Privacy Policy

INFORMATION ABOUT THE COMPANY’S PRIVACY POLICIES AND PRACTICES EFFECTIVE JANUARY 1, 2004

Privacy Commitment

As of January 1, 2004, new federal or provincial privacy laws apply to most organizations in Canada. However, apart from certain administrative requirements, these new laws will not change how we deal with your personal information. Where your personal information was collected prior to January 1, 2004, Arbor Memorial Services Inc. (the “Company”) and its affiliates (“Affiliates”) will exchange, hold, use and disclose such information only for the purposes for which you could reasonably expect such information to be exchanged, held, used or disclosed or as required or permitted by law.

The Company and Affiliates are committed to ensuring that your personal information (generally any information about you as an identifiable individual) is collected, held, used, disclosed and protected, and that your privacy rights are respected, all in accordance with professional ethics and applicable law. The Company and Affiliates follow the same privacy policies and practices.

The Company’s Policies and Practices

The following explains how the Company will generally comply with its Privacy Commitment. Reference to “you” or “your” includes your personal representative. As with any legal or ethical requirements, there are exceptions.

1. Accountability

  • the Company is responsible for the protection of your personal information under its control
  • the Company has appointed as the individual (“Chief Privacy Officer”) who is accountable for the Company’s compliance with its Privacy Commitment, Mr. Gary Carmichael, whose contact information is:

Mailing Address: 2 Jane Street, Toronto, Ontario M6S 4W8
Telephone Number: 1-800-465-1270
E-mail Address: cpo@arbormemorial.com

  • if the Company uses the services of another organization requiring access to your personal information, the Company obtains assurances that the other organization will provide the information with a level of protection equal to that provided by the Company and will not hold, use or disclose the information for any other purpose except as required or permitted by law

2. Identifying Purposes

  • although the purposes for which the Company collects personal information are generally transparent, the Company makes all reasonable efforts to ensure that you understand these purposes
  • where the Company collects your personal information from any oral or written request by you for information about any product or service of the Company or any Affiliate or in connection with an order or written agreement with you for supply of a product or service, the Company identifies the purposes of the collection including any intended use or disclosure of the information, at the time of your request or order or in the agreement, unless the purposes are limited to fulfilling your request or order
  • if you are an employee or applicant for employment, the Company collects personal information about you for the purposes of establishing, managing or terminating your employment with the Company
  • the Company does not sell your personal information to other organizations, but may share your personal information with others; for example:
    • the Company, and Affiliates and other organizations providing products or services to you or the Company, may exchange, hold and use your personal information for the purpose of performing the Company’s or their obligations to you
    • the Company and Affiliates, and other organizations providing services to them, may exchange, hold and use your personal information for the purpose of advising you of products and services of the Company and Affiliates which may be of interest to you
    • the Company’s parent may have access to your personal information for the purpose of managing the Company
  • if you have any question about the Company’s collection, use or disclosure of your personal information, please contact our Chief Privacy Officer
  • the Company will not hold, use or disclose your personal information for any new purpose except as required or permitted by law, without first advising you of the purpose and obtaining your consent

3. Consent

  • where required, the Company obtains your consent to the collection, holding, use or disclosure of your personal information for specific purposes see Identifying Purposes
  • where the Company collects your personal information in connection with a request by you for information or an order or written agreement with you for supply of a product or service, the consent is inherent in the request or order or the consent will be oral, electronic or written
  • where the Company collects your personal information for secondary purposes, such as advising you of other products or services of the Company or Affiliates, the consent will be oral, electronic or written, or may, in certain circumstances, be assumed where the Company provides you at or before the time of collection of the information, and you have not exercised, a readily exercisable means of telling the Company that you do not want your personal information used for such purposes
  • if you are an employee, the Company collects, holds, uses and discloses personal information about you as part of the employment relationship
  • you may withdraw or vary your consent to the Company’s collection, use or disclosure of your personal information for secondary purposes, at any time, by giving reasonable notice to the Company by toll-free telephone at 1-800-465-1270 or please include your name and contact information by e-mail tocpo@arbormemorial.com or by mail addressed to the Company at 2 Jane Street, Suite 211, Toronto, ON M6S 4W8, Attention: Chief Privacy Officer
  • the Company will generally be able to give effect to any such withdrawal or variation on 30 days’ notice, and the Company will, if it has not already done so, advise you of the implications of the withdrawal or variation
  • to obtain information about the Company’s affiliates or other organizations which may have access to your personal information under the Company’s control, please contact our Chief Privacy Officer by toll-free telephone at 1-800-465-1270 or please include your name and contact information and the contract number of any contract you have with the Company for supply of a product or service by e-mail to cpo@arbormemorial.com or by mail addressed to the Company at 2 Jane Street, Suite 211, Toronto, ON M6S 4W8, Attention: Chief Privacy Officer.

4. Limiting Collection

  • the Company does not collect your personal information, without your consent, unless the collection is clearly in your interest and the Company is unable to obtain your consent in a timely way, or as permitted by law
  • the Company collects, holds, uses and discloses personal information only for legitimate purposes of its business, e.g., to establish, manage or terminate a business or employment relationship, to supply a product or service, to comply with the Company’s obligations under applicable law, or for related internal business or management or legal purposes
  • the Company will not, as a condition of supplying a product or service to you, require consent to the collection, holding, use or disclosure of your personal information beyond that reasonably required to supply the product or service, to comply with its obligations under applicable law, or for related internal business or management or legal purposes
  • the Company does not collect your personal information for any purpose which has not been clearly identified or is not obvious at or before the time of obtaining your consent
  • the types and uses of personal information about you collected by the Company are generally
  • your name and contact information, for any of the purposes identified below
  • your interest in obtaining information about products and services of the Company and Affiliates, for the purpose of providing such information and other related information which may be of interest to you
  • information required to make or administer your funeral and burial arrangements and assist your personal representative, family or friends, including information about them and your caregivers
  • information required to arrange or administer an annuity or insurance contract for you with Fortis Benefits Insurance Co. or National Assistance, Inc.
  • information reasonably required for the purpose of establishing, managing or terminating your employment relationship (including certain agency or contracting relationships) with the Company
  • certain information required by law
  • any of the foregoing information, for related internal business or management or legal purposes

5. Limiting Holding, Use and Disclosure

  • the Company will not hold, use or disclose your personal information except for the purposes for which it was collected or new purposes to which you have consented, or as required or permitted by law
  • the Company has adopted the following guidelines for the retention of your personal information:
    • where the information is being used for the purpose of keeping you advised about products and services of the Company and Affiliates, for a maximum of 3 years since your last request for information about such products or services, subject to earlier withdrawal of your consent to the use of your information for such purposes
    • where you have requested access to your personal information under the Company’s control see Access below, for a minimum of 6 months following the Company’s response to your request
    • where the information was used to make a decision that directly affects you, for a minimum of 1 year
    • otherwise, only so long as necessary for the Company and you to perform their obligations to one another, to comply with the Company’s obligations under applicable law, or for related internal business or management or legal purposes of the Company
  • where your personal information is no longer required by the Company, the Company will destroy the information

6. Accuracy

  • the Company uses reasonable efforts to ensure that your personal information is as accurate, complete and up-to-date as necessary for the purposes for which such information was collected by the Company, however the Company will primarily rely on you to advise it of any change in your contact information or other information necessary for the Company to perform its obligations to you

7. Safeguards

  • the Company has adopted organizational, physical and technological safeguards appropriate to the sensitivity of the information, e.g., limiting access on a “need-to-know” basis, restricted access and passwords, and where appropriate requiring you to provide identification in any communication with the Company about your personal information, to protect your personal information under its control
  • the Company’s staff are made aware, through training programs, of the absolute importance of maintaining confidentiality of your personal information
  • the Company conducts periodic internal and independent audits of its security safeguards
  • any breach of the Company’s security safeguards is a disciplinary matter
  • the Company’s security safeguards extend to destruction of your personal information

8. Openness

  • this information document is intended to provide you with specific information about the Company’s privacy policies and practices, however, if you have any question about our policies and practices, please contact our Chief Privacy Officer

9. Individual Access

  • subject to limited exceptions provided by law, you are entitled to access your personal information under the Company’s control, for a nominal fee, if any, by making a request in writing to our Chief Privacy Officer, including your name and contact information and the contract number of any contract you have with the Company for the supply of a product or service
  • the Company will generally respond to any request for access by informing you of the existence, source, use and disclosure of your personal information under the Company’s control, and providing you with a copy of or access to the information, within 30 days following receipt of the request
  • you are also entitled to challenge the accuracy or completeness of your personal information under the Company’s control, by giving written notice to our Chief Privacy Officer, including your name and contact information and a brief explanation of the amendment you wish to have made to your personal information and the reasons therefor
  • the Company will generally respond to any such challenge within 30 days following receipt of your notice
  • where your personal information is amended at your request, the Company will where appropriate advise any other organization to which the information has been disclosed of the amendment, or if your challenge is not resolved to your satisfaction, the Company will annotate the information and where appropriate advise any such other organization of the unresolved challenge

10. Challenging Compliance

  • if you have any complaint about the Company’s compliance with its Privacy Commitment, please contact our Chief Privacy Officer in writing, including your name and contact information and a brief description of your complaint
  • the Chief Privacy Officer will investigate your complaint, and will generally respond to you within 30 days of receipt of your complaint with any action proposed to be taken by the Company including any amendment to its privacy policies and practices
  • prior to making a complaint to the Chief Privacy Officer, or if such complaint is not resolved to your satisfaction, you may also make a complaint to:
    • if your complaint relates to any act or omission in Alberta:
    • The Office of the Information and Privacy Commissioner
      Suite 500, 640-5th Avenue SW
      Calgary, AB T2P 3G4
    • if your complaint relates to any act or omission in British Columbia:
    • Office of the Information and Privacy Commissioner
      3rd Floor, 756 Fort St.
      Victoria, B.C. V8W 9A4
    • if your complaint relates to any act or omission in Quebec:
    • Commission d’accs l’information
      480, boul. St-Laurent
      Bureau 501
      Montreal, PQ H2Y 3Y7
    • if your complaint relates to any act or omission in any other jurisdiction:
    • Office of the Privacy Commissioner of Canada
      112 Kent Street
      Ottawa, ON K1A 1H3

This information document is subject to amendment, and, as amended, will be effective as of the date of posting on our website at www.arbormemorial.com.