This Privacy Policy sets out the policies and practices of Hugessen Consulting Inc. (“Hugessen”) with respect to the collection, use, and disclosure of personal information other than information about Hugessen employees, which is instead governed by Hugessen’s Employee Privacy Guidelines.  In this Privacy Policy, “personal information” means any information about an identifiable individual, as further defined under applicable Canadian laws.

Hugessen is committed to respecting privacy rights.  Hugessen will only collect, use or disclose personal information in accordance with this Privacy Policy and applicable law.  
This Privacy Policy applies to Hugessen and to anyone providing services on Hugessen’s behalf.

Hugessen may update this Privacy Policy from time to time.  Hugessen will give reasonable notice of the revised terms.  A current copy of this Privacy Policy is available on our website, or from Hugessen’s Privacy Officer (the “Privacy Officer”), as described below.

Collection and Use of Personal Information

Hugessen collects only the personal information that it requires to provide the services for which it has been retained by a client.  This may include:

  • information about the compensation offered or provided by organizations to particular individuals;
  • information about performance assessments of individuals by organizations; and
  • other related information.

Hugessen normally collects personal information directly from its client.  Anyone who is concerned about any personal information which may have been provided to Hugessen is invited to contact the Privacy Officer, as described below, for additional information.

Hugessen will collect and use this personal information for the purpose of providing services to the client in accordance with the applicable engagement letter and work plan, or as otherwise agreed between Hugessen and its client (the “Client Agreement”).

Hugessen may also retain the personal information and use it in aggregate form for the purpose of improving Hugessen’s services and advice, generally.  Hugessen will not disclose this information to any third party in a manner which allows or might reasonably be considered to allow particular individuals to be identified, except as noted below.

Disclosure of Personal Information

Hugessen may disclose personal information as follows:

  • as expressly provided in the applicable Client Agreement;
  • to third-party service providers or agents who provide services to or on behalf of Hugessen, as further detailed below;
  • to law enforcement agencies for the purposes of investigating fraud or other offences, in connection with the prevention or investigation of suspected fraudulent activities or harm to individuals or property, to establish or exercise our legal rights or defend against legal claims, or in connection with an emergency that warrants use or disclosure of the information;
  • to regulatory authorities, as required or permitted by applicable law;
  • to legal, financial, insurance, and other advisors or in connection with the sale, reorganization, or management of all or part of its business or operations; and
  • as consented to by the individual from time to time, including to fulfill any other purposes that are identified when the personal information is collected.

Hugessen will not use or disclose personal information for purposes other than those for which it was collected, except with an individual’s consent or as required or permitted by law.  Consent may be express or implied, and given in writing, including by using or not using a check-off box, electronically, orally, or by the individual’s conduct, such as use of the services or products.

Storage and Processing of Data by Service Providers

Hugessen makes use of third-party service providers to store and process data, including personal information, on its behalf.  Hugessen, its service providers, or its agents may use servers or other facilities located in the United States of America for this purpose.  When acting on Hugessen’s behalf, such service providers and agents are only authorized to collect, use, or disclose personal information as described in this Privacy Policy.  However, the government, courts, law enforcement, security, or regulatory agencies of the United States of America may be able to obtain access to or disclosure of personal information as permitted by the laws of that country.

Any questions in this regard may be directed to the Privacy Officer using the contact information provided below.

Security
Hugessen protects against the loss, misuse, and alteration of personal information with security measures appropriate to the sensitivity of the information, including through the use of physical, organizational, and technological measures and appropriate training of employees.

Corrections and Complaints

Any individual may contact the Privacy Officer, using the contact information provided below, to modify or correct any of his or her personal information that is under Hugessen’s control.  Any individual may also direct a written complaint regarding compliance with this Privacy Policy to the Privacy Officer and, within a reasonable time upon receiving the written complaint, the Privacy Officer will conduct an investigation into the matter. Within a reasonable time of concluding the investigation, the Privacy Officer will respond to the complaint and, if appropriate, Hugessen will take appropriate measures necessary to rectify the source of the complaint.

Contact
Any questions about this Privacy Policy or Hugessen’s collection, use, disclosure, or retention of the Individual’s personal information should be directed to the Privacy Officer as follows:

Hugessen Consulting Inc.
Attention: Privacy Officer 
Address: 200 Bay Street, Suite 3200, Royal Plaza, South Tower, Toronto, ON M5J 2J4
Email: privacy@hugessen.com
Telephone: 416-868-1288
Fax: 416-868-4415

Last Updated: July 17, 2014