Corporate Privacy Code
OUR COMMITMENT TO YOUR PRIVACYBrenntag Canada is committed to respecting your privacy, and providing a secure environment in which you can participate in on-line activities is important to us. This Privacy Code discloses our privacy practices and expresses our commitment to keeping you informed of the information we collect and how it is used.
Brenntag Canada has developed a corporate privacy code in accordance with the Model Code of Fair Information Practices designed by the Canadian Standards Association, and the requirements of the Personal Information Protection and Electronic Documents Act (Canada).
Brenntag will review its Privacy Code at least every five years to ensure it is relevant and remains current with changing technologies and laws and the evolving needs of the organization and its customers and partners.
Scope and Application of the Privacy Code
The Brenntag Privacy Code (hereinafter referred to as the “Code”) applies to personal information about Brenntag customers and business partners that is collected, used, or disclosed by Brenntag.
The Code applies to the management of personal information in any form whether oral, electronic, or written;
The Code does not impose any limits on the collection, use, or disclosure of the following information by the organization:
- information that is publicly available, such as a customer or business partner’s name, address, telephone number and electronic address, when listed in a directory or made available through directory assistance; or
- the name, title or business address or telephone number of any employee of an organization.
The application of the Code is subject to the requirements or provisions of any applicable legislation, regulations or agreements, or order or any court or other lawful authority.
Definitions
collection – the act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.
consent – voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically, or in writing, but is always unequivocal and does not require any inference on the part of Brenntag. Implied consent is consent that can reasonably be inferred from an individuals’ action or inaction.
disclosure – making personal information available to a third party.
personal information – information about an identifiable individual but not aggregated information that cannot be associated with a specific individual. For a customer, such information includes credit information, billing records, ordering requirements, service and equipment history, and any recorded complaints.
third party – an individual other than the customer, business partner, or agent or organization outside Brenntag.
use – the treatment, handling and management of personal information by and within Brenntag.
Summary of Principles
The ten principles that form the basis of the Code are interrelated and Brenntag will adhere to the ten principles as a whole. The objective of the code is to ensure responsible and transparent practices in the management of personal information, in accordance with the national standard and federal legislation.
Principle 1 –Accountability
Brenntag is responsible for personal information under its control. The Director, Human Resources & Communications is accountable for the company’s compliance with the Code.
Principle 2 - Identifying Purposes for Collection of Personal Information
Brenntag shall identify the purposes for which personal information is collected at or before the time the information is collected.
Principle 3 - Obtaining Consent for Collection, Use, or Disclosure of Personal Information
The knowledge and consent of a customer or business partner are required for the collection, use or disclosure of personal information, except where inappropriate.
Principle 4 – Limiting Collection of Personal Information
Brenntag shall limit the collection of personal information to that which is necessary for the purposes identified by the company.
We collect different types of information about visitors to our website that include personal information such as name and email address, and aggregate information which includes how many visitors log onto to our site, pages accessed, etc.
Personal information that you may voluntarily submit to us during the use of our site and services is treated as confidential information and may be used to respond to your comments or to contact you with respect to order processing. In addition, we may use personal information to identify products and services to meet the needs of our customers and partners. We will not use it for secondary purposes or divulge it to third parties, except as may be directed by appropriate law enforcement and/or legislative requirements.
Brenntag shall collect all personal information by fair and lawful means.
Automatic Information -“Cookies”
When you log-on or use any of the on-line services available at our website, our web servers technology makes use of ‘cookies’ as part of the normal functioning of the website. Brenntag may use such ‘cookie’ technology to obtain non-personal information from you, as an on-line visitor, to manage visitor identification, authentication, security, and to facilitate efficient browsing of the site. We will not divulge any ‘cookie’ information to third parties, except as may be directed by appropriate law enforcement and/or legislative requirements.
Principle 5 – Limiting Use, Disclosure and Retention of Personal Information
Brenntag shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Brenntag shall retain personal information only as long as necessary for the fulfillment of the purposes for which it was collected.
Principle 6 – Accuracy of Personal Information
The personal information that Brenntag maintains shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
Principle 7 - Security Safeguards
Brenntag shall protect personal information through the use of security safeguards appropriate to the sensitivity of the information.
We take every precaution to protect our users’ information both online and off line. User information is stored on servers in a locked, secure environment. Our servers are protected from hackers with firewalls and a variety of other security mechanisms and procedures. Only our employees and authorized technological contractors who maintain our servers, have access to the communications and related data, responses and reports that we may store as part of our on line services.
All employees and contractors with access to the information have signed a non-disclosure agreement and are trained in our security and privacy practices.
Our web site contains links to other sites. Please be aware that Brenntag Canada is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of each and every web site that collects personally identifiable information. This privacy statement applies solely to information collected by the Brenntag Canada web site.
Principle 8 – Openness Concerning Policies and Practices
Brenntag shall make readily available to customers and employees specific information about its politics and practices relating to its management of personal information.
Principle 9 – Customer Access to Personal Information
Brenntag shall inform a customer or business partner of the existence, use and disclosure of his/her personal information upon request and shall give the individual access to that information. A customer or business partner may be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Principle 10 – Challenging Compliance
A customer or business partner shall be able to address a challenge concerning compliance with the above principles to the person accountable for Brenntag’s compliance with this Code. Brenntag Canada will investigate all complaints as quickly as possible and, if a complaint is found to be justified, Brenntag will take all reasonable steps to resolve the matter.
Any questions concerning compliance with the Brenntag Privacy Code should be addressed to: Chief Privacy Officer, Brenntag Canada Inc., 43 Jutland Road, Toronto, Ontario, Canada or phone 416-259-8231.
January 2005
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