AIA is the national trade association representing the automotive aftermarket industry in Canada. AIA represents manufacturers, re-builders, manufacturers agents, warehouse distributors, national distributors, buying groups, wholesalers, machine shops, retailers, and through its councils, the interests of collision repair shops and automotive service and repair outlets.
AIA’s mandate is to promote, educate and represent members in all areas that impact the growth and prosperity of the industry. To meet this mandate, AIA collects, uses, and discloses Personal Information from individuals such as our members, Directors, Trustees, volunteers, business partners, training course registrants (also known as “clients”), and other stakeholders. AIA is committed to respecting the privacy of all individuals who entrust us with their Personal Information.
a) Personal Information
Personal information is defined as any information, recorded or not, that is about an identifiable individual. It can be objective information (i.e. a member’s home address or someone’s credit card number), or it can be subjective information (i.e. a volunteer’s travel preferences). Anonymous or aggregate information is not considered Personal Information and does not fall under the scope of this Policy.
A disclosure occurs when AIA makes Personal Information available to others outside of AIA.
A transfer occurs when AIA provides Personal Information to a third party in order for them to provide AIA with a service. When AIA transfers Personal Information to its service providers, it remains accountable for the protection of that information. Rest assured that AIA includes a privacy protection clause in its contracts with these providers in order to guarantee that they will provide the same level of privacy protection as AIA is committed to providing.
THE COLLECTION OF PERSONAL INFORMATION
AIA collects and maintains different types of Personal Information including:
- Identification information such as name, home address, telephone, personal email address;
- Social Insurance Number (in very limited circumstances);
- Current education status and education history;
- Financial information such as credit card numbers;
- Language preference;
- Opinions and suggestions;
- Travel preferences;
- Organizational memberships;
- Education and/or Training History; and
- Food allergies, shirt sizes, special travel requirements.
PURPOSES FOR COLLECTION, USE, AND DISCLOSURE
AIA will identify the reasons for collecting Personal Information before or at the time of collection and it will limit its collection of Personal Information to only that information required to fulfil the purposes identified.
Generally, AIA may collect, generate, use or disclose Personal Information for the following purposes:
- Processing membership applications;
- Collecting membership dues;
- Processing registration to events, conferences and seminars;
- Creating, processing and maintaining student applications for training course registration;
- Awarding scholarships;
- Mailing subscriptions to various publications;
- Processing requests for member access to the AIA Canada website;
- Processing sponsorship contracts;
- Responding to requests for information;
- Creating directories or mailing lists, which are made available to other Members and other reputable organizations associated with AIA;
- Giving signing authority to AIA volunteers who require access to AIA funds and/or bank accounts;
- Conducting industry research and studies;
- Promoting AIA products and services;
- E-mailing newsletters;
- Publishing directories for tradeshows and other business events;
- Ensuring security of AIA computer systems;
- Meeting government reporting requirements; and
- Meeting any legal or regulatory requirements.
THE USE OF PERSONAL INFORMATION
AIA will only use Personal Information it has collected about individuals for the purposes listed above. If AIA identifies any new purposes for the information, it will obtain the person’s consent before using it for that new purpose.
AIA does not sell, trade, or barter Personal Information about its members, clients or any other individuals whose Personal Information it may hold.
Circumstances where AIA may use Personal Information without an individual’s knowledge or consent include but are not limited to:
- When it has reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law and the information is used for that investigation;
- When there is an emergency that threatens an individual’s life, health or security;
- When the use is clearly in the individual’s interest and consent is not available in a timely way;
- If knowledge and consent would compromise the availability or accuracy of the information and collection was required to investigate a breach of an agreement or contravention of a federal or provincial law; and
- Other circumstances recognized by PIPEDA as permitting use without consent.
THE DISCLOSURE OF PERSONAL INFORMATION
AIA will only disclose Personal Information it has collected about its members for the purposes listed above.
If AIA intends to disclose Personal Information for a new purpose, it will notify the individual first and seek consent to do so.
Circumstances where AIA may disclose Personal Information without the individual’s knowledge or consent include but are not limited to:
- When it is being disclosed to a lawyer representing AIA;
- When it is being disclosed to collect a debt the individual owes to AIA;
- When it is being disclosed as required by law or to comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction; and
- Other circumstances recognized by PIPEDA as permitting disclosure without consent.
AIA will always obtain consent to collect, use or disclose Personal Information. This consent can be express such as when someone specifically requests to be added to a mailing list for an AIA publication or consent can be implied such as when someone applies to become a member of AIA. By that action, that new member is consenting to AIA’s collection of personal information for the purposes outlined in this Policy.
Individuals are free to withdraw specific consent at any time regarding a particular piece of Personal Information, but AIA reserves the right to withdraw a service if having that information is critical, necessary or a legislated requirement in the provision of its services. These consequences shall be explained to the individual to ensure he or she understands the implications of withdrawing consent.
RETENTION OF PERSONAL INFORMATION
AIA only retains Personal Information for as long as it has a purpose to do so and/or as is required by all the applicable legislation that governs its operations. Once Personal Information is no longer required to fulfill the identified purposes or to comply with legal requirements regarding retention, it will be destroyed or rendered anonymous.
If an individual withdraws consent for AIA to use his or her Personal Information, AIA will be required to retain enough of the data in order to continue accommodating that request.
ACCURACY OF INFORMATION
AIA endeavours to ensure that any Personal Information in its possession and/or under its control is as accurate, current and complete as necessary for the purposes for which AIA uses that information. Members, clients and other individuals are encouraged to contact AIA in a timely manner with any changes to their Personal Information. With consent, AIA will also forward any corrections or amendments of Personal Information to the appropriate third parties to whom the original data has been disclosed, if any.
AIA reserves the right not to change any Personal Information which in its opinion is accurate but it will append any alternative text the individual concerned believes to be appropriate.
AIA will protect Personal Information against loss or theft, as well as from unauthorized access, disclosure, copying, use or modification. AIA will protect Personal Information regardless of the format in which it is held.
AIA will use appropriate security safeguards to provide necessary protection such as:
- Physical measures (locked filing cabinets, restricting access to offices, alarm systems);
- Technological tools (passwords, encryption, firewalls); and
- Organizational controls (limiting access on a “need-to-know” basis, staff training, shredding practices, and confidentiality policies).
AIA will consider the following factors in selecting appropriate safeguards:
- The sensitivity of the information;
- The amount of information;
- The extent of distribution;
- The format of the information (electronic, paper, etc.); and
- The type of storage.
As part of those precautions and in order that AIA may conduct its activities, AIA restricts access to Personal Information to only those employees, Contractors and others (i.e. individuals or organizations providing services to AIA) that AIA determines need to know that information.
ACCESSING AND UPDATING PERSONAL INFORMATION
Subject to some exceptions, individuals have the right to access their own Personal Information, wherever it is stored, which is in the possession and/or under the control of AIA. They also have the right to know if their Personal Information has been disclosed to any third parties and, if so, which ones. AIA will ensure that the requested information is understandable and will explain any acronyms, abbreviations and/or codes.
AIA has 30 days in which to respond to a request for Personal Information. It does have the right to deny a request for access under certain circumstances. Those circumstances include but are not limited to:
- Information which is protected by solicitor-member privilege;
- Information which reveals Personal Information about another individual;
- Personal Information which was collected for an investigation or legal proceeding that has not yet concluded;
- If providing access to particular Personal Information could jeopardize an individual’s life or security; or
- If access to the Personal Information could reasonably be expected to threaten the safety or physical or mental health of another individual.
Acceptable proof of identification may be required before access to Personal Information is granted.
AIA has the right to charge a reasonable fee should an individual request copies of his/her Personal Information.
If AIA refuses access, the individual making the request will be provided with the reasons for non-disclosure. AIA will not respond to repetitious or vexatious requests for access.
ACCOUNTABILITY AND ADDRESSING CONCERNS
In the event that anyone has questions about (a) access to Personal Information; (b) the collection, use, management or disclosure of Personal Information by AIA; or (c) this Policy, that person should contact the CPO at:
Automotive Industries Association of Canada
1272 Wellington Street West
Ottawa, ON K1Y 3A7
Toll Free: (800) 808-2920
If the CPO is unable to resolve the concern, anyone can contact the Privacy Commissioner of Canada at www.privcom.gc.ca or at:
112 Kent Street
Toll free: 1-800-282-1376