Privacy Policy

Definitions

The Privacy Act is described as:

An Act to extend the present laws of Canada that protect the privacy of individuals and that provide individuals with a right of access to personal information about themselves.

The term personal information is defined as information about an identifiable individual that is recorded in any form with some specific exceptions for the purposes of Access to Information Act requests.

1. Statement of Policy

It is the policy of Travana Networks to control the collection, use, and disclosure of personal information in accordance with all requirements set out in the Privacy Act.

1.1Requirements

The following requirements shall be met by Travana Networks unless exempted by the Privacy Act.

Collection of Personal Information

Unless otherwise authorized by the Privacy Act

• No personal information shall be collected by Travana Networks unless it relates directly to an operating program or activity of Travana Networks

   

• Travana Networks shall, wherever possible, collect personal information that is intended to be used for an administrative purpose directly from the individual to whom it relates except where the individual authorizes otherwise.

   

• Travana Networks shall inform any individual from whom it collects personal

   

information of the purpose for which the information is being collected.

Retention of Personal Information

Personal information that has been used by Travana Networks for an administrative purpose shall be retained for such period of time after it is so used as may be prescribed by regulation in order to ensure that the individual to whom it relates has a reasonable opportunity to obtain access to the information.

Accuracy of Personal Information

Travana Networks shall take all reasonable steps to ensure that personal information that is used for an administrative purpose is as accurate, up-to-date and complete as possible.

Disposition of Personal Information

Travana Networks shall dispose of personal information under its control in accordance with the regulations and with any directives or guidelines issued by the designated minister in relation to the disposal of that information and with its corporate retention schedule. Use and Disclosure of Personal Information

Personal information under the control of Travana Networks shall not, without the consent of the individual to whom it relates, be used or disclosed by Travana Networks except for the purpose for which the information was obtained or compiled or for a use consistent with that purpose unless otherwise authorized by the Privacy Act. In certain circumstances personal information subject to the Privacy Act may be used, or disclosed without the knowledge or consent of the individual concerned. Such circumstances include, but are not limited to personal information used or disclosed:

• for the purpose for which the information was obtained or compiled by Travana Networks or for a use consistent with that purpose;

   

• for the purpose of complying with a subpoena or warrant issued or order made by a court, person or body with jurisdiction to compel the production of information or for the purpose of complying with rules of court relating to the production of information;

   

• to an investigative body specified in the regulations for the purpose of enforcing any laws or carrying out a lawful investigation;

   

• to officers or employees of Travana Networks for internal audit purpose;

   

• to the Library and Archives of Canada for archival purposes;

   

• where disclosure would clearly benefit the individual to whom the information relates.

   

Record of Disclosures

Travana Networks shall retain a record of any use of personal information contained in a personal information bank or any use or purpose for which that information is disclosed where the use or purpose is not included in the statements of uses in the personal information index published by the designated minister and shall attach the record to the personal information.

Personal Information Banks

Travana Networks shall include in personal information banks all personal information under its control that

• has been used, is being used or is available for use for an administrative purpose; or

   

• is organized or intended to be retrieved by the name of an individual or by an identifying number, symbol or other particular assigned to an individual.

   

Access to Personal Information

Upon receipt of a written request, Travana Networks shall provide a right of access to personal information subject to the Privacy Act to

• any personal information about the individual requestor contained in a personal information bank; and

   

• any other personal information about the individual requestor under the control of a Travana Networks with respect to which the individual is able to provide sufficiently specific information on the location of the information as to render it reasonably retrievable. 
• Individuals who are given access to their personal information may


• request correction of the personal information where the individual believes there is an error or omission therein;

   

• require that a notation be attached to the information reflecting any correction requested but not made; and

   

• require that any person or body to whom that information has been disclosed for use for an administrative purpose within two years prior to the time a correction is requested or a notation is required under this subsection in respect of that information

   

• be notified of the correction or notation, and

   

• where the disclosure is to a government institution, the institution make the correction or notation on any copy of the information under its control.

   

Refusal of Access to Personal Information

Travana Networks may refuse access to personal information as provided by the Privacy Act where such information, among other circumstances:

• is subject to solicitor client privilege

   

• is part of or relates to an investigative record where disclosure could be injurious to the enforcement of a law of Canada or a province or the conduct of investigation.

   

• Where disclosure threatens the safety of individuals.

   

1.2 Responsibility

All Travana Networks employees, who collect, maintain and/or use personal information, are responsible for insuring that the collection, use and disclosure of this information is carried out in accordance with this policy and relevant procedures.

The Corporate Secretariat is the department responsible for supervising compliance with the legislation and for initiating procedures, guidelines and schedules that will be developed to effect this policy.

The Privacy Coordinator is accountable for Travana Networks's policies and practices, with respect to the management of personal information, and is the individual to whom complaints and inquiries can be forwarded.

2. Operating Principles

All questions related to the interpretation and application of this policy should be directed to the Privacy Coordinator, This e-mail address is being protected from spam bots, you need JavaScript enabled to view it .

Privacy Standards

Travana Networks's privacy provisions are based on the CSA International's Model Code for the Protection of Personal Information, recognized as a national standard in 1996. The standard addresses the ways in which organizations collect, use and disclose personal information. It also addresses the rights of individuals to have access to their personal information and to have it corrected if necessary.

The code's 10 principles are:

Accountability

An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization's compliance with these principles.

Identifying Purposes

The purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected.

Consent

The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except where inappropriate.

Limiting Collection

The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means.

Limiting Use, Disclosure, and Retention

Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfilment of these purposes.

Accuracy

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Safeguards

Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.

Openness

An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.

Individual Access

Upon request, an individual shall be informed of the existence, use and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization's compliance.