privacy policy

Schedule “A” (Dated: May 1, 2019) Privacy Policy of ALEDA MASSAGE THERAPY (the “ALEDA”) Re: Personal Information
1. Preamble

ThePersonalInformationProtectionAct(“the Act”)regulatesthe wayprivate sector “organizations” (as defined in theAct) withinAlberta collect, use and disclose personal information. “PersonalInformation” means information about an identifiable individual. ALEDA recognizes the importance of privacy and recognizes the sensitivity of the personal information received by us in the course of our conduct of business. We recognize our legal obligation to maintain the confidentiality of our clients’, customer’s and other’s information, and also our obligations concerning all individuals’ personal information which we collect, use or disclose in our conduct of business. This policyhas been developedwith those obligationsinmind.

2. Our need for Personal Information

To be able to give service to our clients and customers, we need to collect all relevant facts and information that relate to our services and contracts and those parties who participate in them. This includes customers as well as supplier’s of goods and services. We may also need business and credit information so we can ensure that we will be compensated for our services. This information will necessarily include personal information about our clients and customers and possibly about individuals other than our clients and customers.

3. Collection, Use and Disclosure of Personal Information

Where practical, we will try to collect personal information directly from the person to whom the information pertains. Where necessary, we will collect personal information fromothersources. We will collect only the personal information necessary for the purposes stated in the previous paragraph. The Act providesthat an individual is deemed to consent to the collection, use or disclosure of personal information about that individual for a particular purpose if i) the individual voluntarily provides the information for that purpose, and ii) it is reasonable that a person would voluntarily provide that information. It is our policy to collect personal information about individuals other than our clients and customers in accordance with the provisions of the Act. When we collect personal information about individuals directly from them, except when their consent to the collection is deemed, we will tell them the purpose for which the information is collected, and the name of a person who can answer questions about the collection. The Act also permits us to collect, use or disclose personal information about an individual in some circumstanceswithout the individual’s consent. Such circumstancesinclude but are not limited towhere: - the collection, use or disclosure is clearly in the interests of the individual and consent cannot be obtained in a timely way; - collection, use, or disclosure is reasonable for the purposes of an investigation or proceeding; - the personal information is available to the public from a prescribed source; or - the collection, use, or disclosure is required or authorized by a statute or regulation of Alberta of Canada; and those other purposes enumerated in Section 17 of the Act. When we collect, use or disclose personal information, we will make reasonable effortsto ensure that it is accurate and complete. The Act also allows us, for legal or business purposesto retain (store) personal information for as long as is reasonable. Subject to Section 2 of the Act, for purposes of this policy, we regard reasonable as including, but not limited only to, the limitation periods defined in the Income Tax Act (Canada), the Customs and Excise Tax Act (Canada), similar Provincial legislation, and applicable limitations statutes such as the Limitations Act of Alberta.

4. Security of Personal Information

We recognize our business and legal obligations to protect the personal information of our clients. We recognize as well our legal obligations to protect the personal information we have gathered about our clients customers and about other individuals during the course of our business. We have therefore made arrangements to secure against the unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information.

6. Requests for Correction of Personal Information

The law permits individuals to submit written requests to us to correct errors or omissions in their personal information that is in our custody or control. We will: - correct the personal information and, ifreasonable to do so,send correction notificationsto any other organization to whom we disclosed the incorrect information; or - decided not to correct the personal information but annotate the personal information that a correction was requested but not made.

7. Business Transaction Disclosure

Disclosure of personal informationmaybemade as pertainingto businesstransactionsinaccordancewith Division 6 of the Act. For purposes of this Policy, “businesstransaction” shall have the same meaning as is provided in Section 22 (1) a) of the Act.

8. Contacting or Communication with Us

If you have any questions with respect to our policies concerning the handling of your personal information, or if you wish to request access to, or correction of, your personal information under our care and control, please contact our Privacy Officer at: Alexis Misner C/O 201, 3939 50A, Avenue, Red Deer, Alberta, T4N 4E6 or by e-mail at aledamassagetherapy@gmail.com. I you are dissatisfied with our handling of your personal information, we invite you to contact our Privacy Officer in writing, setting out the reasons for your concern. If you remain dissatisfied after our Privacy Officer has reviewed and responded to your concern, you may wish to contact the Office of the Information and Privacy Commissioner at: 410, 9925 - 109 Street Edmonton, Alberta T5K 2J8 Telephone (780) 422-8860 or Fax (780) 422-5682 NOTICE: The provisions of the policy may be amended from time so as circumstances and procedures in Aleda Massage Therapy change so as to stay in compliance with the requirements of the Act. All staff and others are invited to contribute to the revision of this policy by bringing questions, concerns and making observations to the attention of Alexis Misner (Privacy Officer). All staff are responsible for reading the Policies as amended from time to time and for staying familiar with their requirements. Breaches of these policies or of the Act by an employee or other staff member of Aleda Massage Therapy may be considered as grounds for dismissal. References to Acts and Regulations and to sections thereof may be amended by act of Parliament and/or the Legislature and the references contained herein include reference to such acts and regulations as may be amended from time to time. THE UNDERSIGNED HEREBY ACKNOWLEDGES THAT THEY HAVE BEEN PROVIDED WITH A COPY OF THE WITHIN SCHEDULE 'A' THIS ______DAY OF ________, A.D. 20____.

(Print Name Below)______________________________________

SCHEDULE “B” (May 1, 2019) PRIVACY POLICY OF ALEDA MASSAGE THERAPY (“ALEDA”): PERSONAL INFORMATION OF EMPLOYEES AND OTHERS ENGAGED BY ALEDA (Pursuant to the Personal Information Protection Act, S.A. 2003, C P-6.5 and amendments thereto)
1. Preamble

The Personal Information Protection Act (“the Act”) regulates the way private sector organizations (as defined in the Act) within Alberta collect, use and disclose personal information. “Personal Information” means information about an identifiable individual. ALEDA recognizes the importance of privacy and recognizes the sensitivity of personal information received by us in the course of the conduct of our business. We recognize our legal (common law and statutory) obligations to maintain the confidentiality of our employees’ information, and also our obligations concerning all individuals’ personal information which we collect, use or disclose in the course of our business. This policy has been developed with those obligations in mind.

2. Employee personal Information

An employee is someone employed by ALEDA or someone who performs a service for us and includes a volunteer, a student, a temporary employee, and those in a contract or agency relationship with us. In the case of a corporation, it includes the directors and officers of the corporation as well. Employee personal information refers to an employee’s personal information reasonably required by us and that we have collected, used or disclosed for: i) the purposes of establishing, managing or terminating an employment, volunteer or contractor relationship, or ii) the purposes of managing a post- employment, post-volunteer or contractor relationship, but does not include personal information not related to that relationship. Contact information refers to an individual’s name and position or title, business telephone number, business address, business e-mail, business fax number and other business contact information

3. Collection, Use and Disclosure of Personal Information

The law provides that we can collect, use, and disclose an individual’s employee personal information without consent if the individual is an employee of the organization or if it is for the purpose of recruiting a potential employee, but only if: - the collection, use or disclosure is reasonable for the purposes for which it is being collected, used or disclosed; - the information is related to the employment relationship with us; and - we have, with employees, provided notification to them before collection, using or disclosing the information that we are doing so and our purposes for doing so. Where practical, we will try to collect employee information directly from the person to whom the information pertains. Where necessary, we will collect personal information from other sources. When collecting employee personal information from other sources, or when using or disclosing the personal information we have collected, we will, where required, first obtain the consent of the individual. The Act provides that an individual is deemed to consent to the collection, use or disclosure of personal information about that individual for a particular purpose if the individual voluntarily provides the information for that purpose, and it is reasonable that a person would voluntarily provide that information. When we collect personal information about individuals directly from them, except when their consent to the collection is deemed, we will tell them the purpose for which the information is collected, and the name of a person who can answer questions about the collection (“Privacy Officer”). In addition to the circumstances outlined above, there are other times when the law permits us to collect, use or disclose personal information about an individual without their consent. Such circumstances include, but are not limited to, where: - the collection, use or disclosure is clearly in the interests of the individual and consent cannot be obtained in a timely way; - collection, use, or disclosure is reasonable for the purposes of an investigation or proceeding; - the personal information is available to the public from a prescribed source; or - the collection, use, or disclosure is required or authorized by a statute or regulation of Alberta, or Canada and those other purposes enumerated in Section 18 of the Act. When we collect, use or disclose personal information, we will make reasonable efforts to ensure that it is accurate and complete. The Act also allows us, for legal or business purposes to retain personal information for as long as is reasonable. Subject to Section 2 of the Act, for purposes of this policy, we regard reasonable as including, but not limited only to, the limitation periods defined in the Income Tax Act (Canada), the Customs and Excise Tax Act (Canada), similar Provincial legislation, and applicable limitations statutes such as the Limitations Act of Alberta. .

4. Security of Personal Information

We recognize our legal obligations to protect personal information during the course of our business. We have therefore made arrangements to secure against the unauthorized access, collection, use, disclosure, copying, modification, disposal or destruction of personal information.

5. Requests for Access to Personal Information

The law permits individuals, including employees, to submit written requests to us to provide them with: - their personal information under our custody or control; - information about the purposes for which their personal information under our custody or control has been and is being used by us; and - the names of persons to whom, and the circumstances in which, their personal information has been and is being disclosed by us. We will respond to requests in the time allowed by the Act and will make a reasonable effort to assist applicants and to respond as accurately and completely as reasonably possible. All requests may be subject to any fees and disbursements the law permits us to charge. An employee’s ability to access his or her personal information under our control is not absolute. The law provides that we must not disclose personal information where: - the disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request; - the disclosure would reveal personal information about another individual; or - the disclosure would reveal the identity of an individual who has in confidence provided us with an opinion about another individual and the individual providing the opinion does not consent to the disclosure of his or her identity. The current law further provides that we may choose not to disclose personal information where: - the personal information is protected by any legal privilege; - the disclosure of the information would reveal confidential commercial information and it is not unreasonable to withhold that information; - the personal information was collected by us for an investigation or legal proceeding; - the disclosure of the personal information might result in similar information no longer being provided to us when it is reasonable that it would be provided; - the personal information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act under an agreement, under an enactment, or by a court, or - the personal information relates to or may be used in the exercise of prosecutorial discretion. The Act indicates that it is not to be applied so as to affect any legal privilege. We will not disclose information that is privileged where the applicant is not the client in whom the privilege is vested. In the course of the conduct of business such as ours, the application of privilege such as this will be rare.

6. Requests for Correction of Personal Information

The law permits individuals, including employee’s to submit written requests to us to correct errors or omissions in their personal information that is in our custody or control. We will: - correct the personal information and, if reasonable to do so, send correction notifications to any other organization to whom we disclosed the incorrect information; or - decide not to correct the personal information but annotate the personal information that a correction was requested but not made.

7. Contacting or Communication with Us

If you have any questions with respect to our policies concerning the handling of your personal information, or if you wish to request access to, or correction of, your personal information under our care and control, please contact our Privacy Officer at: Alexis Misner C/O 201, 3939 50A, Avenue, Red Deer, Alberta, T4N 4E6 or by e-mail at aledamassagetherapy@gmail.com. I you are dissatisfied with our handling of your personal information, we invite you to contact our Privacy Officer in writing, setting out the reasons for your concern. If you remain dissatisfied after our Privacy Officer has reviewed and responded to your concern, you may wish to contact the Office of the Information and Privacy Commissioner at: 410, 9925 - 109 Street Edmonton, Alberta T5K 2J8 Telephone (780) 422-8860 or Fax (780) 422-5682 NOTICE: The provisions of the policy may be amended from time so as circumstances and procedures in Aleda Massage Therapy change so as to stay in compliance with the requirements of the Act. All staff and others are invited to contribute to the revision of this policy by bringing questions, concerns and making observations to the attention of Alexis Misner (Privacy Officer). All staff are responsible for reading the Policies as amended from time to time and for staying familiar with their requirements. Breaches of these policies or of the Act by an employee or other staff member of Aleda Massage Therapy may be considered as grounds for dismissal. References to Acts and Regulations and to sections thereof may be amended by act of Parliament and/or the Legislature and the references contained herein include reference to such acts and regulations as may be amended from time to time. THE UNDERSIGNED HEREBY ACKNOWLEDGES THAT THEY HAVE BEEN PROVIDED WITH A COPY OF THE WITHIN SCHEDULE 'B' THIS ______DAY OF ________, A.D. 20____.

(Print Name Below)______________________________________