Introduction
The Ontario Council on Articulation and Transfer (ONCAT) is committed to protecting the privacy of our clients, stakeholders and members of the public who are in contact with us. Our goal is to meet the privacy standards of the Canadian Standards Association: Personal Information Protection Principles, as follows:
- 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 privacy principles.
- Identifying Purposes: An organization shall identify the purposes for which personal information is collected 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 must be retained only as long as necessary for the fulfillment of those 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.
At ONCAT, we have put rules in place across the organization to make sure personal information is kept secure, confidential and accurate.
Personal information means any information that would identify an individual: for example, name and address, phone number and email address; financial or banking information; or information about educational or employment history. Personal information does not include information that has been anonymized, aggregated or combined with other details in such a way that it is impossible to identify any individual.
Further details of how we protect your privacy can be found below. We have developed our privacy policy based on both the CSA privacy standards, as well as the privacy rules found in Ontario’s Freedom of Information and Protection of Privacy Act.
Content
This Privacy Policy describes how ONCAT protects your personal information. The policy explains why ONCAT collects certain kinds of personal information, how that information is used and protected. This policy also explains your rights of access to your own information and/or its correction.
In this Privacy Policy, "ONCAT", "we", "us" or "our" means the Ontario Council on Articulation and Transfer. "Client", “stakeholder”, “supplier”, "you", and "your" mean an individual who is providing personal information for a particular purpose.
However, this Privacy Policy does not apply to information about businesses or post-secondary institutions that carry on business as corporations, partnerships or other forms of association. ONCAT does, however, protect the confidentiality of such information in accordance with the law, institutional codes of conduct, contractual arrangements and our own policies.
By entering into agreements with us, using our website, or otherwise providing us with your personal information, you are accepting the practices described in this Privacy Policy, as they currently exist. Since we may change the terms in this Privacy Policy occasionally, we recommend you review it periodically.
Accountability
At ONCAT, the Executive Director has ultimate responsibility for protecting the privacy of our stakeholders and clients. The Executive Director has delegated the day-to-day responsibilities to ONCAT’s Privacy Officer. However, all employees must meet the organization’s privacy rules.
The Privacy Officer is the person who makes sure the privacy rules are followed across the organization. She is responsible for keeping ONCAT’s privacy rules current and up-to-date. She is also the person who should receive any privacy complaints or inquiries about privacy at ONCAT. If you have questions or concerns, please contact her by e-mail at privacyofficer@oncat.ca or by telephone at 416-640-6951.
ONCAT is responsible for protecting the personal information that it holds about its clients and stakeholders, or that it may disclose to third parties (i.e. to service providers, post-secondary institutions) for various reasons. ONCAT has a number of contracts and agreements with third parties. Those contracts hold the third party to the same level of privacy protection as ONCAT provides.
ONCAT has trained all staff so they understand the privacy rules and their obligations to protect personal information. There are also policies and procedures in place across the organization to make sure ONCAT complies with the privacy rules noted here.
Identifying Purposes
When we ask you for any personal information, ONCAT will explain the reason for the request: why we are collecting personal information and what we will do with it. We will do this when we ask for the information.
After that point, if we need to use your personal information for any other reason, we will explain the new use and ask for consent before we use it. You may refuse to allow ONCAT to use this personal information for this new purpose, unless the new purpose is required by law. However, if you refuse we may not be able to provide you with some services.
Generally, we will use your personal information for the following reasons:
- to contact you, to answer your questions or to give you information about ONTransfer and/or ONCAT’s programs and services;
- to establish a banking relationship if you are providing services to ONCAT;
- to respond to your application for employment; and
- to ask you to take part in surveys or research.
If an ONCAT employee asks you for personal information, that employee should be able to explain how the information will be used. In some cases, privacy questions may be referred to ONCAT’s Privacy Officer, who can provide additional information and answer questions.
Non-Identifying Purposes
In addition to any personally identifiable information or other information that you choose to provide to us, we and our third-party service providers may use a variety of technologies, now and hereafter devised, that automatically collect certain non-personal information whenever you visit or interact with our Website.
We use non-identifying information in a variety of ways, including to help analyze site traffic, understand user needs and trends, carry out targeted promotional activities and to improve our products and services. We may use your non-personal information by itself or aggregate it with information we have obtained from others.
If data collection is not required for the functionality of our site, we do not collect it. At any time, you may request your information to be exported and sent to you for review, and we promptly honor any requests by you to have your information deleted and forgotten.
Cookies
ONCAT uses “cookies” in conjunction with its Websites and Services to obtain information. A cookie is a small data file that is transferred to your device (e.g., your phone or your computer) for record-keeping purposes. For example, a cookie could allow the Websites to recognize your browser, while another could store your preferences and other information.
Your browser may allow you to set how it handles cookies, such as declining all cookies or prompting you to decide whether to accept each cookie. But please note that some parts of the Websites or Services may not work as intended or may not work at all without cookies.
1. ONCAT Cookies and Third Party Cookies
ONCAT may place our cookies on your device via our Websites and Services. Accordingly, our Privacy Policy will apply to our treatment of the information we obtain via our cookies.
We may also allow our business partners to place cookies on your device. For example, we use Google Analytics for web analytics which may also set cookies on your device.
2. Uses for ONCAT Cookies
ONCAT may use cookies for a number of purposes, such as the following:
- to enable, facilitate and streamline the functioning of our sites across different webpages and browser sessions;
- to simplify your access to and use of our sites and make it more seamless;
- to monitor and analyze the performance, operation and effectiveness of our sites, so that we can improve and optimize it; and
- to show you content that is more relevant to you
3. Other Technologies
Our sites may also use other technologies with similar functionality to cookies, such as web beacons and tracking URLs to obtain anonymous data about users. We may also use web beacons and tracking URLs in our messages to you to determine whether you have opened a certain message or accessed a certain link.
4. Disabling Cookies
Most browsers automatically accept cookies, but you can modify your browser setting to turn off cookies. If you choose to decline turn off, please note that some interactive features of our sites may not function properly.
5. Changes to this Cookie Policy
If there are any material changes to this Cookie Policy, you will be notified by email, on our sites, or by posting a prominent notice on our Websites prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our cookie practices. Your continued use of our Websites constitutes your agreement to be bound by such changes to this Cookie Policy. If you do not accept the terms of this Cookie Policy, you can discontinue use of our Websites, or disable cookies and be subject to a potentially degraded experience.
AD Networks
Our Website may use third parties such as network advertisers to serve advertisements on our Website and may use traffic measurement services to analyze traffic on our Websites. Network advertisers are third parties that display advertisements based on your visits to our Website and other websites you have visited. Third-party ad serving enables us to target advertisements to you for services in which you might be interested. Our Website’s third-party ad network providers, the advertisers, the sponsors and/or traffic measurement services may themselves set and access their own cookies and other technologies on your computer and track certain behavioral information regarding users of your computer via an IP address or other device identifier. These third-party cookies and other technologies are set to, among other things: (i) help deliver advertisements to you that you might be interested in; (ii) prevent you from seeing the same advertisements too many times; and (iii) understand the usefulness to you of the advertisements that have been delivered to you. Note that any images (or any other parts of a web page) served by third parties in association with third-party cookies may serve as web beacons, which enable third parties to carry out the previously described activities. Third-party cookies, web beacons and other third-party technologies are governed by each third party’s specific privacy policy, not this one.
Consent
ONCAT will ask for your consent for the collection, use and/or disclosure of your personal information when we collect it from you. In most cases, your consent will be express. For example, when you complete a profile and establish an account on ONTransfer.ca, you are providing express consent for ONCAT to use your personal information to provide you with information about post-secondary transfers in Ontario.
There are only limited circumstances when ONCAT might collect, use or disclose your personal information without your knowledge or consent. These circumstances are permitted or required by law.
You can refuse or withdraw your consent to the collection, use or disclosure of your personal information at any time. However, ONCAT may require you to give notice of your intent, or may advise that your refusal or withdrawal of consent is not possible for certain reasons. You need to be aware that your refusal to consent, or your withdrawal of consent, may mean that ONCAT cannot provide you with some services. We will explain the effects of your withdrawal or refusal to provide consent.
Limiting Collection
ONCAT will not ask for any more of your personal information than we need for the reason(s) we have explained. The kind of information we might ask for includes:
- your name and email address;
- your resume and other employment-related information if you are applying for a position with us;
- educational information about post-secondary courses, diplomas and degrees you might have completed;
- bank information for electronic payments from us (i.e. name and address of bank, your account type and number); and
- additional information regarding a communication you sent us by letter, e-mail or by phone.
Limiting Use, Disclosure and Retention
ONCAT will not use your personal information, except for the purposes we explained when we originally collected it from you. We will not disclose any personal information without your written consent except where you might have reasonably expected such a disclosure.
ONCAT will keep your personal information only as long we need it for the reasons we gave you when we collected it in the first place and to meet legal and contractual obligations. We will not trade, rent or sell your personal information to anyone for any reason.
ONCAT will protect your personal information while we have it. We will apply our records retention policies and schedules to your personal information. Once we no longer need to keep your information, we will destroy it in a secure manner so it cannot be reassembled and used by anyone else.
The only employees at ONCAT who will see your personal information are those whose jobs require access to your personal information.
Accuracy
ONCAT makes every effort to keep your personal information as accurate and up-to-date as possible. If you feel we may be using information about you that is out-of-date or incorrect, you may ask to see the information we have on file about you and ask for a correction, if that is required. Further details about that process are included in the Individual Access section below.
Safeguards
While we have your personal information, we take great care to protect it from loss or theft or any unauthorized access. This means we have rules in place to make sure your information is not copied or changed in any way, or used or disclosed in a way that is not consistent with the consent you gave us.
The way we protect your personal information depends on the format in which we hold it. Paper files are held in locked filing cabinets and only accessible to employees who need the information to do their jobs.
Electronic files are protected behind firewalls and are password-protected. Only ONCAT employees have password access. All employees at ONCAT are aware of their responsibility to protect personal information.
Openness
ONCAT has policies and procedures in place to protect the personal information it holds about clients and stakeholders. If you have any questions about how your personal information is being protected, wish to correct or update your personal information, or wish to see the information we have on file about you, please contact ONCAT’s Privacy Officer.
Individual Access
Anyone can request to see their personal information and request a correction if that information is wrong or out-of-date. There may be some situations where ONCAT may not be able to provide access to all the personal information it holds about an individual. These exceptions are limited and specific. They include situations where one individual’s personal information contains references to other people, where the information was supplied in confidence, or it is information that cannot be disclosed for legal, security or commercial proprietary reasons.
When you make a request to see your own personal information, ONCAT will ask you to provide identifying information so that we can confirm your identity. We do this to confirm your right of access to your own information. We do not use your identifying information for any other purpose.
If a correction or amendment is required, we will correct the personal information as quickly as possible. If there is a difference of opinion as to the need for a correction, a statement of disagreement will be attached to your file. In either event, ONCAT will share the correction or the statement of disagreement with any third parties who have used the personal information within the past year.