Privacy Policy

Article 1       General

Definitions - The following terms have these meanings in this Policy:

1. Act - Personal Information Protection and Electronic Documents Act
2. Commercial Activity - any particular transaction, act or conduct that is of a commercial character.
3. Organization - includes an association, a partnership, a person, an unincorporated association, a trust a not for profit organization, a trade union and a corporation.
4. Personal Information - any information about an identifiable individual, but does not include an employee's name, title, business address or telephone number.
5. Personal Health Information - any health information about an identifiable individual.
6. Representatives - Directors, officers, employees, committees, members, volunteers, coaches, contractors and other decision makes with LIFESTYLE INFORMATION NETWORK (LIN).

1. Disclose personal information to a third party during any business or transaction unless such business, transaction or other interest is properly consented to in accordance with this policy;
2. Knowingly place themselves in a position where they are under obligation to any person to disclose personal information;
3. In the performance of their official duties, disclose personal information to family members, friends or colleagues, or to organizations in which their family members, friend or colleagues have an interest;
4. Derive personal benefit from personal information that they have acquired during the course of fulfilling their official duties with LIFESTYLE INFORMATION NETWORK (LIN); and
5. Accept any gift or favor that could be construed as being given in anticipation of, or in recognition for, the disclosure of personal information.

1. Implement procedures to protect personal information;
2. Establish procedures to receive and respond to complaints and inquiries;
3. Train staff and communicate to staff information about the LIFESTYLE INFORMATION NETWORK (LIN)' s policies and practices; and
4. Develop information to explain LIFESTYLE INFORMATION NETWORK (LIN)'s policies and procedures to members and the public.

1. Name, address, phone number, cell phone number, fax number and e-mail address for the purpose of providing information to LIFESTYLE INFORMATION NETWORK (LIN).
2. Credit card information for purchasing services and other resources.
3. Banking information, social insurance number, criminal records check, resume, and
   beneficiaries for LIFESTYLE INFORMATION NETWORK (LIN)'s payroll, company insurance and health plan.
4. Individual measurements for adjusting equipment.

1. By signing an application form;
2. By checking a check off box;
3. By providing written consent either physically or electronically;
4. By consenting orally in person; or
5. By consenting orally over the phone.

Exceptions for Collection - LIFESTYLE INFORMATION NETWORK (LIN) is not required to obtain consent for the collection, of personal information if:

1. it is clearly in the individual's interests and consent is not available in a timely way;
2. knowledge and consent would compromise the availability or accuracy of the information and collection is required to investigate a breach of an agreement or contravention of a federal or provincial law;
3. the information is for journalistic, artistic or literary purposes;
4. the information is publicly available as specified in the Acts.

Exceptions for Use - LIFESTYLE INFORMATION NETWORK (LIN) may use personal information without the individual's knowledge or consent only:

1. if LIFESTYLE INFORMATION NETWORK (LIN) has reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law and the information is used for that investigation;
2. for an emergency that threatens an individual's life, health or security;
3. for statistical or scholarly study or research (LIFESTYLE INFORMATION NETWORK (LIN) must notify the Privacy Commissioner before using the information);
4. if it is publicly available as specified in the Acts;
5. if the use is clearly in the individual's interest and consent is not available in a timely way; or
6. if knowledge and consent would compromise the availability or accuracy of the information and collection was required to investigate a breach of an agreement or contravention of a federal or provincial law.

Exceptions for Disclosure - LIFESTYLE INFORMATION NETWORK (LIN) may disclose personal information without the individual's knowledge or consent only:

1. to a lawyer representing LIFESTYLE INFORMATION NETWORK (LIN);
2. to collect a debt the individual owes to LIFESTYLE INFORMATION NETWORK (LIN);
3. to comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction;
4. to a government institution that has requested the information, identified its lawful authority, and indicated that disclosure is for the purpose of enforcing, carrying out an investigation, or gathering intelligence relating to any federal, provincial or foreign law; or that suspects that the information relates to national security or the conduct of international affairs; or is for the purpose of administering any federal or provincial law;
5. to an investigative body named in the Acts or government institution on LIFESTYLE INFORMATION NETWORK (LIN)'s initiative when LIFESTYLE INFORMATION NETWORK (LIN) believes the information concerns a breach of an agreement, or a contravention of a federal, provincial, or foreign law, or suspects the information relates to national security or the conduct of international affairs;
6. to an investigative body for the purposes related to the investigation of a breach of an agreement or a contravention of a federal or provincial law;
7. in an emergency threatening an individual's life, health, or security (LIFESTYLE INFORMATION NETWORK (LIN) must inform the individual of the disclosure);
8. for statistical, scholarly study or research (LIFESTYLE INFORMATION NETWORK LIN) must notify the Privacy Commissioner before disclosing the information);
9. to an archival institution;
10. 20 years after the individual's death or 100 years after the record was created;
11. if it is publicly available as specified in the regulations; or
12. if otherwise required by law.

Retention Periods - Personal information shall be retained for certain periods of time in accordance with the following:

1. Employee information shall be retained for a period of seven years in accordance with Canada Customs and Revenue Agency requirements.
2. Marketing information shall be immediately destroyed upon compilation and analysis of
   collected information.
3. As otherwise may be stipulated in federal or provincial legislation.

Destruction of Information - Documents shall be destroyed by way of shredding and electronic files shall be deleted in their entirety.

Information - The information made available shall include:

1. the name or title, and the address, of the person who is accountable for the organization's policies and practices and to whom complaints or inquiries can be forwarded;
2. the means of gaining access to personal information held by the organization;
3. a description of the type of personal information held by the organization, including a general account of its use;
4. a copy of any brochures or other information that explain the organization's policies, standards, or codes.

Denial - An individual may be denied access to his or her personal information and provided a
written explanation as to why if:

1. the information is prohibitively costly to provide;
2. the information contains references to other individuals;
3. the information cannot be disclosed for legal, security, or commercial proprietary reasons, and
4. the information is subject to solicitor-client or litigation privilege.

Contents of Refusal - If LIFESTYLE INFORMATION NETWORK (LIN) determines that the disclosure of personal information should be refused, LIFESTYLE INFORMATION NETWORK (LIN) must inform an individual the following:

1. the reasons for the refusal and the provisions of the Act on which the refusal is based;
2. the name, position title, business address and business telephone number of the Privacy Officer who can answer the applicant's questions; and
3. that the individual may ask for a review within thirty (30) days of being notified of the
   refusal.

Procedures - Upon receipt of a complaint LIFESTYLE INFORMATION NETWORK (LIN) shall:

1. Record the date the complaint is received;
2. Notify the Privacy Officer who will serve in a neutral, unbiased capacity to resolve the complaint;
3. Acknowledge receipt of the complaint by way of telephone conversation and clarify the nature of the complaint within three (3) days of receipt of the complaint;
4. Appoint an investigator using LIFESTYLE INFORMATION NETWORK (LIN) personnel or an independent investigator, who will have the skills necessary to conduct a fair and impartial investigation and will have unfettered access to all file and personnel, within ten (10) days of receipt of the complaint.
5. Upon completion of the investigation and within twenty-five (25) days of receipt of the complaint, the investigator shall submit a written report to LIFESTYLE INFORMATION NETWORK (LIN).
6. Notify the complainant the outcome of the investigation and any relevant steps taken to rectify the complaint, including any amendments to policies and procedures within thirty (30) days of receipt of the complaint.

Whistleblowing - LIFESTYLE INFORMATION NETWORK (LIN) must not dismiss, suspend, demote, discipline, harass or otherwise disadvantage an employee of LIFESTYLE INFORMATION NETWORK (LIN), or deny that employee a benefit because the employee, acting in good faith and on the basis of reasonable belief:

1. has disclosed to the commissioner that LIFESTYLE INFORMATION NETWORK (LIN) has contravened or is about to contravene the Acts;
2. has done or stated an intention of doing anything that is required to be done in order to avoid having any person contravene these Acts;
3. has refused to do or stated an intention of refusing to do anything that is in contravention of these Acts.