Privacy Policy

Personal Information And Electronic Documents Act (PIPEDA)


• SpringBoard will comply with all 10 principles of the Privacy Act.
• The General Manager is responsible for SpringBoard compliancy with the Act.
• SpringBoard will protect all information collected in the conduct of doing business.
• SpringBoard will only share employee or client information with our authorized service providers
that perform certain services or functions on our behalf, as required by law. SpringBoard does
not sell or rent any personal information to anyone.
• SpringBoard makes every reasonable attempt to correct client information and keep private
records in our databases up to date.
• SpringBoard keeps all paper files in locked storage for up to two years, after which time the files
are shredded to ensure that all personal information is destroyed.
• What personal information do we collect?
a. Name
b. Gender
c. Home contact information
d. Business contact information
e. Preferred place of correspondence
f. Date of birth
g. Dates on which pertinent information was sent out
h. Credit card number
i. Banking Information


Identify The Purpose – SpringBoard collects personal information to administer payroll or to write
and publish articles.
The information is generally collected by the following means:
• Verbally, over the telephone.
• Electronically, via e-mail.
• Written, written correspondence and faxes.
• Face to face during meetings or open houses


Consent – The knowledge and consent of the person to which the personal information relates is
required for the collection, use or disclosure of such personal information, except where otherwise
required or permitted by law. Personal information collected directly by SpringBoard is collected in
order conduct business transactions.


Limiting Collection – SpringBoard limits the collection of personal information to that which is
necessary to fulfill our business purposes and responsibilities. To this end, the Privacy Officer has
been tasked with the responsibility of reviewing, on a random audit basis, the personal information
being requested by our clients and has the authority to require changes where it is determined that
the collection of such information is not necessary for the purpose. Furthermore, SpringBoard
regularly reviews the personal information that has been collected to determine what information is no
longer required and to delete such information from our records.


Limiting Use, Disclosure and Retention – SpringBoard takes all reasonable steps to ensure that
all personal information collected is done with the knowledge of the individual to whom it relates and
is used only for the purpose collected, unless otherwise required or permitted by law. SpringBoard
does not sell personal information to any third parties.


Accuracy – Decisions are often made based on the information we have. Therefore, SpringBoard
uses its best efforts to ensure that all personal information collected and maintained is accurate,
complete and up-to-date. To assist us in keeping your personal information up-to-date, we encourage
you to provide us with up-to-date information in order to help us ensure such accuracy. Should we
identify any incorrect or out-of-date information in your file, we will advise you and make the proper


Safeguarding Personal information – In addition to ensuring that it complies with all of its obligations
with respect to the collection, use and distribution of personal information, SpringBoard is responsible
for ensuring that all personal information maintained is safeguarded against unauthorized access or
release. SpringBoard uses current technologies and maintains security standards to ensure that
your personal information is protected against unauthorized access, disclosure, inappropriate
alteration or misuse. Electronic client files are kept in a secured environment with restricted access.
Paper-based files are also stored in restricted access areas.
We manage our server environment appropriately and our firewall infrastructure is strictly adhered to.
Our security practices are reviewed periodically, and we employ current technologies to assist us in
protecting the confidentiality and privacy of your information.
During daily operations, we attempt to restrict access to personal information to authorized employees
who have a legitimate business purpose and reason for accessing it. As a condition of their
employment, all employees are required to abide by the privacy standards we have established and
to follow all applicable laws and regulations. Employees are also required to work within the principles
and ethical behaviour as set out in our internal Company Policy Manual. Employees are informed
about the importance of privacy and they are required to sign a confidentiality agreement that prohibits
the disclosure of any customer information to unauthorized individuals or parties. Unauthorized
access to and/or disclosure of customer information by an employee is strictly prohibited. All
employees are expected to maintain the confidentiality of personal information at all times and failing
to do so will result in appropriate disciplinary measures, which may include dismissal.


Disclosure – Any proposed use of personal information other than in the ordinary course of our
business will be disclosed at the time it is collected or prior to such use, and only with the specific
consent of the person to which such information relates. In addition to making its Privacy Policy
available on its website, a paper copy of it may be obtained upon written request to the Privacy Officer
at the address set out below.


Customer Access – As a customer or an employee, you have the right to access, verify and amend
the information held in your personal files. Upon request, a customer shall be informed of the
existence, use and disclosure of their personal information, and shall be given access to it.
It is SpringBoard’ desire that customers continuously verify the accuracy and completeness of their
personal information and may request that it be amended at any time.
Handling Customer and Employee Complaints and Suggestions- Customers may direct any
questions, enquiries, or complaints with respect to SpringBoard privacy practices and procedures,
this Privacy Policy or our information handling practices, to our Privacy Officer who may be contacted

SpringBoard Data Management
Attention: Ross McLeod – Privacy Officer