PRIVACY STATEMENT
DATE OF ISSUE: January, 2006

PREAMBLE:

This Privacy Statement is a simplified version of the privacy policy adopted by the Centre.

To review the Centre's full Privacy Policy and the Terms of Use of the Centre's Website, click on PRIVACY POLICY/TERMS OF USE at www.cars-council.ca (“the Centre's Privacy Policy/Terms of Use”).

The privacy principles hereinafter set out are based on the Personal Information Protection and Electronic Documents Act (Canada) (the “Act”).

THE CENTRE'S COMMITMENT TO PRIVACY - THE CENTRE:

• values its relationship with the users of its website (“the Centre's Website”) and is committed to the protection of their personal information (“Personal Information”);
  
• adheres to the 10 fundamental privacy principles set out below (the “Privacy Principles”). The commentary is provided to assist users in understanding the application of the Privacy Principles; and,
  
• is committed to controlling the collection, use and disclosure of Personal Information to ensure the accuracy, confidentiality and integrity of Personal Information.

WHAT IS PERSONAL INFORMATION?

Personal information is collected by the Centre only when you specifically and knowingly choose to provide it to the Centre.

“Personal Information” means information about an “identifiable individual”, such as your name, residential address and e-mail address and may include information about your education, employment, training, training evaluation results/scores, subscriptions, website usage, credit information, billing information and records and Personal Information obtained from the Centre's business partners and other third parties, provided that such third parties confirm to the Centre that they have obtained the proper consent to the disclosure of Personal Information.

Personal Information does not include publicly available information, the name, title, business address or telephone number of an employee of an organization, “anonymous” or “non-personal” information gathered by the Centre through the Centre's Website or links thereto, which may be used for technical, research and analytical purposes, and information collected through surveys, existing files and public archives, all of which may be used by the Centre to analyze training and other needs in the Canadian automotive industry (“the Industry”) and to develop or enhance the services offered by the Centre.

THE COLLECTION AND USE OF PERSONAL INFORMATION:

The Centre will seek your prior consent to the collection, use and disclosure of Personal Information as required by applicable privacy legislation.

Your Personal Information will not be used for any other purpose without your consent.

Subject to legal and contractual requirements, you can refuse to consent to the Centre's collection, use or disclosure of Personal Information.

You may also withdraw your consent to any further collection, use or disclosure of your Personal Information at any time by giving the Centre reasonable written notice.

If the Centre's intended use or disclosure of Personal Information changes, the Centre will notify you accordingly, by e-mail or otherwise.

You have the option to advise the Centre not to share Personal Information, or to be excluded from offers for other the Centre services or to revoke any consent previously provided. Failure to provide the Centre with the necessary consents may, however, restrict your use of certain of the Centre's Website and other services.

The Centre may share Personal Information with selected third parties who are acting on its behalf as its agents, suppliers or service providers. Such third party service providers are provided only with such Personal Information as is necessary in the circumstances. Personal Information provided to third parties may be used only for the purpose stipulated and is subject to strict terms of confidentiality.

DISCLOSURE : Unless you specifically authorize the Centre to release Personal Information by accepting the Centre's Privacy Policy/Terms of Use or otherwise, or the release of Personal Information is required or permitted by law, the Centre will not disclose Personal Information to other third parties.

USE OF COOKIES : The Centre uses a browser feature called a “cookie” to collect information anonymously and track user patterns on the Centre's Website. A cookie is a small text file that is placed on your hard disk by a website. “Cookies” contain a unique identification number that identifies your browser, but not you, to the Centre's computers each time you visit one of these websites. The use of cookies is an industry standard and many major browsers are initially set up to accept them. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie. However, if you refuse to accept cookies, you may not be able to use some of the features available on the Centre's Website.

ACCURACY:

The Centre will use it best efforts to ensure that Personal Information about you is accurate, complete and up-to-date. It is your responsibility to inform the Centre immediately of any change of name, address or other Personal Information.

In the event you have questions about the accuracy of Personal Information that the Centre has collected about you, you will have access to that Personal Information in order to verify and update it.

If the Centre has disclosed inaccurate Personal Information about you to a third party, the Centre will be pleased to immediately contact the third party in order to correct any such inaccuracy.

SECURITY:

The Centre is committed to protecting your privacy. Security measures, such as locked filing cabinets, restricted access and the use of user names, passwords, firewalls and encryption have been adopted to protect your Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

The Centre employees have been trained to respect your privacy at all times, and those employees with access to your Personal Information shall use your Personal Information strictly in accordance with the Privacy Principles and the laws applicable to each specific business.

ACCESS:

If you have any questions about the collection, use or disclosure of your Personal Information or if you simply want to know whether the Centre has any of your Personal Information on file, you may contact the Centre's Privacy Officer by e-mail at: centre@cars-council.ca, or in writing at:
Attention: Privacy Officer
C.C.A.I.D.L.
9120 Leslie Street
Richmond Hill, Ontario L4B 3J9

The Centre will respond to your requests for access in accordance with applicable privacy legislation.
Except in limited circumstances, as specifically provided by applicable privacy legislation, the Centre can tell you whether it holds Personal Information about you, the source of the Personal Information, allow you access to your Personal Information and provide an accounting of the use that has been made or is being made of this Personal Information and the third parties to which it has been disclosed.

The Centre will only refuse you access to Personal Information about you in those circumstances permitted or required by applicable privacy legislation.

If the Centre refuses you access to your Personal Information, it will provide you with the reasons for its refusal upon request. Exceptions may include information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.

QUESTIONS OR CONCERNS:

If you have any questions or concerns regarding the Personal Information about you held by the Centre or about the compliance by the Centre with the Privacy Principles, please contact the Centre's Privacy Officer, as set out above.

The Centre has procedures in place to receive and respond to complaints or inquiries about its handling of Personal Information and will describe the complaint procedures to anyone who makes inquiries or lodges complaints.

If you are not satisfied with the response from the Centre's Privacy Officer after making a complaint, you may have recourse to additional remedies under applicable privacy legislation. For further information, please contact the federal Privacy Commissioner or your provincial Privacy Commissioner, as applicable.

TEN BASIC PRIVACY PRINCIPLES
(WITH THE CENTRE'S COMMENTARY THEREON):

Principle #1 - Accountability : The Centre is responsible for all Personal Information under its control and shall designate one or more individuals who shall be accountable for the Centre's compliance with the procedures and Privacy Principles set out in the Centre's Privacy Statement and the Centre's Privacy Policy/Terms of Use. The Centre's Privacy Officer is responsible for the administration of the Privacy Principles even though other individuals within the Centre's organization have responsibility for the day-to-day collection and processing of Personal Information.

Principle #2 - Identifying Purposes : The Centre will identify to you the purposes for which the Centre collects, uses, or discloses Personal Information at or before the time of collection. The Centre will communicate the purposes for which Personal Information will be used to the individual from whom the Personal Information is collected, either at the time of collection or after collection, but before its use. These purposes will be limited to those which are related to the Centre's business and which a reasonable person would consider are appropriate in the circumstances and include: better understanding your needs and advising you of the Centre's services and programs in the Industry; the use of anonymous or “non-personal” information gathered by the Centre through its website for technical, research and analytical purposes; the use of information collected (through surveys, existing files and public archives) by the Centre to analyze its market and to develop or enhance the services it is offering to the Industry; evaluation of the Centre's services and programs; establishing communication with you; providing you with information as to available services in the Industry and related thereto; training; training/skills evaluations; conducting market research and surveys; and, for other purposes in furtherance of the Centre's Objects. If the Centre plans to use Personal Information collected for a purpose not previously identified or referred to in the Centre's Privacy Policy/Terms of Use, the Centre will identify this purpose and communicate it to you before such use and obtain your consent to such use.

Principle #3 - Consent : Personal Information will only be collected, used or disclosed with the knowledge and consent of the individual, except where inappropriate. The way in which the Centre seeks consent is by having you agree to the Centre's Privacy Policy/Terms of Use found on the Centre's Website. The Centre may request further consents for the collection and disclosure of additional Personal Information by e-mail notice or otherwise in the future. Subject to legal and contractual restrictions and on reasonable notice, an individual can withdraw consent at any time. The Centre will inform individuals of any implications of withdrawing consent. The Centre will usually seek consent for the use and/or disclosure of Personal Information at the time of collection of the Personal Information or registration for its' website use. In certain circumstances, consent may be sought after the Personal Information has been collected, but before use (such as where the Centre wants to use Personal Information for a purpose not previously identified). The Centre will not, as a condition of the supply of services, require any individual to consent to the collection, use, or disclosure of Personal Information beyond that required to fulfill the explicitly specified and legitimate purposes. In certain circumstances, as permitted or required by law, the Centre may collect, use or disclose Personal Information without the knowledge or consent of the individual. These circumstances include: Personal Information which is subject to solicitor-client privilege or is publicly available as defined by regulation; where collection or use is clearly in the interests of the individual and consent cannot be obtained in a timely way; to investigate a breach of an agreement or a contravention of a law; to act in respect to an emergency that threatens the life, health or security of an individual; for debt collection; or, to comply with a subpoena, warrant or court order.

Principle #4 - Limiting Collection : The Centre will limit the amount and type of Personal Information collected to that which is necessary for the Centre's identified purposes, and the Centre will only collect Personal Information by fair and lawful means.

Principle #5 - Limiting Use, Disclosure and Retention : Personal Information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal Information will be retained only as long as necessary to fulfill the identified purposes. Personal Information which has been used to make a decision about an individual will be retained long enough to allow the individual access to the Personal Information after the decision has been made and, in the event of an access request or a challenge, long enough to exhaust any recourse an individual may have under the law. Where Personal Information is no longer required to fulfill the identified purposes, it will be destroyed, erased or made anonymous. The Centre may share Personal Information with third parties who are contracted to complete research, administrative services or work on a the Centre Project. In such cases, the Privacy Principles will bind the third party(s).

Principle #6 - Safeguards : The Centre will protect Personal Information with safeguards appropriate to the sensitivity of such information. The Centre's safeguards will protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the Personal Information is held. The Centre will make its employees aware of the importance of maintaining the confidentiality of Personal Information, and will exercise care in the disposal or destruction of Personal Information to prevent unauthorized parties from gaining access to the Personal Information. The Centre's methods of protection will include physical measures (for example, locked filing cabinets and restricted access to offices),organizational measures (for example, limiting access to Personal Information on a “need-to-know” basis), and technological measures (for example, the use of user names, passwords and encryption).

Principle #7 - Openness : The Centre will make available specific information about the Centre's policies and practices relating to the management of Personal Information. The information the Centre will make available will include: how to gain access to your Personal Information; the type of Personal Information in the Centre's files/data base, including a general history of its use by the Centre; information on the Centre's Privacy Policy/Terms of Use and policies in regard thereto; the type of Personal Information made available by the Centre to related companies; and, how to contact the Centre's Privacy Officer; and, the procedure to use in the event you wish to make a complaint about the Centre's privacy practices.

Principle #8 - Accuracy : The Centre will use its best efforts to ensure that Personal Information is as accurate, complete and as up-to-date as is necessary for the purposes for which it is to be used. The Centre will use its best efforts to ensure that Personal Information that is used on an ongoing basis, including information that is disclosed to third parties and information that is used to make a decision about an individual, is accurate, complete, and up-to-date.

Principle #9 - Individual Access : Upon written request, the Centre will inform an individual of the existence, use and disclosure history of his or her Personal Information and, if permitted by applicable privacy legislation, the Centre will give the individual access to the specific Personal Information requested. An individual may challenge the accuracy and completeness of his or her Personal Information in the Centre's possession and have it amended as appropriate. The Centre will respond to an individual's written request within a reasonable time (generally within 30 days). The Centre will assist any individual who informs the Centre that they need assistance in preparing a request. The Centre may require an individual to provide sufficient information to permit it to provide an account of the existence, use and disclosure of Personal Information. In providing an account of third parties to which the Centre may have disclosed Personal Information about an individual, the Centre will attempt to be as specific as possible. When it is not possible to provide a list of the organizations to which it has actually disclosed Personal Information, the Centre will provide a list of organizations to which the Centre may have disclosed the Personal Information. If an individual successfully demonstrates the inaccuracy or incompleteness of Personal Information, the Centre will amend the Personal Information as required. If a challenge is not resolved to the satisfaction of the individual, the Centre will record in its records the substance of the unresolved challenge. Where appropriate, the amended Personal Information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the Personal Information in question. In certain situations, the Centre may refuse a request or not be able to provide access to all the Personal Information held about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law, and may include: information that contains references to other individuals or contains confidential commercial information, where such information cannot be severed from the record; information collected in the course of investigating a breach of an agreement or in the course of a formal dispute resolution process; and information that is subject to solicitor-client privilege. Where permitted, the reasons for denying access will be provided to the individual upon request.

Principle #10 - Challenging Compliance : Any individual can direct a challenge concerning the Centre's compliance with any of the Privacy Principles to its Privacy Officer. The Centre will actively investigate all written complaints. If the Centre finds a complaint to be justified, the Centre will immediately take all appropriate measures to remedy any such complaint, including, if necessary, amending its policies and practices.