PRIVACY POLICY

Policy on the Collection, Use and Disclosure Of Personal Information


“Orion Learning Services Inc. Privacy Notice”


The Orion Privacy Notice and its application


Orion Learning Services Inc. (“Orion”) is committed to respecting the privacy of its Clients. As part of this commitment, we want everyone to know our principles and practices for the collection, use, processing, transfer, storage or disclosure of your Personal Information.

 

This Privacy Notice outlines our policy and practices on the collection, use, transfer, storage and disclosure of Personal Information about Clients, and any other non-Orion individuals with whom we work. The application of this Privacy Notice is subject to applicable laws including legislation, regulations, and the orders or lawful requests of any courts or other lawful authorities.


Definitions:


“Client(s)” means an individual(s) who a) is an Orion customer; b) has requested or used Orion products or services; c) has given his or her information for assessment of needs; or c) registered for Orion training.
“Collection” means the act of gathering, acquiring, noting or obtaining by any other means Personal Information about an individual.


“Consent” means giving permission for the collection, use, and disclosure of Personal Information for certain purposes. Consent can be either express or implied and can be given orally, electronically or in writing. Implied consent is consent that can be reasonably inferred from an action or inaction.


“Disclosure” means making Personal Information available to someone else.


“Orion”, also referred to as “we” or “us”, means Orion Learning Services Inc.


“Personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred or determined from such information, but does not include information that is publically available, such as business contact information or information found in a telephone directory.


“Use” means the treatment, handling and management of Personal Information 


Accountability and Safeguards


Orion takes very seriously its responsibility to protect the personal information in our possession. We are accountable to our Clients to adopt and regularly review our practices to ensure they align with reasonable business practices appropriate to the level of sensitivity to safeguard personal information against loss or theft, unauthorized access, alteration or disclosure.


How Personal Information is used by Orion


Orion uses the Personal Information provided by Clients and others to facilitate assistance and training, activities, and outreach with the goal of delivering Orion products and services in Canada and abroad. Our initiatives include providing and assisting in the provision of training and awareness courses or programs in connection with any of the above


How Orion uses Personal Information


The Personal Information of Orion is never sold or rented to other organizations. The Personal Information of certification program customers and users may be traded with other reputable organizations.


Marketing:  The Personal Information of Orion clients is shared with the International Service Standards Association (ISSA) and/or any other reputable association or organization that is affiliated with Orion or ISSA.


Personal Information on the Orion Website


Orion is the sole owner of the information collected on the www.orionelearning.com website (“website”). Orion collects information from users at several different points on its website. We use IP addresses to analyze trends, administer the site, track users’ movements, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.


Cookies and Web Beacons:  For both anonymous visitors and known visitors to our website, we collect information such as the server your computer is logged onto, the domain name of your internet service provider, your browser type and version (for example, Netscape or Internet Explorer) and your IP address. An IP address is a number that is assigned to your computer automatically and required for using the Internet. We may also derive the general geographic area associated with an IP address. We use “cookies”, sometimes in combination with “web beacons” or similar technology to collect information about how this website is used such as average time spent on this website, pages viewed, and information searched for, access times, response rates to online or e-mail advertising and other relevant information about your online experience. If you are an anonymous visitor, the information in this paragraph does not personally identify you but rather numerically identifies your site and we share this cookie’s information with a third party marketing provider that will use it to deliver marketing about us to you while you visit other sites on the internet. Our third party provider is located in the United States. If you do not want to receive cookies on your computer, you must select the appropriate settings in your browser’s options; however, doing so may limit some of the interactivity our site offers you.


Links to Other Websites:  This website contains links to other sites. Please be aware that Orion is not responsible for the privacy practices of other such sites. We encourage our users to be aware when they leave our site and to read the privacy policy of every website that collects personally identifiable information. This Privacy Notice applies solely to information collected by this website.


Security and Confidentiality on our website:  All online transactions and contributions on this site occur through a safe, private, and secure system that protects the customer and customer user(s) personal information.


Communication with customers via email:  From time to time we may communicate with a customer via email. If an customer does not wish further communication via email, he or she will be given an opportunity to opt out. Members and donors can opt out of receiving any type of emails from us at any time by contacting us at privacy@orionelearning.com.


Consent


When an individual chooses to become a client of Orion, he or she is consenting to our collection, use and disclosure of his or her Personal Information in accordance with this Privacy Notice.  We may seek additional consent where required by law or in situations where we consider further consent to be necessary or appropriate.


An individual is free to refuse or withdraw his or her consent to the collection, use or disclosure of his or her Personal Information at any time upon reasonable notice in writing to Orion. A Client may decline to give Orion his or her Personal Information but, in some circumstances, this decision may hinder Orion’s ability to provide services to the Client.


Limiting Collection, Use, Disclosure, and Retention


Limitations on Collection and Use:  Orion strives to identify the purpose for which it is collecting Personal Information at the time it is collected through oral, electronic, or written means, although in extreme circumstances such as emergency response, it may not be possible to do so immediately. Personal Information will be collected, to the extent possible, directly from the individual concerned, their employer, or association.  An individual with questions about how Orion collects Personal Information may contact us for more information at the Privacy Contacts listed in Section 9 of this Privacy Notice.


Disclosure:  Orion does not disclose the Personal Information of its Clients without the Clients knowledge and consent except when consent is implied.or:


where required by law or by order or requirement of a court, administrative agency or other governmental tribunal;


where we believe, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;


where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain; or


where the information being disclosed or used is in the public domain.


Where Orion is obliged or permitted to disclose information without consent, we will not disclose more information than is minimally required in the applicable circumstances.


Retention:  Orion retains personal information as long as necessary for the fulfillment of the identified purposes for its collection or as otherwise necessary to comply with applicable laws. When personal information is no longer necessary or relevant for the identified purposes, or is required to be retained by applicable laws, Orion will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. Orion uses reasonable business practices to ensure we have adequate controls, schedules and practices for information and records retention and destruction which apply to your personal information.


Accuracy and Individual Access


Orion endeavours to ensure that any Personal Information provided to it by Clients is as accurate, current, and complete as necessary in order to meet the reason for which it was obtained.


Access:  An individual may request access to and review of personal information about themselves that is in the possession of Orion. Access will be provided within a reasonable business timeframe unless access is declined for one of the reasons described herein. We reserve the right to decline access to Personal Information where:


The identity of the person requesting access cannot be confirmed.


The Personal Information is not readily retrievable and the burden or cost of providing it would be disproportionate to the nature or value of the information;


The requested Personal Information does not exist, is not held, or cannot be found;


Disclosure of the Personal Information would compromise the confidentiality of another individual or threaten the safety of another person.


Non-disclosure of the Personal Information is required or permitted by law.


Requests to Change or Delete Information:  An individual may request that Orion change or delete Personal Information about themselves that is in the possession of Orion. We reserve the right not to change any Personal Information but will append any alternative text the individual concerned believes appropriate. We will make reasonable business efforts to comply with a request to delete an individual’s Personal Information as long as technological restraints or legal constraints do not limit our ability to fulfill the deletion request.


Where a request for access, alteration, or deletion of Personal Information is declined, the individual making the request will be provided with the reasons for declining the request.


Privacy Contacts for Concerns or Questions


In the event of questions about: (i) access to Personal Information;  (ii) the collection, use, management or disclosure of Personal Information by or on behalf of Orion; or (iii) this Privacy Notice, please contact Orion via email at privacy@orionelearning.com.


Last modified: Wednesday, 15 June 2016, 4:23 PM