2) Identifying Purposes- Frontline will always express to the customer the purpose(s) of personal information collection at the point of or prior to collection.
4) Limiting Collection- Frontline’s collection of personal information is limited to achieving necessary purposes as identified by Frontline.
5) Limiting use, disclosure and retention- Frontline only uses, discloses and retains information for identified rather than ulterior purposes. Furthermore, Frontline will retain personal information only to the extent necessary for fulfilling an identified purpose.
6) Accuracy- Frontline strives for personal information to be as accurate and contemporary as necessary in order to achieve acknowledged purposes.
7) Safeguards- Frontline employs sufficient security mechanisms to protect all collected personal information.
10) Challenging Compliance- Within the framework of the aforementioned principles, individuals shall be able to hold Frontline accountable for compliance by challenging Frontline’s adherence to the CSA model code’s principles.
Why Frontline Collects Personal Information is collected:
- To guarantee the functioning and secure the reliability of all our services.
- To check and/or verify customer identity and certify any information provided is accurate and current.
Length of time Personal Information is Retained
- We will preserve customer information for a time frame reasonably necessary to achieve the acknowledged purpose(s) for which the personal information was collected or a reasonably sufficient length of time to access the personal information if the personal information’s use was to render a decision on the individual personally and or the individuals account. Upon the personal information’s necessity being immaterial to the acknowledged purpose the personal information shall be discarded of.
Variations in Type of Consent Required- Ranging from no consent, implied consent or express consent
Framework: Consent depends and is relative to both the type of personal information and the particular context.
- Express Consent: Express consent is provided verbally, by signing a document, ticking a box online (which signifies express consent) or any other action which indicates acceptance. Express consent is necessary for individual or sensitive matters.
- Implied Consent: Implied consent stems from actions or a course of conduct with regards to any Frontline services or property in reasonably appropriate scenarios.
- No Consent: Situations where our use or disclosure of personal information will not require customer consent include but are not limited to: recouping outstanding arrears, complying with an order of a court or tribunal of Canadian jurisdiction, it is legally permissible according to provincial and/or Canadian federal legalities and/or it is in the individuals personal interest which include but are not limited to medical emergencies and/or threats to physical safety.
When will Frontline disclose personal information?
- To a public authority (including a public authorities agent) for but not limited to the purpose of disclosing an anticipatory or ensuing public emergency as determined by the public authority or the agent of a public authority.
- To a public authority or their agent where it has been concluded that there is an immediate danger threatening the life or security of an individual and therefore by releasing the relevant personal information the aforementioned events can be avoided or minimized.
- To a third party company or organization (including an agent of either) in order to analyze a Customer’s creditworthiness or aid in obtaining arrears owed to Frontline which have exceeded the specific due date established between the parties.
- To an appropriate institution or organization if reasonably required to aid in the investigation of a breach of law or an agreement or to thwart fraud if attaining the Customer’s consent would hinder the investigation into any of the aforementioned events.
- If according to our sole and absolute reasonable judgement, an entity is pursuing the customer’s personal information as an agent.
Non- Personal Identification Information:
- Frontline may collect non-personal identification information about users whenever they interact with our Site. Non-personal identification information may include the browser name, the type of computer and technical information about a users means of connecting to our website, such as the operating system and internet service providers utilized and other similar information.
Obligation to Protect Children’s Privacy:
- Frontline is of the view that a child’s use of the internet and its associated components requires special consideration pertaining to privacy and protection of any information. Our website does not generally contain features or items which are of interest to minors. Frontline does not knowingly collect any information from minors and complies with federal and provincial laws for collecting information from minors. If it is found a person under the age of 13 is using any online features or items, the individual may be removed at the exclusive discretion of Frontline.
- An individual can register for an account on our website that allows Frontline to store contact information and other preferences so that Customer will not be required to re-enter said data each time this website is accessed. Registration is required if the customer is to take advantage of certain features on the website but the customer can still browse the website without formal registration.