Your Privacy is Important to Us

Doubleday Canada Limited (DCL) is firmly committed to safeguarding the privacy of our Book Club Members' personal information.� As a member of the Canadian Marketing Association (CMA) we have long adhered to the CMA's own Privacy Code established in 1993. In response to the federal government�s privacy legislation, the Personal Information Protection and Electronics Documents Act (PIPEDA), which came into effect on January 1, 2004, DCL has strengthened �its commitment to protecting your privacy.� This notice includes a detailed summary of DCL�s Privacy Policy, what it means to you, and who to contact if you have any questions and concerns. 

 

The Ten Privacy Principles:

 

1.        Accountability

Doubleday Canada Limited (DCL) is responsible for personal information under its control including information transferred to a third party.

 

DCL has designated a Privacy Compliance Officer who is accountable for the organization's compliance with the privacy principles. If you have any questions about our Privacy Policy, please contact our Privacy Compliance Officer at: 5900 Finch Avenue East , Scarborough, Ontario, M1B 0A2 M1B 0A2.

 

DCL has designated the Managers of each department to be accountable for the organization's day-to-day compliance with the privacy principles. In addition, other individuals within the organization may be delegated to act on behalf of the designated individual(s).

 

DCL is responsible for the personal information in its possession or custody, including information that has been transferred to a third party for processing.

 

DCL uses contractual or other means to provide a comparable level of protection while information is being processed by a third party. Third parties agree contractually to abide by provisions of the federal law, and assume the responsibility for doing so.

 

The Management Group of DCL has established formalized information gathering and information handling practices as well as developed documented polices for internal usage regarding the collection, use and disclosure of personal information including:

2.        Identifying Purposes� for Collection, Use, or Disclosure

The purposes for which DCL collects personal information is identified and documented by DCL at or before the time the information is collected in order to comply with the Openness Principle and the Individual Access Principle.

 

DCL collects personal information for the following primary purposes:

  DCL will only use this contact information to get in touch with a Club Member regarding:

  

By identifying the purposes for which personal information is collected at or before the time of collection; DCL ensures that only the required personal information is collected to fulfill these purposes. DCL collects only the contact information the New Member provides on the New Member Application Form which includes the New Member's:� name, address and other applicable contact information such as an e-mail address; and in some cases, a telephone number.� The Limiting Collection Principle requires DCL to collect only that information necessary for the purposes that have been identified.

 

DCL obtains the Club Member's consent prior to using personal information for a purpose not previously identified; unless the new purpose is required by law.

 

DCL employees who collect personal information are able to provide information to explain the purposes for which the information is being collected.

 

3.        Consent to Collection, Use or Disclosure of Personal Information

DCL makes a reasonable effort to ensure that Club Members and New Members understand how personal information will be used. DCL obtains the consent of the Club Members and New Members as required for the collection, use or disclosure of personal information, except where inappropriate.

 

DCL provides information to its New Members and Club Members on how their personal information will be used through printed brochures; the DCL Club web sites; and its Customer Service Centre.

 

DCL obtains consent for the collection, use and disclosure of personal information. Consent is obtained on paper or electronic enrollment forms; electronic or paper order forms; electronic or paper general correspondence; electronic customer service e-mail forms located on our web sites and by phone when members contact DCL's Customer Service Centre or use our Interactive Voice Response (IVR) system.

 

DCL does not as a condition of Club Membership, require the Club Member to consent to the collection, use, or disclosure of personal information beyond that required to fulfill the specified purposes.

 

DCL provides Club Members a meaningful opportunity to decline further marketing use or disclosure of their personal contact information before it is transferred to a third party. This opportunity is detailed in the DCL Club Membership Guide enclosed in all Introductory Packages sent to Club Members upon acceptance of their New Member Application.� DCL continues to notify Club Members of this option every year in their Club Magazine or via an enclosure notice inserted in their Club�s Magazine Mailing Package. Members may also access this information anytime through their DCL Club web sites.

 

DCL will remove the Club Member's name from all internal marketing lists or lists for rental to third parties at the request of the Club Member at any time.� The Club Member need only contact DCL by:

 

 

A DCL Club Member may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. DCL shall inform the Club Member of any implications of such a withdrawal.

 

 

4.        Limiting Collection

The collection of personal information is limited to that which is necessary for the purposes identified by DCL.� DCL collects personal information by fair and lawful means.

 

DCL does not collect personal information indiscriminately. Both the amount and the type of personal information collected is limited to that which is necessary to fulfill the purposes identified.

 

DCL collects personal information from a DCL Club Member:

DCL does not collect e-mail addresses unless the Club Member chooses to specifically provide that information.� DCL does maintain a list of e-mail addresses but does not disclose this personal information to third parties. A Club Member is given the option to modify his/her future e-mail preferences through an �unsubscribe� link included with every online newsletter. Or the Club Member can simply access the: �Change E-mail Address Request� option located in the Members Menu of each DCL Club�s web site. After receiving the Club Member�s request; DCL will remove the Club Member�s e-mail address from the list.

 

5.        Limiting Use, Disclosure and Retention

Personal information shall not be used or disclosed for purposes other than those for which it was collected by DCL, except with the consent of the DCL Club Member or as required by law. DCL retains personal information only as long as is necessary for the fulfillment of those purposes or as per statutory requirements.

 

DCL identifies the purposes for which personal information is collected at or before the time the information is collected.

 

DCL limits the type and extent of the personal information collected to that which is necessary for the purposes identified by DCL.

 

DCL does transfer, rent, sell or exchange mailing lists with carefully screened third parties. DCL along with these third parties establish and agree upon the exact nature of the list's intended usage prior to DCL granting permission for the use of the list or to transfer the information.

 

DCL contracts third party service providers who may have access to DCL Club Member's personal information to perform certain fulfillment services.� This information is confidential and is treated accordingly.

 

DCL may disclose personal information to comply with legal and regulatory requirements.

 

DCL retains personal information of its Club Members in accordance with documented guidelines and procedures established by DCL and based on regulatory requirements governing the retention of business information.�

 

DCL retains the personal information of its Club Members for as long as the member remains active or potentially active or as per statutory requirements.

 

DCL destroys, erases, or renders anonymous personal information that is no longer required to fulfill the identified purposes in accordance with documented guidelines and procedures established by DCL and based on regulatory requirements governing the retention of business information.�

 

DCL safely destroys and disposes of personal information that is no longer required in accordance with documented guidelines and procedures established by DCL.

 

6.        Accuracy

DCL maintains personal information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

 

DCL updates personal information as it is made available by the DCL Club Member and contracted third parties.

 

DCL Club Members and contracted third parties are responsible for providing DCL with any changes to personal information, as appropriate.

 

DCL ensures that personal information will be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information is used to make a decision about a DCL Club Member.

 

DCL ensures that personal information that is used on an ongoing basis, including information that is disclosed to third parties, is generally accurate, and up-to-date, unless limits to the requirements are clearly set out.

 

DCL does not routinely update the personal information of DCL Club members, unless such a process is necessary to fulfill the purposes for which the information is collected.

 

 

7.        Safeguards

DCL protects personal information with security safeguards appropriate to the sensitivity of the personal information.

 

DCL protects personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification with security safeguards appropriate to the sensitivity of the personal information. DCL protects personal information regardless of the format in which it is held.

 

DCL and contracted third parties involved in the transfer, rental, sale or exchange of mailing lists are responsible for the protection of list data and take appropriate measures to ensure against unauthorized access, alteration or dissemination of list data. Those with access to such data agree in advance to use such data only in an authorized manner.

 

When DCL uses a third party to perform fulfillment services on its behalf, legal agreements require the third party to protect the privacy and confidentiality of the personal information. These agreements ensure that the personal information is retained only as long as necessary to complete the assigned task and that the third party only uses it for the specified purposes for which it was given.

 

DCL uses the following methods to protect personal information: 

DCL Club Member�s personal information is stored in secure and confidential databases.

 

DCL employees are aware of the importance of maintaining the confidentiality of DCL Club Member's personal information. DCL provides training programs and provides employees with information about its policies and procedures for protecting and maintaining the confidentiality of DCL Club Member's personal information.

 

DCL disposes of or destroys personal information with care to prevent unauthorized parties from gaining access to the information.

 

8.        Openness

DCL makes readily available to its Club Members and individuals specific information about its policies and practices relating to the management of personal information.

 

DCL is open about its policies and practices with respect to the management of personal information.

 

DCL makes information readily available about its privacy policies and practices to individuals and DCL Club Members through printed brochures such as the Club Membership Guide, its web site and other electronic means, as well as through its Customer Service Centre. In addition, printed copies of the DCL Privacy Policy Statement are available to be mailed to individuals and DCL Club Members upon request.�

 

9.        Individual Access

Upon request, DCL informs Club Members of the existence, use and disclosure of his/her personal information and the DCL Club Member is given access to that information. �Furthermore, a DCL Club Member is able to challenge the accuracy and completeness of the information and have it amended as appropriate.

 

DCL Club Members can request access to their personal information maintained by DCL by writing to: Doubleday Canada Limited--The Privacy Department, 5900 Finch Avenue East,Scarborough, Ontario M1B 0A2. by e-mailing your specific Club's web site; or by calling DCL's Customer Service Centre at: (416) 977-7891.�

 

Upon request, DCL informs the Club Member whether or not it holds personal information about them; and how it uses this personal information. DCL also discloses details of their personal information including (where available): the source of his/her name, and a list of third parties to which it has been disclosed.

 

DCL may request from the Club Member sufficient personal information to permit DCL to provide an account of the existence, use and disclosure of personal information. The information provided by the DCL Club Member shall only be used for this purpose.

 

In providing an account of third parties to which DCL has disclosed personal information about a Club Member, DCL attempts to be as specific as possible. When this is not possible, DCL makes available a list of third parties to which it may have disclosed personal information about the DCL Club Member.

 

DCL responds to a Club Member's request regarding his/her personal information within thirty (30) business days of receipt of the request at no or minimal cost to the DCL Club Member. If the request is complex, DCL may extend the normal 30 day response time limit by a maximum of an additional thirty (30) business days. In addition, a reasonable fee may be charged. The Club Member shall be notified of the time extension and/or additional cost(s) and an agreement shall be obtained between DCL and the Club Member prior to processing the request.

�

When a DCL Club Member successfully demonstrates the inaccuracy or incompleteness of his/her personal information, DCL shall amend the information as required. An amendment may involve a correction, deletion, or addition of information. Where appropriate, the amended information shall be transmitted by DCL to third parties having access to the information in question.

 

A DCL Club Member has the opportunity to challenge the accuracy and completeness of their personal information and have it amended as appropriate. When a challenge is not resolved to the satisfaction of the Club Member, the personal information relating to that DCL Club Member shall reflect the unresolved challenge. When appropriate, the existence of the challenge is transmitted to third parties having access to the information in question.

 

If DCL is unable to provide access to all personal information it holds about the Club Member, the reasons for denying access are provided to the DCL Club Member. 

 

�

10.     Challenging Compliance

A DCL Club Member is able to address a challenge concerning DCL's compliance with the above principles with the individuals identified in Section 1--Accountability.

 

DCL has procedures in place to receive and respond to complaints or inquiries about DCL's policies and practices relating to its handling of personal information.

 

Inquiries about DCL's privacy policies can be forwarded to Doubleday Canada Limited--The Privacy Department, 5900 Finch Avenue East, Scarborough, Ontario, Ontario, M1B 0A2; by e-mailing your specific Club's web site; or by calling DCL's Customer Service Centre at: (416) 977-7891.

 

DCL investigates all complaints and responds within ninety (90) business days after receipt of written correspondence. If the complaint is found to be justified, DCL takes appropriate measures to resolve the complaint, including, if necessary, amending its policies and practices.

 

The DCL Club Member may also contact the following regulatory bodies to make inquiries or lodge complaints about DCL's personal-information handling practices:�

 

 

The Privacy Commissioner of Canada��������������������������������� Canadian Marketing Association

112 Kent Street��������������������������������������������������������������������� 1 Concorde Gate, Suite #607

Ottawa Ontario K1A 1H3������������������ �������������������������������������Don Mills, Ontario� M3C 3N6

 

Telephone:��� 613-995-8210�������������������������������������������������� Telephone:� 416-391-2362

Toll Free:��� 1-800-282-1376�������������������������������������������������� Fax:��� ���������416-441-4062

Fax:�������������� 613-947-6850�������������������������������������������������� E-mail:���������� reception@the-cma.org

Web site:��� www.privcom.gc.ca������������������������������������������ Web site:����� www.the-cma.org

 

 

How DCL uses non-personal information:

Our site�s operating system may automatically record some general information about your visit such as: 

We use this information for statistical analysis, to help us make our site more useful to our visitors. We may disclose this non-personal information to third parties such as sponsors, clients or advertisers and/or use it for auditing purposes. This tracking system does not record personal information about individuals or link this information to any personal data collected.

 

We may use �cookies� that identify you as a return visitor. A cookie is a piece of data that a web site can send to your browser, which may then store the cookie on your hard drive. So, when you come back to visit us again, we can tailor information to suit your individual preferences. The goal is to save you time and provide you with a more meaningful visit and to measure our web site activity. Cookies do not contain any personally identifying information. Browsers such as Netscape allow you to disable cookie collection if you wish, or inform you when a cookie is being stored on your hard drive.

 

 

When you leave the DCL site:

The DCL Privacy Policy Statement discloses the privacy practices for our web site. However, our site may contain links to other sites. Once you link to another site, you are subject to the privacy and security policies of the new site. We encourage you to read the privacy policies of all web sites you visit, especially if you share any personal information.

 

In addition; the DCL Privacy Policy Statement and the choices the Club Member makes does not necessarily apply to the personal information the Club Member may have provided to other clubs operated by controlling entity DCL in the context of other products and services or other separate book clubs.

 

 

Glossary of Definitions:

 

Collection: The act of gathering, acquiring or obtaining personal information from any source including third parties, by any means.

 

Consent: A voluntary agreement with what is being done or proposed. Consent can be either "express", " implied" or "negative option". Express Consent is given explicitly, either orally or in writing. It is unequivocal and does not require inference on the part of the organization seeking consent and it is required for the collection of personal information considered sensitive (financial, credit, medical or health) as well as for any new use. Implied Consent arises when consent may reasonably be inferred from the action or inaction of the individual and is required for the maintenance of established relationships. Negative Option Consent deals with the proposed transfer of non-sensitive personal information to a third party. A meaningful opportunity to decline further marketing use or transfer must be presented before transfer (to a third party) and must be repeated at least once every three (3) years.

 

Disclosure: Making personal information available to others outside the organization.

 

Organization: A term used that includes: associations, businesses, charitable organizations, clubs, government bodies, institutions, professional practices and unions.

 

Personal Information: Any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form, such as:

 

Use: Refers to the treatment and handling of personal information within an organization.