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Oxford Consulting Group
Ltd. (OCG) and its affiliates are committed to the proper
management of information pertaining to clients and others,
and of all visitors to our website (the “Site”)
that we collect, use and disclose in the course of business.
In providing advice to clients, we have a professional
obligation to maintain the confidentiality of information
that we receive within a consultant–client relationship.
The practices set out in this privacy policy (the “Policy”)
seek to balance the business' and individual’s right
to the privacy of their business and personal information
with OCG’s need to collect, use or disclose
information for legitimate business purposes.
Controlling the collection, use and disclosure of business
and personal information is an ongoing process. We will
continue to review our information management practices
and improve them as necessary to better protect the privacy
of individuals. This Policy was last amended on the November
1, 2007.
What Is Business Information?
Business information means any information that can be
used to identify your company, including your operating
name, registered name, telephones numbers and addresses,
email addresses, information obtained during the course
of an engagement, the matter about which you retained
or contacted OCG, your account with us and any other
information
that you choose to provide to OCG. OCG will not confirm
the identity of a client (business or individual) or
any associated information without the written consent
of that client.
What Is Personal Information?
Personal information means any information that can be
used to identify you as an individual, including your
name, personal telephone number and address, email address,
information in your résumé or about your
employment, the matter about which you retained or contacted
OCG, your account with us and any other information that
you choose to provide to OCG.
Your Consent
By providing us with your personal information, you consent
to the collection, use and disclosure of that information
as described in this Policy. We will not, as a condition
of supplying a product or service, require you to consent
to the collection, use or disclosure of your personal
information beyond that required to enable us to provide
the products or services requested. The form of the consent
that we will seek before collecting, using or disclosing
personal information may vary depending upon the circumstances
and the type of information, and includes express oral
or written consent, implied consent and opt-out consent.
We will consider the sensitivity of the information and
the individual’s reasonable expectations in determining
how consent must be given.
You may refuse to give personal information and may, subject
to legal or contractual restrictions and reasonable notice,
withdraw consent at any time to the continued use and disclosure
of personal information previously collected. The period
of reasonable notice will vary depending on the nature
of the information and its purpose to OCG. OCG will inform
you of the implications of refusing or withdrawing consent,
which may have legal consequences or preclude OCG from
providing consulting or other services.
Collection of Business and Personal Information
We will not collect business and personal information indiscriminately.
We will limit the amount and the type of information
we collect to that necessary to fulfill the purposes
we have identified to you, or as otherwise permitted
or required by law. We may also collect information about
your business and business interests or your personal
interests to better serve you and foster our relationship.
When possible, we will collect personal information from
you directly. However, to provide consulting services to
clients or for legal, administrative, marketing or management
purposes, we may also collect personal information through
outside sources such as credit bureaus, government agencies
or institutions or through other third parties such as
employment and other references, employers and service
providers.
Internet Server Provider
Certain other information may be collected on the Site
through various technologies, described below, without
your actively providing the information.
Our website is hosted on servers shared with an Internet
Service Provider (“ISP”). Any personal information
collected on our behalf by the ISP, such as server log
data (see below), is managed in accordance with this Policy
and is protected by applicable law.
Certain information about Internet users’ traffic
patterns is passively and automatically collected and linked
to users’ Internet Protocol (“IP”) addresses.
These unique IP addresses are assigned to all web users
by their ISP's, and are automatically logged by Internet
servers. While the IP address itself does not identify
an individual, it may, in appropriate circumstances such
as an investigation of a security breach, be used with
the cooperation of the ISP to locate and identify an individual
using the website.
Server Logs
In the normal course of establishing and maintaining Internet
connections, our servers automatically log information
about visits to our website. Server logs record statistical
information, such as a visitor’s IP address and
type of operating system, the time and duration of visit
and Web pages requested. The server logs also identify
categories of visitors by items such as domain and browser
type. These statistics are reported in aggregate form
to us and are used to improve our website and ensure
that it provides the optimal online experience for visitors.
We do not link server log information to any other data
in a way that would enable us to identify individual visitors,
except for purposes discussed above.
Cookies
Like many other websites, our Site makes use of cookie
technology. Cookies are small text files
that contain a unique identification number
that is automatically deposited on a visitor’s computer.
These cookies track information during an open session
and are stored only temporarily in your computer.
This information helps us determine the total number of
visitors to the Site on an ongoing basis and the types
of Internet browsers (e.g., Netscape Navigator or Internet
Explorer) and operating systems (e.g., Windows or Macintosh)
that our visitors use. We use this information to facilitate
and enhance your online visits. We do not cross-reference
this information with any type of personal information
that is voluntarily offered through the Site.
The use of cookie technology is common on the Internet,
and many Internet browsers are initially set to accept
cookies automatically. If you would prefer not to accept
cookies, you can set your Internet browser to notify you
when your computer is receiving a cookie or to refuse cookies
automatically. To readjust your Internet browser’s
cookie options, please refer to the instruction documentation
of your particular browser or seek online assistance.
Use of Personal Information
We use personal information only as described in this Policy
or as otherwise permitted or required by law. Before
your personal information is used or disclosed for a
new purpose, we will ask for your consent unless use
or disclosure without your consent in the circumstances
is otherwise permitted or required by law.
OCG generally uses personal information about clients
for the provision of consulting advice, including obtaining
and carrying out client instructions, reporting and communicating
with clients, billing and accounting, and protecting against
fraud, illegal activities or error. OCG may also use your
personal information to send you newsletters about our
services or about industry/IT/business developments that
we think would interest you. To establish or enhance our
relationship, we may invite you to client functions, seminars
and sporting or cultural events.
We regularly distribute client memos, practice group bulletins,
articles and other consulting updates and publications
to people on our mailing lists, who can elect to receive
materials on one or more subject matters. At any time,
you may change your preferences and mailing option (regular
mail or email), or unsubscribe from our mailing lists.
If you send personal information through our Site, we
will use it to assess website use and traffic, and to respond
to your feedback, questions and comments.
Disclosure of Personal Information
We disclose personal information only as described in this
Policy or as otherwise permitted or required by law.
To provide consulting services, we may sometimes disclose
our clients’ personal information to OCG’ affiliates,
foreign agents and government or regulatory agencies.
At times we may also disclose personal information to
service providers, inside or outside Canada, that assist
us with marketing or other services, including technical
support and mailing. We limit the service provider’s
right to use the personal information only for the services
it provides to us, and we require the service provider
to maintain the confidentiality of the personal information
and to take steps to protect the security of the personal
information we give it.
Our staff in London, Toronto, and Detroit may share your
personal information internally to perform consulting services
or for marketing purposes.
Your personal information may be accessed or stored in
Canada or another jurisdiction, and may be subject to the
laws of that jurisdiction.
Retention of Personal Information
OCG will retain information, including personal information,
for as long as it is needed for the purposes for which
it was collected. For example, if you send us personal
information electronically to apply for employment with
OCG, we will retain your personal information for a reasonable
period to permit future consideration for employment.
OCG may also be subject to legislative requirements regarding
the retention of certain types of information.
Protection of Business and Personal Information
We use the standard safeguards of the management consulting
profession to protect the security of business and personal
information in our possession, including physical, organizational
and technological measures.
Links to Other Websites
The Site may contain links to other websites. While we
try to link only to websites that share our standards
and respect for privacy, we are not responsible for the
content or privacy practices of other websites. We strongly
encourage all Site visitors to review the privacy statements
and policies of all external websites.
More Information About OCG's Privacy Practices
You can ask to view your personal information by writing
to the Privacy Compliance Officer, who can be reached
by email at privacy@ocg.ca or at the mailing address
listed on the contact pages. You can request that corrections
be made where you can show that the information we possess
is incorrect or incomplete. Please note that under certain
circumstances, you may not be permitted to view your
records, such as where the disclosure of your records
would cause security, legal or confidentiality concerns.
Please contact OCG’s Privacy Compliance Officer
with any questions or concerns you have about this Policy
or OCG’s handling of your personal information. We
will investigate and respond to your concerns. If you are
not satisfied with our response, the Privacy Commissioner
of Canada can be reached at:
112 Kent Street,
Ottawa Ontario
K1A 1H3
1.800.282.1376
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