, in aggregate form. In aggregate form it is impossible to identify an individual respondent’s personal information.
Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of an individual are required for the collection, use, or disclosure of personal information, except where inappropriate.
Participation by respondents in survey research is always voluntary. When a respondent agrees to participate in a survey, he/she gives consent to the interview by participating.
Generally, any personal information collected in the course of an interview is not disclosed to third parties. However, occasionally, a client sponsoring a research project may need to contact respondents directly; for example, when there is a prize awarded to one or more randomly selected survey participants. In these cases, CRi always explains the reason for the disclosure to the respondent and obtains express permission from the respondent before making any such disclosure. No other information about a prize winner is shared with the client; the information shared is only to allow the client to award the prize.
A respondent is always free to choose whether or not to participate in a survey, free to choose not to answer any specific questions and free to discontinue participation at any time.
In obtaining consent, CRi shall use reasonable efforts to ensure that a respondent is advised of the identified purposes for which personal information will be used or disclosed. The identified purposes shall be stated in a manner that can be reasonably understood by the respondent.
Generally, CRi shall seek consent to use and disclose personal information at the same time it collects the information. However, CRi may seek consent to use and/or disclose personal information after it has been collected, but before it is used and/or disclosed for a new purpose.
In determining the appropriate form of consent, CRi shall take into account the sensitivity of the personal information and the reasonable expectations of its respondents.
The participation of a respondent in a quantitative or qualitative marketing or social research study may constitute implied consent for CRi to collect, use and disclose personal information for the identified purposes.
Principle 4 – Limiting Collection of Personal Information
CRi shall limit the collection of personal information to that which is necessary for the purposes identified by CRi. CRi shall collect personal information by fair and lawful means.
In conducting surveys, CRi limits the amount and type of personal information it collects. We collect only the amount and type of information needed for the purposes identified to individuals.
CRi collects personal information about an individual primarily from that individual or a member of that individual’s household. Except as permitted by law, CRi will only collect personal information from external sources, such as client organizations, if individuals have consented to such collection.
Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information
CRi shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
CRi may disclose a respondent’s personal information to:
(a) a client of CRi where the respondent has consented to such disclosure;
(b) a third party engaged by CRi to perform functions on its behalf;
(c) a public authority or agent of a public authority if, in the reasonable judgment of CRi, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or
(d) a third party or parties, where the respondent consents to such disclosure or disclosure is required or permitted by law.
Only CRi’s employees with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about respondents.
CRi shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where a respondent may have to be re-contacted for purposes of clarifying responses to a survey, or to seek additional responses, CRi shall retain the personal information for a period of time that is reasonably sufficient to allow this re-contact.
CRi shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.
Principle 6 – Accuracy of Personal Information
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
Personal information used by CRi shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a respondent.
CRi shall update personal information about respondents and employees as necessary to fulfill the identified purposes or upon notification by the individual.
Principle 7 – Security Safeguards
CRi shall protect personal information by security safeguards appropriate to the sensitivity of the information.
CRi shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held.
CRi shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.
All of CRi’s employees with access to personal information shall be required to respect the confidentiality of that information.
Principle 8 – Openness Concerning Policies and Procedures
CRi shall make readily available to individuals specific information about its policies and procedures relating to the management of personal information.
CRi shall make information about its policies and procedures easy to understand, including:
(b) the means of gaining access to personal information held by CRi;
(c) a description of the type of personal information held by CRi, including a general account of its use; and
(d) a description of what personal information is made available to related organizations (e.g. subsidiaries).
Principle 9 – Individual Access to Personal Information
Upon request, CRi shall inform an individual of the existence, use, and disclosure of his or her personal information and shall give the individual access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Upon written request to the Privacy Officer, CRi will inform an individual of the existence, use and disclosure of his/her personal information and shall be given access to that information In certain situations, CRi may not be able to provide access to all the personal information that it holds about a respondent. For example, CRi may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, CRi may not provide access to information if disclosure would reveal confidential commercial information.
In order to safeguard personal information, a respondent may be required to provide sufficient identification information to permit CRi to account for the existence, use and disclosure of personal information and to authorize access to the individual’s file. Any such information shall be used only for this purpose.
CRi shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file. Where appropriate, CRi shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences. Respondents and employees can obtain information or seek access to their individual files by contacting CRi Privacy Officer.
Principle 10 – Challenging Compliance
CRi shall maintain procedures for addressing and responding to all inquiries or complaints from its respondents regarding CRi’s handling of personal information. CRi shall, on written request, inform its respondents about the existence of these procedures as well as the availability of complaint procedures.
Officer by e-mail email@example.com or by mail at 337 Rothesay, Unit 198, Saint John, NB E2J 2C3.
Please visit the Privacy Commissioner of Canada’s website at www.privcom.gc.ca