Smartset Mobile Hairdressers LTD.

    Personal Information Protection Policy

At Smartset Mobile Haidressers Ltd, we are committed to providing our customers, facilities, members with exceptional service.  As providing this service involves the collection, use and disclosure of some personal information about our customers, facilities, members, protecting their personal information is one of our highest priorities.

While we have always respected our customers, facilities, members privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA).  PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our customers, facilities, members of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their 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 customers’, facilities’, members’ personal information.  Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our customers’, facilities’, members’ personal information and allowing our customers, facilities, members to request access to, and correction of, their personal information.

Scope of this Policy

This Personal Information Protection Policy applies to Smartset Mobile Hairdressers Ltd. and it’s subsidiaries.

This policy also applies to any service providers or members collecting, using or disclosing personal information on behalf of Smartset Mobile Hairdressers Ltd.

Definitions

Personal Information –means information about an identifiable individual [E.g., including name, age, home address and phone number, social insurance number, bank information, income, education, employment information, service preferences, service periods, room numbers, payment methods].  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 Smartset Mobile Hairdressers Ltd. complies with this policy and PIPA.

Policy 1 – Collecting Personal Information

1.1  Unless the purposes for collecting personal information are obvious and the customer, facility, member 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 upon request.

1.2  We will collect customer, facility, member information that is necessary to fulfill the following purposes listed below but not limited to:

• To verify identity;
• To verify creditworthiness;
• To identify [customer, facility, member] preferences;
• To understand the [financial, banking, insurance] needs of our [customers, facilities, members];
• To open and manage an account;
• To deliver requested products and services;
• To bill customers serviced on account back to facilities;
• To collect and manage historical financial and operating data;
• To process sales and sales related payroll services;
• To provide [medical, dental] services;
• To contact our [customers, facilities, members]
• To ensure a high standard of service to our [customers, facilities, members];
• To meet regulatory requirements;
• To collect and process rent payments;
• To collect and reimbursable employee expenses;

Policy 2 – Consent

2.1  We will obtain customer, facility, member 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 orally or in writing, on our website, by email or by phone or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the customer, facility, member voluntarily provides personal information for that purpose.

2.3  Consent may also be implied where a [customer, facility, member] has been [provided service, under contract, employed] and has not otherwise stated at the time of service, contract or employment otherwise.

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), customers, facilities, members can withhold or withdraw their consent for Smartset Mobile Hairdressers Ltd. to use their personal information in certain ways.  A client’s, customer’s, member’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 customer, facility, member in making the decision.

2.5  We may collect, use or disclose personal information without the client’s, customer’s, member’s knowledge or consent as set forth by the Office of the Information & Privacy Commission for British Columbia PIPA (Private Sector) Act in sections 12, 13, 15, 16, 18 and 19, in addition but limited to:

• In order to facilitate and record business transactions;
• 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 customer, facility, member 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 conduct customer, facility, member surveys in order to enhance the provision of our services;
• To contact our [customers, facilities, members] directly about products and services that may be of interest;
• In order to facilitate and record business transactions

3.2  We will not sell customer, facility, member lists or personal information to other parties [unless we have consent to do so].

Policy 4 – Retaining Personal Information

4.1  If we use customer, facility, member personal information to make a decision that directly affects the customer, facility, member, we will retain that personal information for at least one year so that the customer, facility, member has a reasonable opportunity to request access to it.

4.2  Subject to policy 4.1, we will retain customer, facility, member 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 customer, facility, member personal information is accurate and complete where it may be used to make a decision about the customer, facility, member or disclosed to another organization.

5.2  Customers, facilities, members may request correction to their personal information in order to ensure its accuracy and completeness.  A request to correct personal information can be made in writing or orally and provide sufficient detail to identify the personal information and the correction being sought.

Policy 6 – Securing Personal Information

6.1  The following security measures will be followed to ensure that customer, facility, member personal information is appropriately protected:

• the use of user IDs & passwords,
• SSL host encryption,
• Third-party firewalls;
• restricting employee access to personal information as appropriate (i.e., only those that need to know will have access; contractually requiring any service providers to provide comparable security measures].

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

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

Policy 7 – Providing Customers, facilities, members Access to Personal Information

 7.1  Customers, facilities, members have a right to access their personal information, subject to limited exceptions:

(a) the information is protected by solicitor-client privilege;

(b) the disclosure of the information would reveal confidential commercial information that if disclosed, could, in the opinion of a reasonable person, harm the competitive position of the organization;

(c) the information was collected or disclosed without consent, as allowed under section 12 or 18 of the PIPA Act, for the purposes of an investigation and the investigation and associated proceedings and appeals have not been completed;

(e) the 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

(i) under a collective agreement,

(ii) under an enactment, or

(iii) by a court;

(f) the information is in a document that is subject to a solicitor's lien.

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 customers, facilities, members 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 customer, facility, member of the cost and request further direction from the customer, facility, member 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 customer, facility, member in writing or orally, providing the reasons for refusal and the recourse available to the customer, facility, member.

Policy 8 – Questions and Complaints:  The Role of the Privacy Officer or designated individual

8.1  The Privacy Officer or designated individual is responsible for ensuring Smartset Mobile Hairdressers Ltd.’s compliance with this policy and the Personal Information Protection Act.

8.2  Customers, facilities, members should direct any complaints, concerns or questions regarding Smartset Mobile Hairdressers Ltd.’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer, facility, member may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for Smartset Mobile Hairdressers Ltd.’s Privacy Officer or designated individual:

Aaron Bromley

PO Box 80039

Burnaby, BC

V5H 3X1

T: 604-736-5558

F: 604-736-5598