download as PDF:  click here

Privacy Policy

SMART DM adheres to the basic principles of Canada ’s Privacy Legislation – The Personal Information Protection and Electronic Documents Act (PIPEDA) which was enacted January 1, 2004. This act addresses major themes, the collection, use and disclosure of personal information – and is structured according to basic principles.

Personal information is considered to be any information about an individual which can include name, address, social insurance number or any information considered relevant for the delivery of our services.

Accountability

SMART DM acknowledges that it is responsible for the personal information under it’s control. SMART DM has designated a Privacy/Security Officer who is accountable for the organizations adherence with these principles.

SMART DM acknowledges that it is responsible for personal information in it’s possession or custody. As a mail service provider, this includes all information that has been transferred to SMART DM acting as a third party for processing and/or mailing.

SMART DM will also make available to clients and/or prospects our privacy policy as well as information on PIPEDA to ensure that all parties involved have a clear understanding of the PIPEDA and their respective responsibilities.

Identifying Purposes

In a situation where SMART DM either collects on it’s behalf, or on it’s clients behalf, personal information – then SMART DM shall identify the purpose of this collection at or before the time the information is collected.

Consent and Disclosure.

SMART DM shall, within reason, verify that our client has obtained consent for SMART DM to process their information. SMART DM shall track and record the type of consent obtained by the client.

Limiting Collection

The collection of SMART DM shall be limited to the purposes identified by SMART DM or it’s client. Information shall be collected by fair and lawful means.

Limiting Use, Disclosure and Retention

SMART DM acknowledges that personal information shall 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. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.  

Accuracy

SMART DM shall implement processes and other safeguards to ensure that the accuracy of the information they process is maintained to the highest possible standards.  These processes include:

• provision of counts and dumps to clients prior to processing to verify accuracy

• provision of “lives” of personal information to client prior to mailing to verify accuracy

• provision of sign-offs that includes comparison of original data to processed data to ensure accuracy

• varying levels of sign-offs by client and account management staff prior to processing, imaging or mailing of personal information to ensure accuracy

Safeguards

SMART DM shall implement all reasonable safeguards to ensure that client information entrusted to SMART DM is protected against accidental disclosure, unauthorized publication, damage, or other breach of privacy. These safeguards are outlined in SMART DM’s corporate security policy. Some of these safeguards include the use of secure Internet servers, restricted file access and use of technological safeguards such as security software, firewalls and physical security measures.

Openness

SMART DM shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.

Individual Access

SMART DM shall make provision for clients to provide individuals access to their personal and private information – as to the existence, use and disclosure of this information – within 10 days of an individual request.

An individual’s right to access is not absolute. SMART DM may deny access where required or authorized by law, or information relates to existing or anticipated legal proceedings, or granting access would have an unreasonable impact on other people’s privacy or to protect our company’s rights and property. If SMART DM must deny a request for information – a full explanation will be provided by our Privacy Officer.

Challenging Compliance

SMART DM shall have procedures in place to receive and respond to complaints or inquiries about their policies and practices relating to the handling of personal information.

Contact

If you wish to contact our privacy officer – you may do one of the following:

By telephone: 416 461 9271 Ext 4211
By Fax: 416 461 9201

E-Mail: privacyofficer@smartdm.ca

By Mail:           

SMART DM
Attention: Privacy Officer
324 Horner Ave , Unit A
Etobicoke , Ontario     M8W 1Z3

CMA Membership Responsibilities

As a 30 year member of the Canadian Marketing Association, SMART DM also incorporates five additional principles in addition to the federal legislation.

These are:

1. The CMA mandates that the meaningful opportunity for consumers to decline further marketing use of theirname or other information must be repeated once every three years at a minimum.
    

2. All CMA members must use the Do Not Contact service of the Association in their customer acquisition activities. (SMART DM offers this service to all clients)
    

3. CMA members are obliged to provide consumers with the source of their name, upon request.
    

4. CMA member companies are strongly encouraged to adopt a list rental policy which restricts rental of information to companies which agree to comply with the CMA’s Privacy Code.
    

5. By January 1, 2004, CMA members must offer existing or current customers an opportunity to opt-out of future marketing offers or solicitations that are unrelated to the original purchase. All opt-out opportunities must be easy to understand, easy to see and easy to execute.