Purpose of the Policy
Food and Beverage Ontario (“FBO” or “we/us”) may collect personal information in the course of its activities.
FBO is committed to ensuring compliance with the Canada Personal Information Protection and Electronic Documents Act (“PIPEDA”) and all other applicable privacy legislation.
By providing us with your Personal Information, you are consenting to the collection, use, disclosure, and retention, by us, of your Personal Information, as set out in this Policy.
All employees, members, directors, officers, representatives, consultants, contractors, agents, and other persons who act or provide services on behalf of FBO shall be subject to this Policy.
Personal Information – Personal information is any factual or subjective information, recorded or not, about an identifiable person (e.g. age, name, address, income, phone number, etc.). Personal information does not include the name, title, or business address or telephone number of an employee of an organization.
Personal information could be obtained by interacting with FBO websites (and affiliated websites), databases, applications, Application Programming Interfaces (APIs), employees, and contractors.
While interacting or communicating with us, you do not need to provide any information about yourself. However, if you choose to provide Personal Information to us, we will take the necessary steps to safeguard it to the furthest extent possible.
FBO is committed to ensuring that all personal information gathered by FBO is kept confidential and is treated in a manner that a reasonable person would consider appropriate in the circumstances.
All personal information under the control or custody of FBO shall be regarded as confidential and available only to authorized users. Subject to specific limitations and exceptions, individuals (or their legal representatives) may access their own personal information contained in records under the custody or control of FBO following the process outline in this Policy.
FBO’s websites were not designed and are not directed to children eighteen (18) years of age or younger. Committed to protecting children’s privacy in an on-line environment, we do not intentionally collect or maintain Personal Information provided by children.
The following are FBO’s key privacy principles, based on Schedule 1 of PIPEDA:
- Accountability for Personal Information
FBO shall be responsible for the personal information in its custody or control, including information that has been transferred to a third party for processing. FBO shall use contractual or other means to ensure the protection of any information in the possession of a third party. FBO’s employees and agents shall be responsible for any personal information that they have in their possession at all times.
FBO has a Privacy Officer that is committed to ensuring FBO’s compliance with PIPEDA, to the extent that such Act applies to FBO.
- Identifying Purposes for Collecting Personal Information
FBO shall collect your personal information for the primary purposes of:
- providing services or programs;
- processing a payment or fulfilling other administrative duties;
- creating internal reports and statistical analyses on web usage levels; and/or
- complying with any other legal obligations owing by us to you.
When personal information is required to be collected from an individual, FBO will identify and document the purpose for which it is being collected, will explain how it will be used, and will obtain the individual’s consent to collect, use, and disclose it. FBO will use reasonable efforts to ensure that the individual reasonably understands how the information will be used and disclosed.
If personal information that has been collected is required to be used for a different purpose than originally disclosed, the new purpose will be identified to the relevant individual prior to use. Unless the new purpose is required or permitted by law, such individual’s consent will be obtained before the information is used for that new purpose.
- Consent for Collection, Use, and Disclosure of Personal Information
Consent is required for the collection of personal information and the use and disclosure of such information. FBO shall seek consent for the use and disclosure of personal information either prior to or at the time of collection.
In determining the form of consent to collect, use, or disclose personal information (implied/express, verbal/written), FBO will take into account the sensitivity of the information and applicable legal requirements. Regardless of the form of consent given, FBO will ensure that the consent is knowledgeable, voluntary, related to the information in question, and given by the relevant individual.
Consent may be withdrawn at any time, subject to legal restrictions and reasonable notice. If an individual would like to withdraw consent to FBO’s use of such individual’s personal information, such individual can do so by unsubscribing to communications. A withdrawal of consent will not apply to a collection, use, or disclosure that had occurred prior to receiving the notice of withdrawal.
- Limiting Collection of Personal Information
The collection, use, and disclosure of personal information will be limited to that which is necessary to fulfill the purposes identified.
- Limiting Use, Disclosure, and Retention of Personal Information
FBO will only use personal information for the purposes for which consent has been given.
FBO may provide personal information to other parties:
- when consent to do so has been provided; and/or
- when FBO is required or permitted to do so by law.
Personal information will be kept until the stated purpose is complete and the relevant individual has exhausted any legal recourse regarding an access request. At such time, or at the end of the legislatively required retention period, whichever is longer, the personal information will be disposed of by means of shredding or another secure disposal method, with care taken to prevent unauthorized parties from gaining access to the information.
- Ensuring Accuracy
While FBO will use reasonable efforts to ensure that an individual’s personal information is as accurate, complete, and up-to-date as necessary for the purposes for which FBO uses the information, ultimately, an individual will be responsible for ensuring that FBO has such individual’s current and complete personal information in FBO’s records. FBO will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected.
- Use of Safeguards to Protect Information
FBO will use appropriate procedures and security measures to protect personal information in its custody or control against theft, loss, and unauthorized use, disclosure, modification, or disposal, regardless of the format in which the information is held.
The methods of protection may include the following:
- locked filing cabinets;
- restricted access to offices;
- alarm system;
- confidentiality agreements with staff and volunteers; and/or
- use of passwords, access controls, and encryption.
The personal information collected by FBO may be shared, stored, or accessed in Canada or in other countries where FBO maintains an office, conducts business, and/or has internet facilities.
If personal information is stolen, lost, or accessed by an unauthorized person, FBO will notify the relevant individual(s) and/or other third parties (such as the Privacy Commissioner) at the first reasonable opportunity, if required to do so by applicable law.
FBO does not sell, rent, or lease personal information to third parties.
- Individual Access to Personal Information
Upon written request, and proof of identification, FBO will inform an individual whether or not it holds personal information about the individual. FBO will allow the individual to access this information in accordance with applicable legislation. Certain situations will prevent FBO from providing access to personal information, including for legal, confidentiality, or security reasons; in such situations, FBO will give a written notice to the individual that states that the request for access is being refused, provides reasons for the refusal, and informs the individual that he/she is entitled to make a complaint about the refusal to the Information and Privacy Commissioner of Ontario (if the request relates to personal health information) or to the Office of the Privacy Commissioner of Canada (if the request relates to non-health personal information). FBO will respond to a request for access within thirty (30) calendar days of receipt of the request, unless extensions are permitted under law and FBO has informed the individual of the length and reason for the extension.
If an individual informs FBO about the inaccuracy or incompleteness of such individual’s personal information, FBO will respond to the correction request, with the amendments, within thirty (30) days of receiving the request, unless extensions are permitted under law and FBO has informed the individual of the length and reason for the extension.
In certain circumstances, FBO will not correct a record of personal information, if prohibited from doing so under law. For example, clinical opinions will not be deleted or amended. If a correction is refused, FBO will inform the individual of the refusal, the reasons for the refusal, the individual’s right to file a complaint regarding the refusal to the Information and Privacy Commissioner of Ontario (if personal health information is involved) or to the Office of the Privacy Commissioner of Canada (if non-health personal information is involved), and the right of the individual to attach a statement of disagreement to FBO’s records (so that any other organization that has access to the Information can view the statement).
- Challenging Compliance
FBO’s Privacy Officer can be contacted at:
Food and Beverage Ontario
P.O. Box 429
Beamsville, Ontario L0R 1B0
Telephone: (905) 467-3751
FBO’s Privacy Officer is available to answer any questions an individual may have about FBO’s collection, use, disclosure, and retention of personal information, or to register a complaint. An individual whose personal information is held by FBO has several other avenues of recourse, including registering a complaint with the Information and Privacy Commissioner of Ontario (personal health information) or with the Office of the Privacy Commissioner of Canada (non-health personal information). FBO is committed to investigating all complaints and taking appropriate action.
While providing links to third-party websites, FBO does not guarantee, and is not responsible for, the information collection and privacy practices of such third-party websites, which may differ from our site’s policies. Please review FBO’s Website Terms and Conditions available at www.foodandbeverageontario.ca.