Your privacy is important to us at St. James Volkswagen and the purpose of this Privacy Policy is to ensure that your personal information is protected and that all of our practices and procedures are compliant with the relevant data protection laws.
The Policy below is organized according to the principles of the Canadian Standards Association's Model Code, which forms the base of the Personal information Protection and Electronic Documents Act ("PIPEDA").
1. Accountability
Joan Saladin is the St. James Volkswagen Privacy Officer. She trains all of our staff in how to handle the personal information of customers and employees. She will also be happy to provide any information about the Policy and about your personal information, including supplying you with copies of whatever personal information of yours that we may have.
In our efforts to maintain the accuracy of your personal information we ask that you contact Joan with any changes in your personal information that may occur over the course of either your customer relationship, or your employment with St. James Volkswagen.
Joan can be contacted by one of the following methods:
- By telephone: 788-1100 - By facsimile: 788-1109 - By email: melanied@stjamesaudi.com - By mail: 670 Century Street Winnipeg, Manitoba R3H 0A1
2. Identifying the Purposes for the Collection of Personal Information
St. James Volkswagen collects customer and employee personal information only for the following purposes:
- To obtain a license for your vehicle; - To obtain a credit report if you are financing or leasing your vehicle; - To obtain appropriate financing of your vehicle for you; - To provide you with a reminder that your vehicle requires servicing; - To provide you with updates and information regarding products and services that we have to offer and that we think will interest you; - To manage and develop St. James Volkswagen's business and operations, including personnel and employment matters; and - To meet legal and regulatory requirements.
St. James Volkswagen shall specify orally, electronically or in writing the purposes of collecting your personal information to you at or before the time that personal information is collected. Upon request, persons collecting personal information shall explain these identified purposes or refer you to the Privacy Officer who shall explain these purposes.
Unless required by law, St. James Volkswagen shall not use or disclose your personal information for any new purpose without first identifying and documenting the new purpose and obtaining your consent.
3. Obtaining Consent for Collection, Use or Disclosure of Personal Information
A customer or employee's knowledge and consent is required for the collection, use, or disclosure of personal information, except where inappropriate. In certain select circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual.
For example, St. James Volkswagen may collect or use your personal information without your knowledge or consent if it is clearly in your interests and consent cannot be obtained in a timely way, such as when you are seriously ill or mentally incapacitated.
We may also collect, use, or disclose personal information without your knowledge or consent if seeking consent might defeat the purpose of collecting the information, such as in the investigation of a breach of an agreement or a contravention of a federal or a provincial law or where the life, health or security of an individual is threatened.
We may also collect, use, or disclose personal information without your knowledge or consent to a lawyer representing St. James Volkswagen in the collection of a debt, to comply with a subpoena, warrant or other court order, or as may be required or authorized by law.
Generally St. James Volkswagen shall seek consent to use and disclose personal information at the same time or before it collects the information. However we may seek consent to use and disclose personal information after it has been collected, but before it is used or disclosed for a new purpose.
4. Limiting the Collection of Personal Information
We limit the information we collect to that which is necessary to deliver a high level of service, to perform standard billing and accounting practices and to manage personnel and payroll issues. St James Volkswagen gathers information for no other purpose.
St. James Volkswagen may collect some or all of the following customer personal information when you come to us to lease or purchase a vehicle, service or repair a vehicle, finance a vehicle through us, purchase or lease other products and services from or through us, participate in one of our surveys, contests or promotions, test drive one of our vehicles or contact our dealership staff:
- Name, address and telephone number; - Email address and facsimile number; - Occupation; - Information about driving habits (such as preferred car sized, color, type of vehicle, kilometers driven annually, etc.); - Information about the exiting vehicle and any trade-in; - Details of the vehicle and its service history; - Driver's license number; - Name of the insurance company and the agent you are using; - Insurance policy number and details about the insurance coverage; - Similar information about members of your family; - Language preference; - Date of birth for customer and family members; - Your social insurance number and those of your family members; - Financial and credit information about the customer and other family members; - Principle amount of loan, interest and repayment schedules; - Health information if you are applying for life, health, disability or accident insurance; - Amount of any life, health, disability or accident insurance and details of that insurance.
St. James Volkswagen may collect some or all of the following employee information during the course of your employment with St. James Volkswagen:
-Name, address and telephone number; -Social Insurance number; -Resume information; -Name, address and account number of banking institution; -Date of birth; -Information regarding family members; -Any allergies or medical conditions; -Emergency contact name and phone number; -Physician's name and phone number.
5. Limiting Use, Disclosure and Retention of Personal Information
St. James Volkswagen shall not use or disclose your personal information for purposes other than those for which it was collected, except with your consent or as required by law. Personal information shall only be retained as long as necessary to fulfill the purpose for which it was collected. We will not sell your personal information to third parties.
St. James Volkswagen may disclose customer information to:
- The manufacturer or your vehicle and/or its related parties; - The providers of products or services relating to your vehicle; - Credit reporting agencies; - Financial institutions or financing companies; - Your insurance agent or company as well as companies that provide warranties or insurance relating to your vehicle; - A third party or parties, where you consent to such disclosure or as we are required by law.
St. James Volkswagen may disclose employee personal information during the course of:
a) normal personnel and benefits administration; b) providing references regarding current or former employees in response to requests from prospective employers; or c) as may be required by law.
St. James Volkswagen will retain customer personal information for as long as we believe that you are still the owner of the vehicle. If the information is relating to the financing or leasing of the vehicle, we will retain the information until those arrangements have ceased. If the information relates to the service or repair of your vehicle, your information will be retained for as long as is reasonably necessary to address any issues arising for the service or repair of the vehicle. If there are legal requirements relating to the period of time which we must retain your personal information, we will comply with those requirements.
St. James Volkswagen shall keep employee personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about an employee, St. James Volkswagen shall retain, for a period of time that is reasonably sufficient to allow for access by the employee, either the actual information or the rationale for making the decision.
6. Accuracy of Personal Information
Your personal information shall be accurate, complete and up to date as is necessary for the purposes for which it is to be used. St. James Volkswagen encourages you to contact us should your personal information change so that we may ensure its accuracy. If you have concerns about your information?s accuracy, please contact our Privacy Officer.
7. Security Safeguards
St. James Volkswagen takes your personal information seriously. We will protect your personal information by security safeguards appropriate to the sensitivity of the information. Information such as health and financial data, will be protected by using locked filing cabinets and locked doors, or when stored electronically protected by using safeguards such as passwords and encryption.
St. James Volkswagen will protect your personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is being used.
8. Openess Concerning Practices and Policies
This Privacy Policy shall always be readily available to customers and employees who request a copy. If you would like a copy please contact our Privacy Officer.
9. Customer and Employee Access to Personal Information
Upon request, St. James Volkswagen will inform you of the existence, use and disclosure of your personal information. This information will be provided to you at minimal or no cost, in an understandable form and within a reasonable amount of time.
10. Challenging Compliance
St. James Volkswagen is anxious to ensure that our Privacy Policy meets your concerns and responds to your needs. If you would like to discuss your personal information our Privacy Officer is available to receive your enquiries, comments and complaints. If for some reason you are not satisfied with some aspect of our Policy or the manner in which we have dealt with your personal information, you may contact the Office of the Federal Privacy Commissioner, 112 Kent Street, Ottawa, Ontario, K1A 1H3.
