Overview

Shouldice Trucking will collect, use and disclose personal information in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA).

Shouldice Trucking will manage personal information collected from employees, customers, business partners and other individuals in a responsible and business-like manner. We will control the collection and accuracy of personal information, ensure up-to-date inventory of personal information and protect the information collected from unauthorized use or disclosure.

Identifying Purposes

Shouldice Trucking collects personal information for the following purposes:

• to provide an appropriate supply of well trained employees and contractors for all its critical functions
• to comply with all safety and regulatory obligations
• to recruit and train professionals for all areas of the business
• to deliver service to all its customers
• for management purposes, labor relations and human resources including compliance with all regulatory authorities, fact finding boards, investigation of operating irregularities, employee discipline, employee fitness for work, administration of pay, benefits and other related matters
• to manage equipment, properties and facilities
• to ensure environmental compliance
• to perform risk management
• for all other purposes necessary to ensure safe, efficient and cost effective movement of goods within Canada.

Shouldice Trucking identifies the purposes for which it collects personal information at or before the time of collection from an individual and collects only that information necessary for the purposes identified. This information is normally collected through the completion of forms or other documents. Collection of information may also be by implied consent or orally.

Consent

Knowledge and consent of the individual is required for the collection, use and disclosure of personal information except where inappropriate and in cases of implied consent for statutorily required purposes. The Personal Information Protection and Electronic Documents Act sets out specific conditions under which Shouldice Trucking may collect, use or disclose personal information without the knowledge or consent of the individual.

Consent requires “knowledge and consent”. Shouldice Trucking will make every reasonable effort to ensure that individuals are advised of the purposes for which their information is being collected and used. Purposes for collection will be stated in such a manner as to ensure that the individual can reasonably understand how the information will be used and disclosed.

Shouldice Trucking will not require an individual to consent to the collection, use or disclosure of information beyond that required to fulfill explicitly specified and legitimate purposes. In determining the form of consent, Shouldice Trucking will take into account the sensitivity of the information and the reasonable expectations of the individual.

Depending upon the circumstances and the type of information to be collected, Shouldice Trucking may request consent in a number of ways. Shouldice Trucking will generally seek express consent when the information is considered to be of a sensitive nature and less sensitive information may be collected by implied consent.

Individuals may give consent in a number of ways including:

• an application form may be used to seek consent, collect information and inform the individual of the use that will be made of that information. By completing and signing the form, the individual gives consent to the collection and the specified uses
• consent may be given orally when information is collected over the telephone

An individual may withdraw consent at any time subject to legal and contractual restrictions and with reasonable notice. Shouldice Trucking will inform the individual of the implications of such a withdrawal.

Limiting Collection

Personal information will be limited by Shouldice Trucking to that which is necessary for the purposes it has identified. Information will be collected by lawful and fair means. Shouldice Trucking will not collect personal information in a misleading manner or indiscriminately. Shouldice Trucking will specify the type of information collected as part of its information handling policies and practices.

Limiting Use, Disclosure and Retention

Personal information will not be disclosed or used for purposes other than those identified without the consent of the individual. Personal information will only be held for as long as it is necessary to fulfill those purposes and as identified by various legislative, regulatory and auditing requirement determining retention periods (i.e. Income Tax Act, MOT regulations, etc). Personal information that has been used to make a decision about an individual will normally be held for a one year period to allow an individual access following a decision making process. Shouldice Trucking may also retain information for a reasonable length of time after it is no longer relevant to an individual in order to comply with its objectives, provincial, federal and international requirements.

Personal information will be destroyed or erased after it is no longer required to fulfill the identified purposes. Shouldice Trucking has guidelines that govern the destruction of personal information.

Accuracy and Security of Personal Information

Personal information collected will be kept as accurate, complete and up to date as is necessary for the purposes for which it is used. Safeguards may vary dependent upon they sensitivity of the information being held. These methods include the following:

• physical measures (locked filing cabinets, restricted access to offices)
• limiting access on a “need-to-know” basis
• the use of passwords and/or encryption on files

Shouldice Trucking will ensure that its employees are aware of the importance of maintaining the protection of personal information and will use care in disposing of or destroying personal information collected to prevent unauthorized access to the information.

Individual Access

An individual will be informed, upon request, of the existence, use and disclosure of his/her personal information and will be given access to that information subject to the exclusions set out in the PIPEDA. An individual may challenge the accuracy and completeness of the information and have it amended as appropriate.

Shouldice Trucking will respond to an individual’s request for information within a reasonable time and at a minimal cost to the individual. If there is a cost to the individual for access, Shouldice Trucking will provide an estimate and the individual must advise Shouldice Trucking that he/she is or is not withdrawing the request. Shouldice Trucking will make the information provided to the individual in such form as to be readily understandable and will include any explanations on abbreviations or codes.

Shouldice Trucking will amend information when an individual successfully demonstrates the inaccuracy or incompleteness of personal information. The information may require correction, deletion or addition of information.

Accountability

Shouldice Trucking is responsible for the personal information under its control and has designated the Human Resources Manager as its Privacy Officer. The Privacy Officer is accountable for Shouldice Trucking’s compliance with PIPEDA. Any questions or comments regarding this privacy policy or its administration should be forwarded to the Human Resources Manager.

Procedures have been put in place to receive and respond to inquiries or complaints from our employees and independent operators relating to handling personal information. Shouldice Trucking will investigate all complaints and, if the complaint is justified will take appropriate measures including amending its policies and practices if necessary.

Personal information and privacy inquires should be directed as follows:

In writing:
Administration
Shouldice Trucking
2850 County Road 18
Prescott, ON K0E 1T0

By e-mail: celineg@shouldicetrucking.ca
Facsimile: 613.822.3291