Re:Sound protects the personal information of its customers, rights holders, employees and those with whom it conducts business by adopting and adhering to PIPEDA’s 10 guiding principles:
- Identifying Purpose
- Limiting Collection
- Limiting Use, Disclosure and Retention
- Individual Access
- Challenging Compliance
WHAT IS PROTECTED?
Personal information includes any factual or subjective information, recorded or not, about an identifiable individual, such as a personal e-mail address, credit card numbers and home addresses. Personal information does not include information normally found on a business card (the name, title, or business address or telephone number).
WHO IS RESPONSIBLE FOR PROTECTING THE PERSONAL INFORMATION COLLECTED, USED AND DISCLOSED BY RE:SOUND?
The Chief Privacy Officer is responsible for Re:Sound protecting the personal information collected, used and disclosed. The Chief Privacy Officer, along with members of the Legal Affairs Department and Re:Sound staff, are responsible for ensuring compliance with applicable privacy laws, including PIPEDA, and with this Policy. At times, Re:Sound staff may be delegated to act on behalf of the Chief Privacy Officer or to take responsibility for the occasional collection, use and disclosure of personal information. For further information on the role of the Chief Privacy Officer, please contact the Chief Privacy Officer at the address or number provided at the end of this policy.
Personal and financial information is used by Re:Sound to administer licences, fulfill Re:Sound’s legal and legitimate business requirements and to provide you with the services that you have requested. As a customer, rights holder, employee or someone that conducts business with Re:Sound, certain personal information is collected such as your name, address and telephone number, in order to:
- Establish your identity;
- Provide the ongoing service of administering performing rights in Canada and internationally;
- Comply with any and/or all legal requirements; and
- Protect you from errors and/or fraud.
The type of personal information that Re:Sound collects may include:
FROM OUR CUSTOMERS:
- Employee(s) and Business Names;
- Address(es) and/or Mailing Address(es);
- Telephone and Fax Numbers;
- Email Address(es); and
- Financial Information.
Personal and financial information collected about our Customers is used by Re:Sound to administer your licence, communicate with you, fulfill Re:Sound’s legal and legitimate business requirements and to provide you with the services that you have requested.
FROM RIGHTS HOLDERS:
- Social Insurance Number;
- Home and/or Business Address(es);
- E-mail Address(es);
- Telephone and/or Fax Number;
- Citizenship Information;
- Representative Information;
- Repertoire information; and
- Financial information.
Personal information collected about our rights holders is used by Re:Sound to administer your royalties, confirm your identity and confirm your eligibility to receive royalties. Your information is also used for tax purposes, tax receipts and other membership purposes.
FROM OUR EMPLOYEES:
- Telephone Number(s);
- Date of Birth;
- Social Insurance Numbers;
- Banking Information;
- Benefit information
- Emergency Contact Information; and
- Resume and Reference Letters and/or Contacts.
Typically, the personal information collected about our employees is used by Re:Sound and/or provided to its agents to ensure that you are properly identified as an employee of Re:Sound, to administer payroll and employee benefit programs and to comply with the Income Tax Act. Emergency contact information is required in case we need to notify anyone of your involvement in an emergency situation while at work. Resume and reference letters are used to determine your eligibility for employment and to be considered for future development and opportunities within the organization.
Personal information that is collected, used and disclosed by Re:Sound is provided by you and is updated when requested by you or Re:Sound. If your personal information requires amendment, you should contact Re:Sound, in writing, and request that the change be made.
Prior to the collection, use or disclosure of any personal information about our customers, rights holders or employees, Re:Sound will make a reasonable effort to ensure such individuals have knowledge of the purposes for which the information will be used, and will make reasonable efforts to obtain consent to do so, except where, as noted below, we are authorized to do so without consent:
- When the collection, use or disclosure of personal information in permitted or required by either provincial or federal law or regulation;
- In an emergency that threatens your life, health or personal security;
- If you are seriously ill or mentally incapacitated and obtaining consent is otherwise impossible or impractical;
- When the personal information is publically available;
- For security reasons;
- In the prevention or the detection of fraud or other contraventions of the law, or for law enforcement; and
- In any other circumstances where obtaining consent would be inappropriate.
Re:Sound retains personal information confidentially and only for as long as is required to fulfill the purposes stated within this Policy, and to meet all requirements by law.
LIMITING USE, DISCLOSURE, AND RETENTION
Documents containing personal information that are no longer required are carefully disposed of by shredding, or in the case of electronic documents, permanently deleting them off all hard drives and servers. Electronic documents are deleted in accordance with Re:Sound’s Document Retention Policy.
Your information is not sold or otherwise disclosed to anyone outside of Re:Sound unless outlined in the above limited circumstances.
If Re:Sound is notified of any inaccuracy or incompleteness of your personal information, Re:Sound will correct all errors and take all steps required to ensure that the personal information is updated and remains accurate.
FROM OUR CUSTOMERS:
- Information is updated either quarterly or annually, depending on the applicable license, or as the information is provided. Applicable forms are to be completed manually or through the portal of Re:Sound’s website and are to be returned to Re:Sound.
FROM RIGHTS HOLDERS:
- New information is updated as it is received from our members on behalf of the Rights Holders if applicable, or our Rights Holders.
FROM OUR EMPLOYEES:
- New information is updated as it is received from our employees.
Re:Sound is committed to ensuring that personal information is protected from, among other things, unauthorized access, unintended disclosures or theft. This protection is provided by:
- firewalls or other protective technology in computer systems;
- passwords to protect databases;
- secure physical storage locations;
- access to offices and/or databases restricted only to those who require access; and
- the Chief Privacy Officer will conduct periodic reviews of Re:Sound’s practices to assess compliance with this policy.
Only the Chief Privacy Officer and delegated individuals have access to this information. Re:Sound uses data encryption, or scrambling technologies and industry-standard firewalls. When you send financial information to Re:Sound, it is stored by Re:Sound or its agents and protected using the appropriate technological locks.
Re:Sound will use its best efforts to reasonably ensure that any third party agents contracted by Re:Sound comply with this Policy and prevent unauthorized collection, use and disclosure of personal information. As well, Re:Sound regularly monitors developments in technology and is committed to using the most up-to-date and secure processes available to maintain the privacy of the individuals with whom we deal.
HOW IS PERSONAL INFORMATION COLLECTED, USED OR DISCLOSED VIA RE:SOUND’S WEB SITE?
In order to enhance your browsing experience when accessing Re:Sound’s web site, a small text file called a “cookie” is sent from our web server to your browser and stored on your computer. Cookies enhance your browsing experience, and also allow us to recognize you when you return to Re:Sound’s website. You may set your browser to notify you when you receive cookies and you may choose to disable or delete cookies if you wish. Cookies are not programs or code, and are only used to optimize browsing.
Re:Sound’s web site may also log IP addresses of visitors. This information is used, in aggregate form, to provide statistical measures about usage of the site. This in turn allows us to continually improve the content and design of our web site.
Re:Sound’s web site may contain links to other web sites owned and operated by third parties. While we attempt to ensure that these organizations adhere to similar privacy policies, we are not responsible for the content or privacy practices of such sites. It is highly recommended that you review the privacy policies of other sites prior to providing any personal information on those sites.
Re:Sound does not condone the use of spyware (i.e. pop-up window advertising) and does not employ any such technologies. Re:Sound does not sell space on the website to third parties.
You have a right to access your own personal information in the possession and control of Re:Sound. You also have a right to know if your information has been disclosed to any third parties. If you wish to access your personal information, you should contact the Chief Privacy Officer in writing. Re:Sound reserves the right to charge a minimal cost for the copying and gathering of this information. Re:Sound may choose to not allow access to personal information in its possession for certain reasons. In the event that Re:Sound declines the request for the information, it will do so in writing, and will provide the reasons for the denial and any recourse that may be available to you.
If you have a question or complaint related to this Policy, Re:Sound asks that you contact the Chief Privacy Officer in writing. The Chief Privacy Officer shall acknowledge receipt of the complaint within 15 business days upon receipt and will then proceed to investigate it.
HOW OFTEN WILL THIS POLICY BE UPDATED?
The Chief Privacy Officer will review this Policy regularly and revise it as necessary and/or appropriate without notice. Re:Sound reserves the right to modify or amend this Policy at any time. Nothing contained within this policy is intended to create a contract or agreement between Re:Sound and any other party. Please review this Policy periodically so that you are aware of any changes.
Chief Privacy Officer
Re:Sound Music Licensing Company
1235 Bay Street, Suite 900
Toronto, ON M5R 3K4
Telephone: (416) 968-8870
Facsimile: (416) 352-7441