Nunavut Development Corporation
PRIVACY STATEMENT1. Introduction
The handling of Personal Information by Government of Nunavut organizations, including the Nunavut Development Corporation (“NDC”), is governed by the Access to Information and Protection of Privacy Act (link) (“ATIPPA”). ATIPPA generally provides persons who make a request of a government organization with a right of access to any record in its custody or under its control. However, Personal Information about individuals other than the requester is generally excluded from this right where disclosure would constitute an unreasonable invasion of privacy.
For more information about ATIPPA and its application, please refer to the website of the Legislation Division of the Justice Department of the Government of Nunavut or the website of the Information and Privacy Commissioner of Nunavut.
The NDC is mandated to create employment and income opportunities for residents of Nunavut, especially those in smaller communities; stimulate the growth and development of local businesses; and promote economic diversity and long-term stability. While undertaking our mandate, the NDC may collect Personal Information, and we have prepared this privacy statement to inform you about our ongoing commitment to ensuring that the Personal Information obtained during the course of our activities remains accurate and confidential.
By providing Personal Information to NDC, you agree and consent that we may collect, use, and disclose your Personal Information in accordance with this privacy statement. Unless permitted by law, NDC does not collect, use, or disclose Personal Information without consent.2. What is Personal Information?
“Personal Information” means information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information, including the individual’s name, home or business address or home or business telephone number; the individual’s demographic information; and educational financial, criminal or employment history, etc. This privacy statement does not cover aggregate data from which the identity of an individual cannot be determined.3. Why NDC Collects and Uses Personal Information
NDC may use Personal Information provided to NDC for programs or activities in order to fulfill its mandate. The Personal Information collected by NDC may include:
a. Personal Information received from you on applications or personal net worth statements with respect to a proposed development project, whether the forms are received in writing or electronically. For example, this information may include your name, address, social insurance number, assets, liabilities and your bank account information that permits us to complete appropriate credit checking and other reporting;
b. Information about your banking and financial history with other financial or credit granting institutions. This category also includes your communications to us concerning your bank account(s) or loan account(s) history;
c. Contact and payment information relating to the sale and marketing of Nunavut produced arts and crafts to commercial clients;
d. Other general information that we may obtain about you in the course of evaluating your application, planning or executing a project in relation to our mandate;
e. Meeting any legal or regulatory requirement;
f. For the purpose of hiring, managing or administering personnel;
g. Contact and payment information relating to contracts entered into with third parties; and
h. Such other purposes consistent with the foregoing purposes.
The personal information we ask for will depend upon your involvement with NDC.
Personal Information about users of our services will be collected, to the extent possible, directly from the individual concerned. Unless permitted by law, no Personal Information is collected about an individual without first obtaining the consent of the individual to the collection, use and disclosure of that information. You can change your consent preferences at any time, upon providing reasonable, advance notice, by contacting NDC.4. When NDC may disclose your Personal Information Access to Information
As discussed above, all government organizations, including NDC, may be required to disclose Personal Information in accordance with ATIPPA further to a request for information. While Personal Information about individuals other than the requester of information is generally excluded from the requester’s right to information if it would constitute an unreasonable invasion of privacy, there are circumstances in which Personal Information may be disclosed. For example, disclosure of Personal Information is not an unreasonable invasion of a person’s personal privacy where:
- the person has consented to the disclosure;
- there are compelling circumstance affecting the health or safety of any person;
- the disclosure is for an authorized research purpose;
- the disclosure reveals details of a discretionary benefit of a financial nature granted to the person by a public body, but not Personal Information supplied in support of the application for the benefit; or
- the disclosure reveals financial and other details of a contract to supply goods or services to a public body.
Where your Personal Information may be disclosed further to a request for information, you will generally be afforded an opportunity to make representations concerning the disclosure.
As noted above, more information about ATIPPA and its application is available on the website of the Legislation Division of the Justice Department of the Government of Nunavutand the website of the Information and Privacy Commissioner of Nunavut.Disclosure of Personal Information in other Circumstances
Aside from disclosure pursuant to an access to information request, NDC may also disclose Personal Information in the course of pursuing its mandate of creating employment opportunities and developing a diverse and stable economy for the citizens of Nunavut. Indeed, NDC works with other organizations, associations and agencies in the course of pursuing its mandate and may share Personal Information with such organizations but only as permitted by law. Below are some examples of third parties to whom we may disclose Personal Information. While these examples do not cover every situation permitted under law, we trust they help you understand how your information may be shared.
NDC may disclose Personal Information:
a. with consulting firms, companies and individuals that work for NDC on a contract basis analyzing various components of credit requests, or to provide services, opinions or process transactions. For example, NDC may use outside consulting firms to assist with complex analysis of credit requests, with banks for process transactions and with law firms in the creation of placement and security documentation;
b. to organizations involved in the distribution chain for the purchase and sale of your products through our Sales Division;
c. to process your purchases from our Sales Division;
d. with a party representing you, such as your accountant, lawyer or consulting firm retained by you or to other third parties at your discretion / consent;
e. when permitted or required by law, including to the Auditor General of Canada for audit purposes; to Nunavut Archives for archival purposes; in response to a subpoena or other legal process; or for tax reporting purposes to the Canada Revenue Agency.
In the event sensitive Personal Information is provided to NDC, we will not disclose such Personal Information unless it is required by law or we otherwise have your consent. Where obliged or permitted to disclose information without consent, NDC will not disclose more information than is required.
Additionally NDC may disclose Personal Information to companies that perform services on our behalf or to other financial institutions with which we do business. These companies are under contractual obligation to protect the confidentially of your information and to use it only to provide the services we have asked them to perform.
If you wish to withdraw consent to your personal information being collected, used and disclosed for the purposes listed above, please contact us at the number or address listed below. However, in some circumstances, legal requirements may prevent you from withdrawing consent. We may also limit the products and services we provide to you if you withhold or withdraw consent if the collection, use and disclosure of your personal information are necessary for provisions of the product or services.5. Confidentiality and Security
Our Employees are required to follow procedures with respect to maintaining the confidentiality of Personal Information. Additionally, we maintain physical, electronic, and procedural safeguards to protect the information. This includes performing ongoing evaluations of our systems containing customer information and making changes where appropriate.6. Accuracy and Access
NDC keeps your Personal Information as up to date, accurate and relevant as is required for its intended use. Where your Personal Information is used to make a decision that directly affects you, NDC will make every reasonable effort to ensure the information is accurate and complete; and retain the information for at least one year after using it so that you have a reasonable opportunity of obtaining access to it.
You may request access to the Personal Information we have on record in order to review and amend the information, as appropriate. In circumstances where your Personal Information has been provided by a third party in the 12 months before a request for correction, we will notify the third party of the correction or the request for correction. To access your Personal Information, please contact us at the number or address listed at the end of this Statement.7. We limit retention of your Personal Information
NDC only retains Personal Information for as long as is required to fulfil the purposes listed above or as otherwise required or permitted by law.8. NDC Reviews its Privacy Policies
We have also appointed a Privacy Officer at NDC to address concerns, queries or complaints you may have. Our Privacy Officer may be reached at the number above, by email at firstname.lastname@example.org or by regular mail at Nunavut Development Corporation, P.O. Box 249, Rankin Inlet NU, X0C-0G0 Attn: Privacy Officer.