Overview

At Harris/Decima, respecting privacy is an important part of our commitment to respondents and the general public.

When you participate in survey research conducted by our organization, you can be confident that any personal information that you share with us will stay with us.

Any time you participate as a respondent in one of our surveys, whether in person or by telephone, mail or Internet, you can be assured that your individual responses will be kept confidential and never linked to your personal identifying information without your express permission. Your personal identifying information will never be sold to anyone. You are 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.

The Harris/Decima Privacy Policy is a statement of principles and guidelines describing the level of protection of personal information provided by Harris/Decima to respondents and the general public. The objective of the Harris/Decima Privacy Policy is to promote responsible and transparent personal information management practices in a manner consistent with the provisions of the Personal Information Protection and Electronic Documents Act (Canada).

Harris/Decima will continue to review its Privacy Policy to make sure that it is relevant and remains current with changing industry standards, technologies and laws.

Harris/Decima is a member of the Canadian Association of Market Research Organizations (CAMRO) and of the Canadian Survey Research Council (CSRC). These organizations set standards to which members must adhere and which also protect your privacy.

If you have any concerns about how your privacy is protected at Harris/Decima, please contact our Privacy Officer by e-mail at privacy@harrisdecima.com or by mail at:

• Privacy Officer, Harris/Decima
  160 Elgin Street, Suite 1820 Ottawa, Ontario K2P 2P7

Scope and Application

The ten principles that form the basis of Harris/Decima's Privacy Policy are interrelated and Harris/Decima shall adhere to the ten principles as a whole. Each principle must be read in conjunction with the accompanying commentary. As permitted by the Personal Inomation Protectionand Electronic Documents Act (Canada), the commentary in Decima Research Inc's. Privacy Policy has been drafted to reflect personal information issues specific to Harris/Decima

The scope and application of Harris/Decima Privacy Policy are as follows:

• Harris/Decima's Privacy Policy applies to personal information collected, used, or disclosed by Harris/Decima in the course of commercial activities.
• Harris/Decima's Privacy Policy applies to the management of personal information in any form whether oral, electronic or written.
• Harris/Decima's Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by Harris/Decima:
  1. non-personally identifiable information;
  2. the name, title, business address and/or telephone number of an employee of an organization;
  3. other information about an individual that is publicly available and is specified by regulation pursuant to the Personal Information Protection and Electronic Documents Act (Canada).
• The application of Harris/Decima's Privacy Policy is subject to the requirements and provisions of the Personal Information Protection and Electronic Documents Act (Canada), the regulations enacted there under, and any other applicable legislation or regulation.

Definitions

collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.

consent: Voluntary agreement for 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 Harris/Decima Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.

disclosure: Making personal information available to a third party.

employee: An employee of or independent contractor to Harris/Decima

personal information: Information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization, and does not include descriptive, factual information about an organization.

respondent: A member of the public who provides personal information to Harris/Decima in the course of research conducted by Harris/Decima For example, a respondent is an individual who discloses personal information to Harris/Decima in the course of quantitative or qualitative marketing or social research.

third party: An individual or organization outside of Harris/Decima

use: The treatment, handling, and management of personal information by and within Harris/Decima or by a third party with the knowledge and approval of Harris/Decima

The Ten Principles of Privacy

Principle 1 - Accountability

Harris/Decima is responsible for personal information under its control and shall designate one or more persons who are accountable for Harris/Decima's compliance with the following principles.

Responsibility for compliance with the provisions of the Harris/Decima Privacy Policy rests with Harris/Decima's Privacy Officer who can be reached by e-mail at privacy@harrisdecima.com or by mail at:

• Privacy Officer, Harris/Decima
  160 Elgin Street, Suite 1820, Ottawa, ON K2P 2P7

Other individuals within Harris/Decima may be delegated to act on behalf of the Privacy Officer or to take responsibility for the day-to-day collection and/or processing of personal information.

Harris/Decima 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 for Collection of Personal Information

Harris/Decima shall identify the purposes for which personal information is collected at or before the time the information is collected.

Harris/Decima collects personal information from the public only for the following purposes:

1. to conduct quantitative or qualitative marketing and social research;
2. to understand respondent opinions to establish suitability for further quantitative and qualitative marketing and social research; and
3. to meet legal and regulatory requirements.

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

Harris/Decima shall specify orally, electronically or in writing the identified purposes to the respondent 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 Harris/Decima who can explain the purposes.

When personal information that has been collected is to be used or disclosed for a purpose not previously identified, 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.

Harris/Decima 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 for Collection, Use or Disclosure of Personal Information

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, Harris/Decima always explains the reason for the disclosure to the respondent and obtains express permission from the respondent before 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, Harris/Decima 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, Harris/Decima shall seek consent to use and disclose personal information at the same time it collects the information. However, Harris/Decima 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, Harris/Decima shall 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 Harris/Decima to collect, use and disclose personal information for the identified purposes.

Principle 4 - Limiting Collection of Personal Information

Harris/Decima shall limit the collection of personal information to that which is necessary for the purposes identified by Harris/Decima Harris/Decima shall collect personal information by fair and lawful means.

In conducting surveys, Harris/Decima 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.

Harris/Decima collects personal information about an individual primarily from that individual or a member of that individual’s household. Except as permitted by law, Harris/Decima 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 of Personal Information

Harris/Decima 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 or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

Harris/Decima may disclose a respondent’s personal information to:

1. a client of Harris/Decima where the respondent has consented to such disclosure;
2. a third party engaged by Harris/Decima to perform functions on its behalf;
3. a public authority or agent of a public authority if, in the reasonable judgment of Harris/Decima, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or
4. a third party or parties, where the respondent consents to such disclosure or disclosure is required or permitted by law.

Only Harris/Decima's employees with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about respondents.

Harris/Decima shall 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, Harris/Decima shall retain the personal information for a period of time that is reasonably sufficient to allow this re-contact.

Harris/Decima shall 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 of Personal Information

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 Harris/Decima shall 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.

Harris/Decima shall update personal information about respondents and employees as necessary to fulfill the identified purposes or upon notification by the individual.

Principle 7 - Security Safeguards

Harris/Decima shall protect personal information by security safeguards appropriate to the sensitivity of the information.

Harris/Decima shall 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.

Harris/Decima shall 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 Harris/Decima 's employees with access to personal information shall be required to respect the confidentiality of that information.

Principle 8 - Openness Concerning Policies and Procedures

Harris/Decima shall make readily available to individuals specific information about its policies and procedures relating to the management of personal information.

Harris/Decima shall make information about its policies and procedures easy to understand, including:

1. the title and address of the person or persons accountable for Harris/Decima’s compliance with its Privacy Policy and to whom inquiries and/or complaints can be forwarded;
2. the means of gaining access to personal information held by Harris/Decima;
3. a description of the type of personal information held by Harris/Decima, including a general account of its use; and
4. a description of what personal information is made available to related organizations (e.g. subsidiaries).

Principle 9 – Individual Access to Personal Information

Upon request, Harris/Decima shall 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 the Privacy Officer, Harris/Decima 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, Harris/Decima may not be able to provide access to all the personal information that it holds about a respondent. For example, Harris/Decima 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, Harris/Decima 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 Harris/Decima 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.

Harris/Decima shall 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, Harris/Decima 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 the Harris/Decima 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 or persons accountable for Harris/Decima’s compliance with the Harris/Decima Privacy Policy.

Harris/Decima shall maintain procedures for addressing and responding to all inquiries or complaints from its respondents regarding Harris/Decima’s handling of personal information.

Harris/Decima shall, on written request, inform its respondents about the existence of these procedures as well as the availability of complaint procedures.

The person or persons accountable for compliance with the Harris/Decima Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

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

Additional Information

For more information regarding the Harris/Decima Privacy Policy, please contact the Harris/Decima Privacy Officer by e-mail at privacy@harrisdecima.com or by mail at:

• Privacy Officer, Harris/Decima
  160 Elgin Street, Suite 1820, Ottawa, ON K2P 2P7

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