Last Updated: October 22, 2021.
Business + Higher Education Roundtable (“BHER”, "we", "our" and "us") respects the privacy of our stakeholders and is committed to safeguarding the personal information entrusted to us. Protecting the personal information of our stakeholders is one of our highest priorities.
We will inform our members and stakeholders of why and how we collect, use and disclose their personal information, obtain meaningful consent where required and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
What is Personal Information?
Personal Information means any information that identifies you or could be combined by us or our service providers and affiliates with other information to identify you. Examples of Personal Information we may collect includes:
- Geolocation information;
- Device information, such as information about the device used to access our website and when (eg. IP address, web browser used, operating system, browser language settings, which site it came from, searched keywords, and unique device identifiers and advertising identifiers);
- Online activity on our website such as pages you visited and content you reviewed;
- Any communications exchanged with our team related to an inquiry made or any of our programs; and
- Any other information you directly provide to us.
Personal Information does not include personal information where all references to the identity of the relevant individual have been removed (i.e. anonymous personal information). Also, publicly available information is not usually considered Personal Information. Business contact information such as your name, title, business address, telephone number or email addresses that are collected, used or disclosed solely for the purpose of communicating with you in relation to your employment or profession is generally not considered Personal Information.
Purposes BHER Collects Personal Information
Unless the purposes for collecting Personal Information are apparent in the circumstances or obvious or the member and stakeholder voluntarily provide their 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.
We may collect Personal Information that is necessary to fulfill the following purposes:
1) manage and develop BHER's business and operations, including personnel and employment matters; and
2) to meet legal a regulatory requirements
However, there may be other circumstances that require such information to be collected and used.
BHER collects the following personal information from individuals during the course of normal commercial activities. The information obtained includes, but is not limited to, name, business title, rank, function and general contact information, levels of interest for our services and topics, and transaction activity with BHER.
This information is used primarily to determine an individual's entitlement to BHER. In addition, this information may be used to:
- Enable individuals to tailor the presentation of our services to better meet their needs.
- Inform individuals about BHER products and services that we believe may be of interest to them.
- Better understand an individual’s interests in our products and services.
- Develop, enhance or improve products and services.
- Registration for programs, events and activities.
BHER will obtain stakeholder consent to collect, use and disclose Personal Information, except where authorized to do so without consent. Consent can be provided orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting, using or disclosing the Personal Information would be considered obvious and the member, employee, client, volunteer, donor, sponsor or stakeholder voluntarily provide Personal Information for that purpose.
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), members, employees, clients, volunteers, donors, sponsors and stakeholders can withhold or withdraw their consent for BHER to use their Personal Information in certain ways. Their decision to withhold or withdraw their consent to certain uses of Personal Information may restrict our ability to provide a particular service or support. If so, we will explain the situation to assist them in making the decision.
In limited circumstances, BHER may collect or disclose personal information without the knowledge or consent of the individual, for example, for purposes of debt collection, breaches of agreements, as required by governmental bodies acting with authority, or as authorized or required by applicable legislation.
How Do We Use and Disclose Personal Information?
Personal information will 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.
We may share Personal Information with third-party providers to assist BHER in the providing of services be it requested, relevant to content or to facilitate payment processing; related to corporate transactions; or to comply with legal or governmental requirements.
In all cases, we require our third parties to keep Personal Information secure. They must agree to protect any Personal Information with at least the same level of protection that we do. In addition, our service providers may not use or disclose Personal Information for any purpose other than providing the services on our behalf unless we or they have obtained the individual’s consent.
How Long Do We Retain Your Personal Information?
We will only retain stakeholder Personal information for as long as reasonably necessary to fulfil the purposes it was collected for, including for the purposes of satisfying any legal, contractual, regulatory, tax, accounting or reporting requirements.
We collect information when someone visits our website in order to customize your experience. For example, we collect information about what site referred you to our Website, your browser type, operating system type and version, language, and your Internet Protocol ("IP") address. We also collect information about how you browse through our website, including logging the pages you visit and the amount of time you spend on certain pages. We use this information for a number of technical purposes to ensure that our pages load correctly in your browser, as well as to personalize our offers to you. We also use this information to improve our website.
Law Enforcement Requests
We will disclose Personal Information without knowledge or consent if we receive an order, subpoena, warrant or other legal requirement issued by a court, tribunal, regulator or other person with jurisdiction to compel disclosure of the Personal Information. If we receive a request from a police officer or other law enforcement agency for access to a member’s, employee’s, client’s, volunteer’s, donor’s, sponsor’s and stakeholder’s personal information in the course of an actual or potential investigation, our policy is to require the police officer or law enforcement agency to obtain an order, subpoena or warrant, unless the information is urgently required to prevent serious bodily injury or serious damage to personal property.
Storage Outside of Canada
Member, employee, client, volunteer, donor, sponsor and stakeholder Personal Information may be used or stored by us or our service providers outside of Canada. For example, we use Google Drive for document storage to enable a remote work environment. We require that our service providers use technical, administrative and technological safeguards of Personal Information. However, if Personal Information is used or stored outside of Canada, it will also be subject to the laws of the country in which it is used or stored and may be accessible by law enforcement agencies in that country.
How Do We Protect Personal Information?
We take administrative, technical and physical measures to safeguard Personal Information against unauthorized access, unauthorized disclosure, theft and misuse.
Although we take precautions against possible breaches of our security systems, we cannot guarantee that unauthorized access, hacking, data loss or breaches of our security systems will never occur.
Notice to Persons Outside of Canada
How to Request Access or Correction of Personal Information or Make a Complaint
Upon request, we will inform a stakeholder if we hold any Personal Information about them and provide them access to this information. The personal information can be reviewed and modified by making a formal written request by mail or email to BHER’s Privacy Officer at:
Attn: Privacy Officer
176 Gloucester Street, Suite 320
Ottawa, ON K2P 0A6, CA
We will respond to you within thirty (30) days after receipt of your written request or will notify you if a longer period is required by us to fully address your request, provided that an extension of thirty (30) day period is permitted by applicable privacy laws.
BHER will investigate all privacy complaints and respond appropriately. If you are not satisfied with our response to your request or complaint, you should contact the Office of the Privacy Commissioner of Canada or the relevant provincial/territorial privacy commissioner’s office.