The Ten Principles of Privacy

Principle 1 - Accountability

R.I.S. CHRISTIE is responsible for personal information under its control and shall designate one or more persons who are accountable for our compliance with these principles.

Responsibility for compliance with the provisions of the Privacy Policy rests with R.I.S. CHRISTIE’s Privacy Officer who can be reached by e-mail at: or by mail at: R.I.S. Christie, 14 Verral Avenue, Toronto, Ontario, M4M 2R2. Other individuals within the company may be delegated as/if appropriate to act on behalf of the Privacy Officer or to take responsibility for the day-to-day collection and/or processing of personal information.

R.I.S. CHRISTIE is responsible for personal information in its possession or control and shall use contractual or other means to provide a comparable level of protection while information is being processed or used by a third party.

Principle 2 - Identifying Purposes

R.I.S. CHRISTIE will identify the purposes for which personal information is collected at or before the time the information is collected.

We collect personal information from the public only for the following purposes:

(a) to conduct quantitative or qualitative marketing and social research;

(b) to understand respondent opinions to establish suitability for further quantitative and qualitative marketing and social research; and

(c) to meet legal and regulatory requirements.

Further reference to “identified purposes” mean the purposes identified in this Principle.

We shall specify to the respondent orally, electronically or in writing, the identified purposes of the survey at or before the time personal information is collected in a survey. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within R.I.S. CHRISTIE who can explain the purposes.

When personal information that has been collected is to be used or disclosed for a purpose not previously identified, then the new purpose shall be identified prior to use. Unless the new purpose is permitted or required by law, the consent of the respondent will be acquired before the information will be used or disclosed for the new purpose.

R.I.S. CHRISTIE may provide clients or other third parties with information from any survey, in aggregate form. In aggregate form it is impossible to identify an individual respondent’s personal information.

Principle 3 - Obtaining Consent

The knowledge and consent of an individual are required for the collection, use, or disclosure of personal information, except where inappropriate.

Participation by respondents in survey research is always voluntary. When a respondent agrees to participate in a survey, he/she gives consent to the interview by participating.

Generally, any personal information collected in the course of an interview is not disclosed to third parties. However, occasionally, a client sponsoring a research project may want to contact respondents directly. In these cases, R.I.S. CHRISTIE will always explain the reason for the disclosure to the respondent and obtain express permission from the respondent, prior to making any such disclosure.

A respondent is always free to choose whether or not to participate in a survey, free to choose not to answer any specific questions and free to discontinue participation at any time. In obtaining consent, R.I.S. CHRISTIE shall use reasonable efforts to ensure that a respondent is advised of the identified purposes for which personal information will be used or disclosed. The identified purposes shall be stated in a manner that can be reasonably understood by the respondent.

Generally, we shall seek consent to use and disclose personal information at the same time we collect the information. However, R.I.S. CHRISTIE may seek consent to use and/or disclose personal information after it has been collected, but before it is used and/or disclosed for a new purpose.

In determining the appropriate form of consent, we take into account the sensitivity of the personal information and the reasonable expectations of its respondents.

The participation of a respondent in a quantitative or qualitative marketing or social research study may constitute implied consent for us to collect, use and disclose personal information for the identified purposes.

Principle 4 - Limiting Collection

R.I.S. CHRISTIE will limit the collection of personal information to that which is necessary for the purposes identified. We will collect personal information by fair and lawful means.

In conducting surveys, R.I.S. CHRISTIE limits the amount and type of personal information it collects. We collect only the amount and type of information needed for the purposes identified to individuals.

We collect personal information about an individual primarily from that individual or a member of that individual’s household. Except as permitted by law, we will only collect personal information from external sources, such as client organizations, if individuals have consented to such collection.

Principle 5 - Limiting Use, Disclosure, and Retention

Personal information will 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 or permitted by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes.

We may disclose a respondent’s personal information to:

(a) a client of R.I.S. CHRISTIE where the respondent has consented to such disclosure;

(b) a third party engaged by R.I.S. CHRISTIE to perform functions on its behalf;

(c) a public authority or agent of a public authority if, in our reasonable judgment it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or

(d) a third party or parties, where the respondent consents to such disclosure or disclosure is required or permitted by law.

Only R.I.S. CHRISTIE employees with a business need-to-know, or whose duties reasonably require, are granted access to personal information about respondents.

We will keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where a respondent may have to be re-contacted for purposes of clarifying responses to a survey, or to seek additional responses, R.I.S. CHRISTIE will retain the personal information for a period of time that is reasonably sufficient to allow this re-contact.

We will maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.

Principle 6 - Accuracy

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Personal information used by R.I.S. CHRISTIE will be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a respondent.

We will update personal information about respondents and employees as necessary to fulfill the identified purposes or upon notification by the individual.

Principle 7 - Security Safeguards

R.I.S. CHRISTIE will protect personal information by security safeguards appropriate to the sensitivity of the information.

We will protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held.

We will protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

All of R.I.S. CHRISTIE’s employees with access to personal information shall be required to respect the confidentiality of that information.

Principle 8 - Openness

R.I.S. CHRISTIE will make specific information about its policies and procedures relating to the management of personal information readily available to individuals.

We will make information about its policies and procedures easy to understand, including:

(a) the title and address of the person or persons accountable for compliance with our Privacy Policy, and to whom inquiries and/or complaints can be forwarded;

(b) the means of gaining access to personal information held by R.I.S. CHRISTIE;

(c) a description of the type of personal information held by the company, including a general account of its use; and

(d) a description of what personal information is made available to related organizations (e.g. subsidiaries).

Principle 9 – Individual Access

Upon request, R.I.S. CHRISTIE willl inform an individual of the existence, use, and disclosure of his or her personal information and shall give the individual access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Upon written request to our Privacy Officer, we will inform an individual of the existence, use and disclosure of his/her personal information and shall be given access to that information

In certain situations, R.I.S. CHRISTIE may not be able to provide access to all the personal information that it holds about a respondent. For example, we may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, we may not provide access to information if disclosure would reveal confidential commercial information.

In order to safeguard personal information, a respondent may be required to provide sufficient identification information to permit us to account for the existence, use and disclosure of personal information and to authorize access to the individual’s file. Any such information shall be used only for this purpose.

R.I.S. CHRISTIE will promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file. Where appropriate, we shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.

Respondents and employees can obtain information or seek access to their individual files by contacting R.I.S. CHRISTIE’s Privacy Officer.

Principle 10 - Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designated person accountable for R.I.S. CHRISTIE’s compliance with the company’s Privacy Policy.

We will maintain procedures for addressing and responding to all inquiries or complaints from our respondents regarding our handling of personal information.

We will, on written request, inform our respondents about the existence of these procedures as well as the availability of complaint procedures.

The person or persons accountable for compliance with R.I.S. CHRISTIE’s Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

R.I.S. CHRISTIE will investigate all complaints concerning compliance with its Privacy Policy. If a complaint is found to be justified, we will take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. The respondent will be informed of the outcome of the investigation regarding his or her complaint.

Additional Information

For more information regarding R.I.S. CHRISTIE’s Privacy Policy, please contact our Privacy Officer by e-mail at: , or by mail at: Privacy Officer, R.I.S. Christie, 14 Verral Avenue, Toronto. Ontario, M4M 2R2.

Please visit the Privacy Commissioner of Canada’s website at http://www.privcom.gc.ca www.privcom.gc.ca.