CANADA PRIVACY ADDENDUM  

1.     Commitment and Scope

1.1     This Canada Privacy Addendum supplements the information contained in the Global Privacy Policy and our Fair Processing Notice.

1.2     Charles Taylor complies with the requirements of the following statues in Canada with regards to the collection, storage, processing and disclosure of personal information and is committed to upholding the core data protection principles:

•    Federal: Personal Information Protection and Electronic Documents Act 2000 (PIPEDA)
•    British Columbia: Personal Information Protection Act, SBC 2003 c 62 (BC PIPA)
•    Alberta: Personal Information Protection Act, SA 2003 c P-6.5 (AB PIPA)
•    Quebec: Act respecting the Protection of Personal Information in the Private Sector, CQLR c P-39.1 (Quebec Private Sector Act)

1.3     For those who work for Charles Taylor in Canada, the Charles Taylor Employee Privacy Notice is accessible online via our intranet.

2.     Your personal and sensitive data

2.1    Personal data is given a broad interpretation within Canadian data protection laws. Information would fit the definition of personal information where there is a serious possibility that an individual could be identified through the use of the information, alone or combined with other available information. Sensitive data is not specifically defined in Canada regulations. PIPEDA provides that any information can be sensitive depending on the context. 

2.2    We only process personal and sensitive data if and to the extent permitted or required by applicable laws in Canada, including after obtaining your separate consent if required. We will seek to protect such information and, therefore, your sensitive data should not be processed in a way that will result in negative implications to your personal rights e.g. harm to your reputation, physical or medial health, personal or property security.  

2.3    For the personal information we process, we will take appropriate security measures that correspond to the risk level of such information to prevent the loss or unlawful destruction or unauthorised disclosure of or access to personal information.

2.4    To make things simpler, Charles Taylor has nominated one entity, Charles Taylor Ltd, to handle all requests or queries you might have about our processing of your personal data. We have appointed a Data Protection Officer (DPO) to oversee compliance with data protection laws. 

You can contact our DPO at:

2 Minster Court, Mincing Lane, London EC3R 7BB
dpo@charlestaylor.com

3.    Our responsibilities

3.1    During its core business activities, Charles Taylor is instructed to process the personal data of individuals who are identified in our clients’ instructions or during the course of the investigation undertaken pursuant to such instructions. Charles Taylor will not process any personal data without first having been satisfied as to the legal bases on which to process personal data. 

3.2    To comply with the law, Charles Taylor will ensure that information processed about individuals is kept to the minimum, collected, and used fairly, be accurate, used solely for the purpose intended, stored safely, securely including protection against unauthorised or unlawful processing, loss, destruction or damage, using appropriate technical measures such as encryption or in password protected devices, retained  for no longer than necessary and not disclosed to any third party unlawfully. 

3.3   Some processing of personal data is considered high-risk, either because of the nature and volume of personal data processed or because we want to process that data using novel technology or a system or application that is new to us. Where this is the case, and where required by law, we assess the risks of the processing, how we mitigate those risks, and we document decisions taken in Data Protection Impact Assessments. 

4.    Your Privacy Rights

4.1   If you are a Canadian resident for whom we collect personal information, you may rely on the disclosures in our Global Privacy Policy and Global Fair Processing Notice. 

4.2   Under the Canadian data protection acts you are afforded the following rights regarding your personal information:

•    Right to access personal data.
•    Right to require a data user to correct personal data.
•    Right to withdraw consent to the processing of personal data.
•    Right to prevent processing likely to cause damage or distress.
•    Right to prevent processing for direct marketing purposes.
 

4.3   Charles Taylor does not process your personal information for targeted advertising purposes or carry out profiling on you or your behaviour and/or habits. You will not be discriminated against for exercising any of your data rights.

4.4   You may exercise any of the rights described by contacting our Data Protection Officer using the email address below:

     DPO@charlestaylor.com
 

5.    Transfer of your data

5.1   Our Fair Processing Notice explains the types of data we collect, how it is collected and with whom we might share your personal information.

5.2   Where personal information is transferred to an overseas third party for use by that overseas third party on behalf of Charles Taylor, or for the overseas third party’s own business purposes, Charles Taylor will remain responsible for compliance with PDPA in relation to that personal information. Please see our Global Privacy Policy and Fair Processing Notice for more information.

5.3   To ensure correct management of personal data, and to comply with many data privacy regimes around the world, we maintain records of data processing which identify key information in respect of all personal data we process. This enables us to align our privacy practices with local privacy laws. 

5.4   Any individual whose personal data we process may contact the Group DPO to request information about the types of personal data we process, the lawful basis (or bases) for that processing and how we protect their personal data. 

6.   Your right to complain

6.1  We work conscientiously to handle your personal data responsibly. If you are unhappy with the way we are doing this, please contact our DPO, who will try to address your concerns:

dpo@charlestaylor.com

6.2  You have a right to complain to the relevant data authority, as listed below:

Office of the Privacy Commissioner of Canada (OPC)
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec
K1A 1H3

Toll-free: 1-800-282-1376

Website: https://www.priv.gc.ca/en/contact-the-opc/

Office of the Information and Privacy Commissioner for British Columbia 
Office of the Information and Privacy Commissioner for British Columbia
PO Box 9038 Stn. Prov. Govt.
Victoria B.C. V8W 9A4  

Telephone: (250) 387-5629

Website: https://www.oipc.bc.ca/about/contact-us/

Office of the Information and Privacy Commissioner of Alberta (AB OIPC)
Office of the Information and Privacy Commissioner of Alberta 
410 9925-109 St, Edmonton, 
Alberta T5K 2J8, 
Canada.    

Website: https://oipc.ab.ca/about-us/contact-us/

Quebec Commission on Access to Information
Quebec Commission on Access to Information – Montreal Office
2045 Stanley Street, 
Suite 900, 
Ville-Marie, 
Montréal, 
QC, H3A 2V4

Telephone: 514 873-4196

Website: https://www.cai.gouv.qc.ca/
 

7.       Changes to this Policy

7.1   Charles Taylor reserves the right to amend this notice at our discretion and at any time. When we make changes to this notice, we will post the updated notice on the website and update the notice’s effective date. Your continued use of our services following the posting of changes constitutes your acceptance of such changes.

Last updated: January 2024