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Privacy Policy

The Vertical Growth Network (a division of The Intellectual Capital Coaching Corporation) is committed to keeping the personal information of its clients accurate, confidential, secure and private.  Our Privacy Policy has been designed to inform employees, clients and, subcontractors of our commitment and recognition of our obligation to meet the spirit and terms of the federal Personal Information Protection and Electronic Documents Act.

Contents
Our Privacy Policy describes the principles by which The Vertical Growth Network protects the privacy of personal information in its possession.  It addresses the reasons why such information is collected, how it is used, how its confidentiality is protected and outlines the clients’ rights in respect of this information.  Our Privacy Policy incorporates and expands the 10 principles for the protection of personal information, as devised by the Canadian Standards Association (CSA).

Personal Information Protection Principles

  1. Accountability
    The Vertical Growth Network is accountable for the protection of all personal information within the organization’s possession or control.  We also require a comparable level of protection of this information for our third party relations.

    Our Privacy Officer has overall responsibility for our protection of personal information and for The Vertical Growth Network’s compliance with this Privacy Policy.
  2. Identifying Purposes
    The Vertical Growth Network will not collect, use or disclose to a third party your personally identifiable information without your consent, except where such information could contribute to a legal investigation.

    The nature of the personal information we collect may include:
    • information we receive from you such as name, address, phone number, email address
    • facts about your historical and current use of our services
    • general financial credit and reference information

    Additional purposes for collecting personal information may be identified to a client before or at the time of collection.  However, at a minimum The Vertical Growth Network will collect personal information for the following purposes:

    • to understand your needs and eligibility for services
    • to provide you with services and bill you for those services
    • to communicate with you in general, and to respond to your inquiries
    • to keep current your program history
    • to keep you updated and to make special offers and announcements
    • to compile statistics, including The Performance Evaluator and Performance Index
    • to determine fees
  3. Consent
    The Vertical Growth Network will obtain consent before or when it collects, uses or discloses personal information about an individual.  An individual can provide consent to the collection, use and disclosure of personal information about them expressly or implicitly.  The Vertical Growth Network will collect, use or disclose personal information without an individuals consent only in limited circumstances as permitted by law.  Subject to certain legal and contractual restrictions and reasonable notice, an individual can refuse or withdraw their consent to the collection, use or disclosure of personal information about them at any time.

    All existing clients will be informed of what types of personal information have been collected, the purpose for the collection and the procedures available for contacting The Vertical Growth Network with any inquiries.  All new clients will be provided with a consent form and an accompanying explanation about the collection, use and disclosure of their personal information.
  4. Limiting Collection
    The Vertical Growth Network limits the amount and type of information it collects to that which is necessary for the business.  Personal information will be collected using procedures which are fair, transparent and lawful.
  5. Limiting Use, Disclosure and Retention
    The Vertical Growth Network will only use the personal information for the purposes for which it was collected as identified in principle #2, unless consent is given by the individual to use or disclose it for another purpose.  The Vertical Growth Network will develop explicit retention periods for former clients, after which personal information will be destroyed or made anonymous.

    Under certain circumstance, The Vertical Growth Network may have a legal duty or right to disclose personal information without the individual’s knowledge or consent.
  6. Accuracy
    In order to ensure reliable service, and the correct billing for such service, all personal information will be kept accurate, complete and up to date.

    Individuals may challenge the accuracy and completeness of personal information about them and have it amended, as appropriate.
  7. Safeguards
    In executing its responsibilities with respect to the confidentiality of personal information, The Vertical Growth Network will employ a number of safeguards, appropriate to the sensitivity of the information, to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.  Such safeguards will include physical measures, organizational measures and technological measures, for example locked filing cabinets, restricted access to offices, limiting access on a “need to know” basis and use of passwords and encryption.  Procedures for implementing these measures will be communicated to all employees and third parties to ensure compliance with this principle.
  8. Openness
    The Vertical Growth Network will make its policies and practices relating to the protection of personal information readily available to its clients.  The information will be available in a format that is easy to understand.
  9. Individual Access
    Any client of The Vertical Growth Network can have access to the personal information about them that The Vertical Growth Network has in its possession or control.  Any client may request that their personal information be amended for purposes of accuracy and completeness.

    Clients may make their requests by telephone (905) 631-0500, or  in writing to  5045 south Service Rd., 1st Floor, Burlington, ON L7L 5Y7.  Response to an individual’s request will be made in a timely and efficient manner.

  10. Challenging Compliance
    Any client of The Vertical Growth Network may challenge The Vertical Growth Network’s compliance with this Privacy Policy by contacting The Vertical Growth Network directly.  If the client is not satisfied with the way The Vertical Growth Network has responded to a complaint, the client can contact the Privacy Commissioner of Canada.

Date of Issue: January 2004