Privacy Policy
Personal Information Protection Policy
OUR COMMITMENT TO PRIVACY
Our Personal Information Protection policy explains how Pathways Executive Search hereinafter referred to as “Pathways”, collects, uses, discloses, and protects your personal information. Pathways respects the privacy and confidentiality of your personal information used in our business processes and adheres to the standards and expectations of the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable laws.
This policy also applies to any person(s) providing services on our behalf.
WHAT IS PERSONAL INFORMATION?
Personal Information is information that may be used to identify you as an individual. This includes: your name, home address, home telephone numbers, age, sex, marital or family status, community affiliation, financial information, educational history, and identification numbers.
As defined under PIPEDA, Personal Information does not include your business contact information when you are being contacted as a representative of an organization. This information includes: your name, position name or title, business address, business telephone number and business e-mail address.
CONSENT
If you choose to use our services and/or submit your Personal Information to Pathways, then you are providing your consent for Pathways to retain your Personal Information and use it in the conduct of our business activities. This includes Executive and Professional Search services. For example, if you submit your resume through our website to apply for a search we are conducting for a client, you are providing your consent for us to use your Personal Information in the context of our Executive and/or Professional Search businesses.
You may withdraw your consent to the use and disclosure of your Personal Information at any time unless it is necessary for us to use your Personal Information to fulfill our legal obligations. Please contact our Managing Partner if you would like to withdraw your consent.
COLLECTION AND USE OF YOUR PERSONAL INFORMATION
Pathways collects Personal Information for our Executive and Professional Search business lines, and as an employer described below:
Executive and Professional Search:
Pathways will collect your Personal Information when you are applying for a specific role and search assignment that we are conducting for a current client or for future roles and search assignments (in which case you may choose to submit your resume for future consideration). This information may be acquired from resumes, cover letters, telephone conversations, interviews, security or criminal checks, and/or academic verifications.
Employment with Pathways:
Pathways may collect your Personal Information if you are applying for employment within our company. If hired, more Personal Information will be required for payroll, compensation and benefits, office security and emergency services.
In all cases noted above, after collecting your Personal Information, it may be used by Pathways to communicate with you from time to time for reasons such as ensuring the information that we have about you is correct, to communicate with you about opportunities for employment, to provide you with information about Pathways and its services, and/or to communicate with you about other appropriate business matters.
DISCLOSING PERSONAL INFORMATION
Pathways does not sell Personal Information in any circumstance.
Pathways may disclose your Personal Information in the normal course of providing our business services in the following ways:
Executive and Professional Search:
Pathways may disclose your resume or any Personal Information about you to our clients, for the purpose of providing you with a recruiting opportunity, only with your prior consent. This information will only be used to evaluate your suitability for the role, or potentially other opportunities as well.
Employment with Pathways:
When you accept employment with Pathways, your Personal Information will be disclosed to: third-party insurers, government authorities (including Canada Customs and Revenue Agency), our provider for employee benefits, our payroll administrator, our banks, consultants who advise our company regarding employee benefits and other compensation information or issues, staff responsible for hiring and/or performance management, and to legal counsel if ever required. Personal Information may also be used for emergency contact information.
In addition, in certain circumstances, Pathways may disclose your Personal Information to comply with applicable laws, respond to inquiries or requests from government authorities, or if compelled by legal process.
PROTECTING YOUR PERSONAL INFORMATION
In the normal course of providing Executive and Professional Search services, Pathways utilizes both its own technology and third-party IT providers.
Where Pathways utilizes its own technology, your Personal Information is stored in secure databases on locked servers. We use technological safeguards such as data encryption for security of information being transferred between Pathways offices, firewall protection and virus protection software, and strong password protection to ensure security, and prevent unauthorized computer access.
Where Pathways utilizes third-party IT providers, your Personal Information may be transferred and/or stored on technology not owned by Pathways, and that may be located in Canada, United States or other country. Pathways reviews all third-party IT providers for their security practices, privacy policies and general business reputation. Contractual and other means are used to ensure that the level of protection provided complies with PIPEDA. You should be aware that where your Personal Information is transferred and/or stored on technology outside of Canada, your information may be accessible to law enforcement and national security authorities of those jurisdictions in certain circumstances.
All Pathways employees sign a confidentiality agreement and are educated with respect to handling your Personal Information in a confidential manner.
We protect Personal Information in a manner appropriate to the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of Personal Information, as well as any unauthorized access to Personal Information.
RETENTION OF PERSONAL INFORMATION
Pathways retains your Personal Information as described below:
Executive and Professional Search:
We will retain your Personal Information in our confidential database to contact you again to discuss future opportunities, unless you specifically request otherwise.
Employment with Pathways:
We will retain your Personal Information throughout your employment and for at least seven years after your employment with Pathways ends, as required by Canada Customs and Revenue Agency.
REMOVAL/DISPOSAL OF PERSONAL INFORMATION
We use appropriate security measures, such as professional waste management for the destruction of any hard copy information, to dispose of any Personal Information. If the information is electronic, then the information is permanently deleted from our server. In the event an individual requests the removal of their personal information, a small technical identifier is stored to prevent the re-addition of personal information.
ACCESS AND ACCURACY OF YOUR PERSONAL INFORMATION
You may make a request to access your Personal Information by writing to our Managing Partner and providing sufficient information in your request to allow us to identify the information you are seeking. We will respond to your request within 45 calendar days and a reasonable fee to provide information may apply. If we need more time, we will provide an explanation and timeframe. If we refuse your request in whole or in part, we will provide you the reasons for the refusal. For example, we may not be able to provide information about you from our records if it contains references to other persons or cannot be disclosed for legal reasons.
Please inform our Managing Partner if we need to make any changes to your Personal Information so that it is as accurate as possible. When necessary, the corrections will be made as soon as reasonably possible, and we will notify anyone we may have misinformed.
QUESTIONS AND COMPLAINTS
If you have a question or concern about your Personal Information, or want to request access to your Personal Information, please contact:
Laurie Sterritt
Managing Partner
Pathways Executive Search
1-888-210-5832
inquiries@PathwaysExecutiveSearch.com
A reasonable fee may be charged to cover the administrative costs of addressing your request. We will advise you of any fees that may apply before beginning to process your request. If we are unable to respond to your request for any reason, we will provide you with a written explanation.
Other resources:
OFFICE OF THE PRIVACY COMMISSIONER OF CANADA
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec
K1A 1H3
Toll-free: 1-800-282-1376
Phone: (819) 994-5444
TTY: 819-994-6591