Pace Creative Group Personal Information Protection Policy

At Pace Creative Group we are committed to providing our clients with exceptional service. Providing this service can involve the collection, use, and disclosure of our clients’ personal information; therefore, protecting their personal information is one of our highest priorities.

To protect our clients’ information, we follow British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, is a law that outlines how businesses and not-for-profit organizations in British Columbia may collect, use, and disclose personal information.

In adherence to PIPA, we will inform our clients about why and how we collect, use, and disclose their personal information; will obtain consent where required; and will only handle personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ personal information and allowing our clients to request access to, and correction of, their personal information.

Definitions

Personal Information: Any information about an identifiable individual (Note: personal information does not include contact information [described below]).

Contact Information: Any information that would enable an individual to be contacted at a place of business and includes name, position 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: The individual designated who is responsible for ensuring that Pace Creative Group complies with this policy and PIPA.

1.0 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:

1.2.1 To verify identity (we may collect name, company name, email, business address, and business telephone number).

1.2.2 To identify client preferences (we may collect name, company name, email, business address, and business telephone number).

1.2.3 To understand the needs of our clients (we may collect name, company name, email, business address, and business telephone number).

1.2.4 To deliver requested products and services (we may collect name, company name, email, business address, and business telephone number).

1.2.5 To provide marketing services (we may collect name, company name, email, business address, and business telephone number).

1.2.6 To ensure a high standard of service to our clients (we may collect name, company name, email, business address and business telephone number).

2.0 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 orally, in writing, electronically, and 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 client voluntarily provides personal information for that purpose.

2.3Consent 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 mail-outs, the marketing of new services or products, or fundraising 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 Pace Creative Group 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:

2.5.1 When the collection, use, or disclosure of personal information is permitted or required by law.

2.5.2 When the personal information is available from a public source (e.g., a telephone directory).

2.5.3 When we require legal advice from a lawyer.

2.5.4 For the purposes of collecting a debt.

2.5.5 To protect ourselves from fraud.

2.5.6 To investigate an anticipated breach of an agreement or a contravention of law.

3.0 Using and Disclosing Personal Information

3.1 We will only use or disclose our clients’ 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:

3.1.1 To conduct client surveys to enhance the provision of our services.

3.1.2 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 unless we have consent to do so.

4.0 Retaining Personal Information

4.1 If we use our clients’ 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 our clients’ personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

5.0 Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that our clients’ 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 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. A request to correct personal information should be forwarded to Pace Creative’s Privacy Officer or designated individual.

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.

6.0 Securing Personal Information

6.1 We are committed to ensuring the security of our clients’ personal information to protect it from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks.

6.2 The following security measures will be followed to ensure that our clients’ personal information is appropriately protected:

6.2.1 We will use appropriate security measures when destroying client’s personal information such as shredding documents and deleting electronically stored information.

6.2.2 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

7.0 Providing Clients Access to Personal Information

7.1 Clients have a right to access their personal information, subject to limited exceptions.

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. Any request to access personal information should be forwarded to the Privacy Officer.

7.3 Upon request, we will also tell our 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 will 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 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.

8.0 Questions and Complaints: The Role of the Privacy Officer

8.1 The Privacy Officer is responsible for ensuring Pace Creative Group’s compliance with this policy and PIPA.

8.2 Clients should direct any complaints, concerns, or questions regarding Pace Creative Group’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.

9.0 Contact

Contact information for Pace Creative Group’s Privacy Officer:

John Pace

Telephone: 604-620-3040

Email: contact@creativepace.com