Customer Privacy Policy

Personal information is any recorded information about an identifiable individual, and may include:

• name, address, telephone number or email address;
• birth date;
• any identifying number, symbol or other particular identifier; and
• correspondence that is implicitly or explicitly of a private or confidential nature.

Pursuant to Ontario’s Freedom of Information and Protection of Privacy Act (FIPPA), ONTC is responsible for personal information in its custody or under its control.

By submitting your personal information to ONTC, you give ONTC consent to collect, use and disclose your personal information:

• in accordance with this Privacy Policy;
• for such other purposes as may be identified to you at the time of collection; and
• for such purposes as are permitted pursuant to applicable law.

Subject to applicable law, you have the right to withdraw your consent at any time by providing written notice to us. However, please note that your withdrawal of consent may affect our ability to respond to your requests or provide services to you.

Your personal information is collected as required to enable ONTC to provide services and/or products to you, now and in the future. ONTC may collect personal information from you in person, over the telephone, by mail, by fax, or through the internet.

We may operate video cameras in our facilities for the safety, security and protection of ONTC staff, visitors and customers as well as for the prevention and detection of criminal activity.

ONTC shall have the right to use your personal information for the following purposes:

• To provide our products and services to you, including:
  • to communicate with you about our products and services;
  • to verify your identity and/or eligibility for certain ONTC services;
  • to process financial and other transactions, such as processing a fare payment or issuing a refund;
  • to conduct promotional campaigns, including contests, draws, raffles, promotions and offers for third party products and services;
  • to provide you with information on new products, services or upcoming events, including third party events sponsored by ONTC; and
  • to conduct and administer rewards or loyalty programs.
• To manage, develop and improve our operations, products and services, including:
  • to respond to comments, questions or complaints;
  • to ensure high-quality customer service and provide effective training to staff;
  • to detect and prevent  theft and other illegal activities;
  • to enforce and administer ONTC rules, by-laws and policies; and
  • to audit internal procedures.
• To assess, process and administer: applications for employment; injury, damage and other claims; and tenders, proposals and contracts.
• For research, statistical, planning and actuarial purposes, including:
  • to analyse business results, trends and patterns; and
  • to conduct market research.
• To comply with our legal and regulatory requirements and to ensure compliance with this Privacy Policy.
• For any other purpose required or authorized by law.

We may also use your personal information to create aggregated data. Aggregated data is information placed in a format that prevents or limits the chance of revealing an individual’s identity. It may be used to show general statistics or track customer behavior as a whole (for example, the number of customers living in a certain area). Such aggregated information is used by ONTC to plan, develop, implement, market and promote our services and products. It will not be used to identify you.

If we require personal information for any purpose(s) other than those set above, we will ask for and obtain your consent before using your personal information for such purpose.

ONTC may from time to time provide your personal information to third parties that we work with to provide our products and services or who have a need to know the information for one of the purposes described above. This may include circumstances where:

• aggregated data is provided to third parties for the purposes of planning, developing, implementing, marketing or promoting ONTC services, or for research, statistical, planning and actuarial purposes;
• disclosure is required or permitted by law or pursuant to a court order; or
• disclosure to a third party is reasonably required to facilitate the provision of our products or services.

Third parties includes various organizations with whom we work to provide products and services to you, including contractors and other service providers, affiliates, municipalities, and other government agencies. We will not transfer personal information to third parties unless they have agreed to comply with all applicable privacy standards, including this Privacy Policy and FIPPA.

The collection of personal information will be limited to that which is necessary to fulfill the purposes identified by ONTC, in this Privacy Policy or otherwise.

Once collected, personal information will only be used and disclosed:

• for the purposes for which it was collected, and to which you have consented (pursuant to this Privacy Policy or otherwise), or
• as required or permitted by applicable law.

Personal information will be retained as long as it is required for the identified purposes and, thereafter, for a further period as determined by FIPPA and other applicable law. We will act in accordance with FIPPA to destroy, delete or erase your personal information from its records when it is no longer required. There may, however, be circumstances where we may not be able to completely remove your personal information, including as a result of data backup procedures or document retention policies. In these circumstances such information will continue to be held securely pursuant to this Privacy Policy.

ONTC will take reasonable steps to ensure that your personal information is accurate, complete and up–to–date. If you wish to verify, update, remove or amend your personal information in our records, please notify us in writing at the address set out below. If you successfully demonstrate the inaccuracy or incompleteness of your personal information, we will amend your information as required. Depending upon the nature of the information challenged, amendment may involve the correction, deletion, or addition of information. Where appropriate, we will provide the corrected information to third parties that have access to your information.

Security safeguards appropriate to the sensitivity of the information are used to protect personal information collected by ONTC against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. Technical, contractual administrative and physical security measures, or a combination thereof, may be used. ONTC protects personal information regardless of the format in which it is held.

We are committed to ensuring that information about our privacy policies and practices is available to you. ONTC makes general information regarding its privacy policies and practises available on its website. For additional information, please contact the ONTC Legal Counsel at 555 Oak Street East, North Bay, Ontario P1B 8L3, (705) 472-4500 ext. 316.

Upon written request, we will confirm the existence, use and disclosure of your personal information. You may request access to your personal information at any time. Please provide sufficient information in your request to enable ONTC to provide an accurate account of your personal information. Depending on the nature and complexity of the request, you may be required to pay a fee (as prescribed by FIPPA s.57) before your request can be processed.

In certain situations, ONTC may not be able to provide access to all personal information it holds about you. For example, we may not be able to disclose information if the record also contains references to other individuals, contains confidential information, or is subject to legal privilege. Exceptions to the access requirements are determined in accordance with applicable law, and the reasons for denying access will be provided to you.

ONTC has procedures in place to receive and respond to complaints or inquiries about its policies and practices relating to the handling of personal information. If you believe that we are not complying with the principles set out in this Privacy Policy or FIPPA, please contact the ONTC Legal Counsel, who will investigate your concerns. We will investigate all complaints. If a complaint is found to be justified, we will take appropriate measures to resolve the matter in accordance with applicable law.

Any questions pertaining to the privacy concerns should be addressed to:

Hayden Wice, Access and Privacy Specialist
Ontario Northland Transportation Commission
555 Oak Street East
North Bay, Ontario, P1B 8L3
(705) 472-4500 ext. 516

Our Privacy Policy may change from time to time; however, we will not reduce your rights under this Privacy Policy without your express consent. We will post any Privacy Policy changes on our websites and, if the changes are significant, we will provide a more prominent notice (including, for certain services, an email notification of changes to this Privacy Policy). We will also keep prior versions of our Privacy Policy in an archive for your information.