contact usPersonal Information –means information about an identifiable individual such as name, age, home address
and phone number, social insurance number, marital status, religion, income, credit history, medical information,
education, and/or employment information. Personal information does not include contact information (described
below).
Contact information – means information that would enable an individual to be contacted at a place of business
and includes name, position name or title, business telephone number, business address, business email or
business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that SKADI Cyber Defense
complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the client voluntarily provides
his or her personal information for those purposes, we will communicate the purposes for which
personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect client information that is necessary to fulfill the following purposes:
[Fill in the purposes for which your organization collects personal information. Examples of purpose
statements, which may or may not be applicable to your organization, include:
• To verify identity;
• To verify creditworthiness;
• To identify client preferences;
• To understand the cybersecurity needs of our clients;
• To open and manage an account;
• To deliver requested products and services
• To enrol the client in a program;
• To contact our clients for fundraising;
• To ensure a high standard of service to our clients;
• To meet regulatory requirements;
Policy 2 – Consent
2.1 We will obtain client consent to collect, use or disclose personal information (except where, as noted
below, we are authorized to do so without consent).
2.2 Consent can be provided in writing, or it can be implied where the purpose for collecting using or
disclosing the personal information would be considered obvious and the client voluntarily provides
personal information for that purpose.
2.3 Consent may also be implied where a client is given notice and a reasonable opportunity to opt-out of
his or her personal information being used for the marketing of new services or products, and the client
does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or
product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients can
withhold or withdraw their consent for SKADI Cyber Defense to use their personal information in certain
ways. A client’s decision to withhold or withdraw their consent to certain uses of personal information
may restrict our ability to provide a particular service or product. If so, we will explain the situation to
assist the client in making the decision.
2.5 We may collect, use or disclose personal information without the client’s knowledge or consent in the
following limited circumstances:
• When the collection, use or disclosure of personal information is permitted or required by law;
• In an emergency that threatens an individual's life, health, or personal security;
• When the personal information is available from a public source (e.g., a telephone directory);
• When we require legal advice from a lawyer;
• For the purposes of collecting a debt;
• To protect ourselves from fraud;
• To investigate an anticipated breach of an agreement or a contravention of law
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose client personal information where necessary to fulfill the purposes identified
at the time of collection [or for a purpose reasonably related to those purposes such as:
• To contact our clients directly about products and services that may be of interest
3.2 We will not use or disclose client personal information for any additional purpose unless we obtain
consent to do so.
3.3 We will not sell client lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use client personal information to make a decision that directly affects the client, we will retain that
personal information for at least one year so that the client has a reasonable opportunity to request
access to it.
4.2 Subject to policy 4.1, we will retain client personal information only as long as necessary to fulfill the
identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that client personal information is accurate and complete
where it may be used to make a decision about the client or disclosed to another organization.
5.2 Clients may request correction to their personal information in order to ensure its accuracy and
completeness. A request to correct personal information must be made in writing and provide sufficient
detail to identify the personal information and the correction being sought.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the
information as required and send the corrected information to any organization to which we disclosed
the personal information in the previous year. If the correction is not made, we will note the clients’
correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client personal information in order to protect it from
unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that client personal information is
appropriately protected:
Client information is accessible to employees of SKADI Cyber Defense and only on a need-to-know
basis. Information is encrypted and stored on secured systems only, and is not reused or distributed.
6.3 We will use appropriate security measures when destroying client’s personal information such as
overwriting data. In cases where there is data stored on an employee’s computing device for the
purposes listed above, it will also be electronically overwritten.
6.4 We will continually review and update our security policies and controls as technology changes to
ensure ongoing personal information security.
Policy 7 – Providing Clients, Customers, Members Access to Personal Information
7.1 Clients have a right to access their personal information, subject to limited exceptions.
Exception when it concerns solicitor-client privilege, or disclosure would reveal personal information
about another individual.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify
the personal information being sought.
7.3 Upon request, we will also tell clients how we use their personal information and to whom it has been
disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of
an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we
will inform the client of the cost and request further direction from the client on whether or not we should
proceed with the request.
7.6 If a request is refused in full or in part, we will notify the client in writing, providing the reasons for refusal
and the recourse available to the client.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer is responsible for ensuring SKADI Cyber Defense’s compliance with this policy and
the Personal Information Protection Act.
8.2 Clients should direct any complaints, concerns or questions regarding SKADI Cyber Defence’s
compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the
client may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for SKADI Cyber Defense’s Privacy Officer:
Christie Buckley
President
christie [dot] buckley [at] skadicyber [dot] com
