Privacy Policy
Last updated: September 13, 2022
Protecting the privacy and the confidentiality of Personal Information (as defined below) is a standard by which Electricity Human Resources Canada (“EHRC”, “we”, “us”, or “our”) conducts its business. The collection, use and disclosure of Personal Information (as defined below) is fundamental to many of our project areas and day-to-day administrative activities. We strive to provide high quality services and deliverables with the utmost professionalism. This includes respecting privacy and treating all stakeholders fairly.
EHRC has established this Privacy Policy to define its practices and procedures concerning the collection, usage and disclosure of Personal Information that applies to your access and use of the Platform and Services (each as defined in the Terms of Use).
Please read this Privacy Policy carefully to understand our policies and practices for collecting, processing, and storing your Personal Information. If you do not agree with our policies and practices, you must not use the Platform or our Services.
By voluntarily providing us with Personal Information through the use of Services and the Platform, you are consenting to its collection, use and disclosure in accordance with this Privacy Policy. You acknowledge and agree that such Personal Information may be transferred from your current location to the offices and servers of EHRC and authorized third parties referred to herein located in Canada and the United States.
We may revise this Privacy Policy from time to time. The most current version will always be posted on our Platform. Therefore, we recommend that you frequently visit the Platform to monitor any changes to the Privacy Policy. In the event of any material change to this Privacy Policy, we or the applicable EHRC Licensee (as defined in the Terms of Use) will post a notice on the Platform that we have changed this Privacy Policy. If we have your email address, we or the applicable EHRC Licensee may (but are not required to) email you to provide notice that we have changed this Privacy Policy. If you use the Platform after receiving notice of any such modification or replacement, you agree to have read and are indicating your acceptance of, and you agree to be bound by, the modified or replaced privacy policy. Any changes will be effective only after the effective date of the change and will not affect any dispute arising prior to the effective date of the change.
1. What is Personal Information?
“Personal Information” includes any information about an identifiable individual.
When you visit the Platform, our web server automatically recognizes the Internet domain and Internet Protocol (“IP”) address from which you access the Platform, to compile statistics regarding the volume and timing of access to our Platform. We do this so that we can improve the content and structure of the Platform and our Services. Only aggregate information is collected and the Personal Information of individual visitors is not identified. In addition, when you visit our Platform, we collect certain information about your activity on our Platform, as described below under the heading “Our Use of Cookies and Log Files”.
If you are accessing the EHRC Platform (as defined in the Terms of Use) and Services on your own behalf as a participant, the Personal Information we may collect or obtain includes, but may not be limited to:
- Information you provide us: We collect information you provide to us, including your name, phone number, email address, age, employment information, educational background, demographic information and residency status.
- Information provided by your employer: We collect information your employer may provide to us, including your pay stub and other employment information.
If you are accessing the EHRC Platform and Services on behalf of an organization, the Personal Information we may collect or obtain includes, but may not be limited to:
- Information you provide us: We collect information you provide to us, including your name, job title, organization name, email address and phone number.
If you are accessing the White-Label Platform (as defined in the Terms of Use) through your relationship with an EHRC Licensee, we collect the Personal Information as determined by the applicable EHRC Licensee in our capacity as a processor of such Personal Information. This may include, without limitation, information you provide through the White-Label Platform such as name, phone number, email address, educational background, demographic information and residency or legal status. Please refer to the applicable EHRC Licensee’s privacy policy for further information with respect to the types of Personal Information collected through the White-Label Platform.
2. Why does EHRC Collect and Use Personal Information?
EHRC provides services and information to a wide range of individuals. In doing so, we may need to collect Personal Information for various reasons, including without limitation:
- to provide you with access to our Platform and our Services, including applying for funding, determining eligibility for funding programs, checking placement status, managing placements, submitting claims and verifying the status of any placements;
- to provide reporting to the Government of Canada;
- to customize your use of our Platform and Services;
- to validate your role within an organization and eligibility to use and access the Platform and Services;
- to provide you and the EHRC Licensee, as applicable, with support and maintenance services; and
- to understand your needs and to respond to your requests.
To the extent permitted by applicable law, we may use, process, transfer, and store any data about individuals in an anonymous (or pseudonymous) and aggregated manner. We may combine Personal Information with other information collected online and offline, including information from third party sources. We may share anonymized data with third parties including, without limitation, potential licensees and employers for business development purposes and use such anonymized data for purposes including heat map analysis, traffic analysis, site search analytics, email marketing segmentation analysis and A/B testing.
We may also use your Personal Information in other ways with consent or as permitted by applicable law. By using the Platform and/or the Services, you agree that we are hereby licensed to collect, use, share, and store anonymized (or pseudonymized) aggregated data collected through the Platform or your use of the Services for benchmarking, analytics, metrics, research, reporting, machine learning, and other business purposes.
3. How Do We Share Personal Information?
There are some circumstances where we may share your personal information with a third party. For example:
- We may share Personal Information with our affiliates or any business partners or agents acting on our behalf or with our financial, insurance, legal, accounting or other advisors that provide professional services to us.
- Subject to applicable regulations, we may disclose your personal information to a government agency, court, or law enforcement personnel, including the Government of Canada for the purposes of reporting required relating to funding programs.
- Your Personal Information may be disclosed to a company or individual employed or engaged by us to perform functions on our behalf such as data processing or document retention. Any such disclosure of your Personal Information is made on a strictly confidential basis, and the information is to be used only for the purpose for which it was shared. We ensure that the company or individual adheres to this Privacy Policy.
- When we believe in good faith that a law, regulation, subpoena, warrant or other court order requires it or authorizes us to do so or to respond to an emergency situation.
- We may share, disclose or transfer Personal Information to a buyer, investor, new affiliate, or other successor in the event EHRC or any affiliate, portion, group or business unit thereof, undergoes a business transition, such as a merger, acquisition, consolidation, reorganization, divestiture, liquidation or dissolution (including bankruptcy), or a sale or other transfer of all or a portion of any assets of EHRC or any affiliates or during steps in contemplation of such activities (e.g., negotiations and due diligence).
- We reserve the right to disclose Personal Information if required to do so by law or in the good faith belief that such action is reasonably necessary to comply with legal process, enforce our Terms of Use and/or an EHRC License Agreement (as defined in the Terms of Use), respond to claims, or to protect the rights, property or safety of EHRC, our affiliates, our partners, service providers, or the public.
If you are an individual accessing the Platform and Services on your own behalf, we may also share your Personal Information (such as name, email, phone and salary) with your employer (including employer representatives) for payment and identity verification purposes in relation to your employer’s funding application. Please note that we do not share demographic information provided by you with your employer.
If you are an individual accessing the Platform and Services on behalf of an employer organization, we may share your contact information with your participating employees who have created an account on the Platform.
If you are accessing the White-Label Platform through your relationship with an EHRC Licensee, you hereby agree that the EHRC Licensee may share your Personal Information with us in our capacity as a processor and that we are permitted to use such Personal Information in accordance with this Privacy Policy.
4. Your Access to and Control Over Information
You can do the following at any time by contacting us via the email address or phone number given on our Platform:
- See what data we have about you, if any.
- Change/correct any data we have about you.
- Request that we delete any data we have about you.
- Express any concern you have about our use of your data.
In some limited circumstances, a request for access to information may be legally denied by the EHRC as provided under applicable laws (e.g., where the disclosure of an individual’s Personal Information would reveal the Personal Information of a third party).
You may opt out of any future contact from us at any time. If you refuse to provide us with the information we require or later contact us to withdraw your consent for us to use and disclose your Personal Information, we may no longer be able to provide you with our Services. For instance, withdrawing your consent may result in a suspension or termination of your wage subsidy agreement with us as we would be limited in retaining and reporting your information to the Government of Canada.
In the event you are accessing the White-Label Platform through your relationship with an EHRC Licensee, you agree and acknowledge that we may not have the authority to honour your request under this Section without prior written approval of the applicable EHRC Licensee.
5. Third Party Platforms and Personal Information
The Platform may contain links to third party websites which we believe will be of interest and value to our visitors, including those of our business partners and industry stakeholders. While EHRC endeavors to link only to websites that share our high standards and respect for privacy, EHRC is not responsible for the privacy policies or other terms of use of these third party websites. Once you leave our servers, the use of any information you provide is governed by the privacy policy of the website you are visiting. We urge you not to supply Personal Information to these sites unless you have verified their security and privacy policies.
6. Retention of Personal Information
Your Personal Information is retained only as long as necessary for the fulfillment of those purposes in accordance with the applicable EHRC License Agreement or as otherwise permitted by applicable laws. We have procedures in place with respect to destroying, deleting or disposing of Personal Information when it is no longer required for the purposes set out in this Privacy Policy, the applicable EHRC License Agreement, or as otherwise required or permitted by law.
7. Accuracy of Personal Information
EHRC will endeavor to, but is not obligated, to ensure that all Personal Information it collects through the EHRC Platform is accurate, complete and up to date. It is your responsibility to inform EHRC or the applicable EHRC Licensee immediately of any change of name, address or other Personal Information.
8. Security of Personal Information
EHRC aims to protect any Personal Information we have in our possession by implementing commercially reasonable security safeguards, both electronic and physical, designed to protect against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.
In addition, EHRC ensures that its employees understand the importance of maintaining the confidentiality of Personal Information.
Unfortunately, no data transmission over the Internet or data storage system can be guaranteed to be 100% secure. Therefore, despite our efforts, we cannot guarantee its absolute security. We do not warrant or represent that personal information about you will be protected against, loss, misuse, or alterations by third parties.
Our Use of Cookies and Log Files
We use browser tracking cookies (or “cookies”), which are small text files that are placed on the hard disk of a computer by a website. Cookies are uniquely assigned to you, and can only be read by a website or web server that issued the cookie to you. We also use browser “log files” which record certain information when you visit a website, including your IP address. To improve your experience on our Platform, we use cookies and log files to: recognize you when you return to our Platform; keep track of activity on our Platform and remember what items you have clicked on or viewed; study how you navigate through our Platform and which website you request in site searches so that we can improve the design, content and function of our Platform; and customize the message, content and delivery of online banner advertisements and e-mails that reflect how you navigate to and through our Platform based on your online behavior. We call this “Browsing Data”. We may hire third-party service providers to assist us in the collection and analysis of this Browsing Data collected through cookies, but none of your personal information is disclosed to these third party service providers.
You have the ability to accept or decline our use of cookies. You can refuse cookies by turning them off or blocking them in your Internet browser. If you decide to turn off or block cookies, our Platform might not function correctly.
9. Contacting the Privacy Officer
This Privacy Policy addresses some of the main privacy concerns that you might have. If you have concerns regarding the EHRC’s Privacy Policy please contact:
The Privacy Officer
Electricity Human Resources Canada
2197 Riverside Dr., Suite 301
Ottawa, ON K1H 7X3