Privacy of personal information is an important principle to Nourish Boutique Spa. We are committed to collecting, using, and disclosing personal information responsibly and only to the extent necessary for the goods and services we provide. We also try to be open and transparent as to how we handle personal information. This document describes our privacy policies.

WHAT IS PERSONAL INFORMATION?

Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status), their health (e.g., health history, health conditions, health services received by them) or their activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is to be contrasted with business information (e.g., an individual’s business address and telephone number), which is not protected by privacy legislation.

WHO WE ARE

Our organization includes estheticians and support staff. We use a number of consultants and agencies that may, in the course of their duties, have limited access to personal information we hold. These include accountants, bookkeepers, computer consultants, office maintenance, credit card companies, cleaner, lawyers and payroll services. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their assurance that they follow appropriate privacy principles.

WE COLLECT PERSONAL INFORMATION: PRIMARY PURPOSES

About Guests

Like all spas and salons, we collect, use and disclose personal information in order to serve our guests.

For our guests, the primary purposes for collecting personal information are as follows: to provide you with wellness, cosmetic or self-care services. For example, we collect information about a guest’s health history, including their family history, physical condition and social situation in order to help us assess what their skin care needs are, to advise them of their options and then to provide the care they choose to have. A second primary purpose is to obtain a baseline of health and social information so that in providing on-going services we can identify changes that are occurring over time. It would be rare for us to collect information without the guest’s express consent, but this might occur in an emergency (e.g., the guest is unconscious) or where we believe the guest would consent if asked and it is impractical to obtain consent (e.g., a family member passing a message on from our guest and we have no reason to believe that the message is not genuine).

About Members of the General Public

For members of the general public, our primary purposes for collecting personal information are to provide notice of special events (e.g., a seminar, workshop) or to make them aware of our services in general or our spa in particular. For example, while we try to use work contact information where possible, we might collect home addresses, fax numbers and email addresses. We try to obtain consent before using any such personal information, but where this is not, for any reason possible, we will upon request immediately remove any personal information from our distribution list.

On our website we will only collect, with the exception of cookies, the personal information you provide and only use that information for the purpose you gave it to us (e.g., to respond to your email message, to register for a workshop, to subscribe to our newsletter).

About Contract Staff, Volunteers and Students

For people who are contracted to do work for us (e.g., temporary workers), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., sending out paycheques, year-end tax receipts). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. If contract staff, volunteers or students wish a letter of reference or an evaluation, we will collect information about their work related performance and provide a report as authorized by them.

WE COLLECT PERSONAL INFORMATION: RELATED AND SECONDARY PURPOSES

Like most organizations, we also collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:

•  To invoice guests for goods or services that were not paid for at the time, to process credit card payments or to collect unpaid accounts.

• ·To advise guests that their service should be reviewed.

• ·To advise guests and others of special events or opportunities (e.g., seminars, development of a new service) that we have available.

• ·Our spa reviews guest and other files for the purpose of ensuring that we provide high quality services, including assessing the performance of our staff. In addition, the external consultants (e.g., lawyers, practice consultants, voluntary accreditation programs) may on our behalf do audits and continuing quality improvement reviews of our spa, including reviewing guest files and interviewing staff.

• External regulators have strict privacy obligations. Sometimes these reports include personal information about our guests, or other individuals, to support the concern (e.g., improper services). Also, like all organizations, various government agencies (e.g., Canada Customs and Revenue Agency, Human Rights Commission, etc.) have the authority to review our files and interview our staff as a part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.

• Guests or other individuals we deal with may have questions about our goods or services after they have been received. We also provide on-going services for many of our guests over a period of months or years for which our previous records are helpful. We retain our guest information for a minimum of ten years after the last contact to enable us to respond to those questions and provide these services.

• If the spa or its assets were to be sold, the purchaser would want to conduct a “due diligence” review of the spa’s records to ensure that it is a viable business that has been honestly portrayed to the purchaser. This due diligence may involve some review of our accounting and service files. The purchaser would not be able to remove or record personal information. Before being provided access to the files, the purchaser must provide a written promise to keep all personal information confidential. Only reputable purchasers who have already agreed to buy the organization’s business or its assets would be provided access to personal information, and only for the purpose of completing their due diligence search prior to closing the purchase.

You can choose not to be part of some of these related or secondary purposes (e.g., by declining special offers or promotions, by paying for your services in advance). We do not, however, have much choice about some of these related or secondary purposes (e.g., external regulation).

PROTECTING PERSONAL INFORMATION

We understand the importance of protecting personal information. For that reason, we have taken the following steps:

• · Paper information is either under supervision or secured in a locked or restricted area.
•  Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used   on computers. All of our cell phones are digital, which signals are more difficult to intercept.
•  Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
• Electronic information is transmitted either through a direct line or is anonymized or encrypted.
•  Staff is trained to collect, use and disclose personal information only as necessary to fulfil their duties and in accordance with our privacy policy.
• External consultants and agencies with access to personal information must enter into privacy agreements with us.

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RETENTION AND DESTRUCTION OF PERSONAL INFORMATION

We need to retain personal information for some time to ensure that we can answer any questions you might have about the services provided and for our own accountability to external regulatory bodies. However, we do not want to keep personal information too long in order to protect your privacy. We keep our guest files for ten years following the last visit date, and for children, 10 years after their 18^th birthday. Our client and contact directories are much more difficult to systematically destroy, so we remove such information when we can if it does not appear that we will be contacting you again. However, if you ask, we will remove such contact information right away. We keep any personal information relating to our general correspondence with people who are not our guests, newsletters, seminars and marketing activities for about six months after the newsletter, seminar or marketing activity is over.

We destroy paper files containing personal information by shredding. We destroy electronic information by deleting it and, when the hardware is discarded, we ensure that the hard drive is physically destroyed. Alternatively, we may send some or the entire guest file to our guest.

YOU CAN LOOK AT YOUR INFORMATION

With only a few exceptions, you have the right to see what personal information we hold about you. Often all you have to do is ask. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (e.g., short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests. If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days if at all possible and tell you the reason, as best we can, as to why we cannot give you access.

If you believe there is a mistake in the information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that our files are wrong. Where we agree that we made a mistake, we will make the correction and notify anyone to whom we sent this information. If we do not agree that we have made a mistake, we will still agree to include in our file a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.

DO YOU HAVE A CONCERN?

Our Information Officer, Cristol Smyth, can be reached at:

727 William Street, Cobourg, ON

PHONE: 905-377-0627

She will attempt to answer any questions you might have.

If you wish to make a formal complaint about our privacy practices, you may make it in writing to our Information Officer. She will acknowledge receipt of your complaint; ensure that it is investigated promptly and that you are provided with a formal decision and reasons in writing.

This policy is made under the Personal information Protection and Electronic Documents Act. That is a complex Act and provides some additional exceptions to the privacy principles that are too detailed to set out here. There are some rare exceptions to the commitments set out above. For more general inquiries, the Privacy Commissioner of Canada oversees the administration of the privacy legislation in the private sector. The Commissioner also acts as a kind of ombudsman for privacy disputes. The Privacy Commissioner can be reached at:

112 KENT STREET | OTTAWA, ONTARIO | K1A 1H3

PHONE (613) 995-8210 | TOLL-FREE 1-800-282-1376 | FAX (613) 947-6850 | TTY (613) 992-9190

www.privcom.gc.ca