PRIVACY POLICY
Please Note: This document is also available in printed form. If you would like a printed copy, please call or visit any of our offices and request this document from reception.
CRAMER LEGAL SERVICES PRIVACY POLICY
CRAMER LEGAL SERVICES (CLS) believes strongly in protecting your privacy and the confidentiality of your Personal Information. We acknowledge that you may have privacy and security concerns with respect to the information we collect, use and disclose to third parties for the purpose of allowing us to provide legal advise and offer our services to you. In order to comply with the privacy legislation, we have developed this Privacy Policy. Any personally identifiable information about a client or prospective client is considered Personal Information (“Personal Information”) and will be treated in accordance with this Privacy Policy.
Our duty to keep your Personal Information and any other information about you confidential stems from both the Personal Information Protection and Electronic Documents Act and the Rules of Professional Conduct of the Law Society of Upper Canada.
COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
CLS collects, uses and discloses your Personal Information (including individuals associated with you, all of whom are referred to as ‘‘you’’ in this Privacy Policy) for the following purposes (“Identified Purposes”):
To establish and manage client relationships, provide legal advice, perform legal services, fulfill legal duties, and avoid conflicts of interest. This may include the sharing of Personal Information by and between CLS personnel for such purposes;
To act on your behalf in the course of dealing with your matter
To make proposals for your future needs
To share Personal Information to and from third parties for the purpose of providing legal services. Such third parties may include opposing parties; parties in interest; opposing, foreign and other counsel and advisors; witnesses; decision-makers; and experts;
To consider whether CLS should establish a commercial relationship with clients, suppliers and other third parties, including to evaluate credit worthiness, issue invoices, administer accounts, collect and process payments, and to fulfill contractual obligations;
To understand and respond to client, supplier and other third party needs and preferences, including to contact and communicate with such parties and to conduct surveys, research and evaluations;
To develop, enhance, market, sell or otherwise provide CLS products and services;
To distribute our newsletters, seminar information and other material to individuals on our mail and email lists, including via third party mailing houses and email service providers;
To develop and manage our knowledge-management precedent systems and databases;
To develop and manage CLS’s business and operations;
To detect and protect CLS and other third parties against error, negligence, breach of contract, fraud, theft and other illegal activity, and to audit compliance with CLS policies and contractual obligations;
To engage in business transactions, including the purchase, sale, lease, merger, amalgamation or any other type of acquisition, disposal, securitization or financing involving CLS;
As permitted by and to comply with, any legal or regulatory requirements or provisions; And
For any other purpose to which you consent.
WHAT INFORMATION WE COLLECT
Information you provide on legal documents or other forms, which may include your name, home address, home email address, age, Identification Numbers (e.g. Social Insurance Number, driver’s license, pilot’s license), credit card numbers, credit records, banking information, payment records, medical and health information, employment and income information, billing and account information, information about your legal issue and other information incidental to providing legal advice and services (including Personal Information about witnesses, family members, beneficiaries, directors, officers, employees, adverse parties, investigators, experts, other professional advisors, and your business partners, investors, shareholders, competitors and customers who are individuals).
Information we acquire from other parties for purposes related to your matters or matters that you are involved in.
Information generated during the performance of legal services undertaken by CLS on your behalf. Personal Information does not generally include what is considered business contact information: your name, title or position, business address, telephone number, facsimile number, or email address.
DISCLOSURE OF INFORMATION TO OTHERS
We will not disclose any Personal Information about you to any third parties except as instructed by you, as required to perform the services CLS undertakes to perform on your behalf, and as otherwise permitted by law. Please Make Note: If we are required by law we may have to disclose your Personal Information to third parties without obtaining your prior approval or providing you with notice thereof.
CONSENT
Your knowledge of and consent to CLS’s collection, use and disclosure of your Personal Information is critical. We rely on the following actions by you as indications of your consent to our existing and future Personal Information practices:
Your voluntary provision of Personal Information to us directly, or through another party;
Your express consent or acknowledgement contained within a written, verbal or electronic process;
Your implied consent by virtue of you retaining our services.
Your consent may be given through your authorized representative such as a legal guardian, agent or holder of a power of attorney.
By submitting personal information to CLS or its service providers and agents, you agree that we may collect, use and disclose such personal information in accordance with this privacy policy and as permitted or required by law.
Subject to certain legal or contractual restrictions and reasonable notice, you may withdraw this consent at any time. CLS will inform you of the consequences of withdrawing your consent. In some cases, refusing to provide certain Personal Information or withdrawing consent for CLS to collect, use or disclose your Personal Information could mean that we cannot provide you with the requested services or information.
If you wish to withdraw your consent please refer to the Questions or to Withdraw Consent section below.
LIMITING COLLECTION AND RETENTION OF PERSONAL INFORMATION
CLS will only collect, use, or disclose Personal Information that is necessary for the Identified Purposes or as permitted by law. If we require Personal Information for any other purpose, you will be notified of the new purpose, and subject to your consent, that new purpose will become an Identified Purpose. CLS will collect Personal Information only by fair and lawful means. We will retain Personal Information only as long as necessary for the fulfillment of the Identified Purposes.
SAFEGUARDS
We have in place physical, electronic, and procedural safeguards appropriate to the sensitivity of the information we maintain regarding clients. Safeguards will vary depending on the sensitivity, format, location, amount, distribution and storage of the Personal Information.
ACCURACY, ACCOUNTABILITY, OPENNESS AND CUSTOMER ACCESS
Our knowing about changes to some of your Personal Information (e.g. your address) may be key to our representation of you. Please keep us informed of changes to your Personal Information.
A copy of this Privacy Policy (and any significant changes) can be obtained from our website atwww.CLS.ca. CLS is responsible for all Personal Information under its control and has designated a Chief Privacy Officer who is accountable to Senior Management for CLS’s compliance with this Privacy Policy.
QUESTIONS, OR TO WITHDRAW CONSENT
To secure your Personal Information, CLS does not provide online access to its clients to view or amend Personal Information in its database. You have the right to access your Personal Information and request rectification of any Personal Information in the file that may be obsolete, incomplete or incorrect.
If you have any questions about this Privacy Policy or want to access your Personal Information, you can obtain our Personal Information Question/Request form by writing or calling our Chief Privacy Officer at the following address or visiting the www.CLS.ca website:
Chief Privacy Officer
Cramer Legal Services
P.O Box 21, 525 Dominion Avenue, Midland, Ontario, L4R 4K8
Phone: 1 800-208-2586 Facsimile: 1 888-790-7004
Email: john@cramerlegal.ca
You may also withdraw your consent to any use or disclosure of your Personal Information (which may limit or terminate the services that CLS provides to you) by writing or sending an email to us at the above address. We will need to validate the identity of anyone making such a request to ensure that we do not provide your information to anyone who does not have the right to such information.
Normally we will respond to access requests within 30 days.
CHANGES TO THIS PRIVACY POLICY
If there is any significant change to this Privacy Policy, CLS will post a notice of the change on its website.
FILING A COMPLAINT
Please write to us at the address above to file a privacy complaint. Should we fail to resolve a complaint to your satisfaction or within a reasonable period, you may contact the Office of the Privacy Commissioner of Canada during business hours at 1 (800) 282-1376 or at www.privcom.gc.ca.
This page last updated June 25, 2018