Privacy Policy

Scope of this Policy

This Privacy Policy (the “Policy”) is in compliance with the federal Personal Information Protection and Electronic Documents Act (PIPEDA, otherwise know as “the Act”) and applies only to personal information that S.G. Smallwood Inc. (the “Company”) collects, uses or discloses in the course of its business operations with regards to the following:

  • users (each, a "User") of the Company website ("Site"); and
  • Company applicants for employment, employees, volunteers, contractors, sub-contractors and third-parties;
  • identifiable individuals from any other organization.

Personal Information

Personal Information under PIPEDA is defined as any factual or subjective information about an identifiable individual.

This includes, but is not limited to, information such as:

  • a person’s age, name, address, phone number, email address, photograph, financial information, education, behavioural information, opinions, evaluations, comments, social status, disciplinary actions; and
  • employee files, credit records, loan records, medical records, intensions (for example to acquire goods or services, change jobs)

Personal information in this Policy relates specifically to that which is under the custody or control of S.G. Smallwood Inc.

Policy Statement

S.G. Smallwood Inc. is committed to complying with the federal Personal Information Protection and Electronic Documents Act.

The Company will endeavour to handle personal information that it collects, uses or discloses in the course of conducting its business operations in the following manner:

  • protection of personal information and the fair handling of it at all times, throughout the Company and in dealings with third parties;
  • provide access to personal information as per “Accessing Personal Information” in this Policy;
  • ensure that collection, use or disclosure of personal information is only for purposes that are appropriate in the circumstances;
  • obtain the individual’s consent for the Company to collect, use or disclose the individual’s personal information and only for the purpose for which it was collected;

Why we Collect Personal Information

S.G. Smallwood Inc. may collect personal information for the following reasons:

  1. understanding the customer's needs;
  2. improving customer service and/or experience;
  3. analyzing the suitability of our products or services for the customer;
  4. determining the customer's eligibility for our products and services;
  5. administering customer accounts;
  6. providing ongoing service;
  7. meeting legal and regulatory requirements;
  8. improving our website and marketing efforts;
  9. recruitment purposes;
  10. management, training, support and development of our employees and representatives;
  11. management of complaints and disputes; and
  12. processing and administration of the above.


We obtain the individual’s consent, except where inappropriate, before or at the time of collection of the personal information, as well as when a new use of this personal information is identified. Consent incorporates what personal information we are collecting, and the purposes for the collection, use or disclosure of personal data. We do not sell, trade, or rent Users’ personal information to others. Consent may be inappropriate as per PIPEDA, Schedule 1, 4.3 Principle 3 – Consent.

An individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. The Company shall inform the individual of the implications of such withdrawal.

Individuals can give consent in many ways. For example:

  1. an application form may be used to seek consent, collect information, and inform the individual of the use that will be made of the information. By completing and signing the form, the individual is giving consent to the collection and the specified uses;
  2. a checkoff box may be used to allow individuals to request that their names and addresses not be given to other organizations. Individuals who do not check the box are assumed to consent to the transfer of this information to third parties;
  3. consent may be given orally when information is collected over the telephone; or
  4. consent may be given at the time that individuals use a product or service.

Types of Information we Collect

We may collect the following types of information:

  • non-personal information (not covered by PIPEDA) such as:
    • Business contact information (employee name, title, business address, telephone number, fax number, email address);
    • publicly available information that is not covered under PIPEDA legislation; and
    • browser name, type of computer, and technical information about the users’ means of connection to our Site, such as the operating system and the Internet service providers utilized and other similar information.
  • personal information under PIPEDA (any factual or subjective information about an identifiable individual) with regards to:
    • employment context: applicants for employment with the Company; and
    • business/professional context: employees of the Company, personal information about an individual in a company

How We Collect Information

We may collect personal identification information from Users in a variety of ways including our website (, telephone conversations, email, regular mail, fax and recruitment procedures.

Our Site may use "cookies" to collect non-personal information to enhance User experience. User's web browser places cookies on their hard drive for record-keeping purposes and sometimes to track information about them. User may choose to set their web browser to refuse cookies, or to alert you when cookies are being sent. If they do so, note that some parts of the Site may not function properly.

We will collect personal identification information from Users only if they voluntarily submit such information to us. Users can always refuse to supply personal information, except that it may prevent the Company from supplying requested services.

Limited Collection

We do not collect personal information indiscriminately as we limit the amount and type of the information gathered to what is necessary for identified purposes. Personal information that we collect is by fair and lawful means.

Limited Use, Disclosure and Retention

We limit the use, disclosure and retention of personal information as follows:

  1. We use or disclose personal information only for the purpose for which it was collected, unless the individual consents otherwise, or the use or disclosure is authorized by the Act.
  2. We keep personal information for only as long as necessary to satisfy the purposes.
  3. We destroy or erase personal information that is no longer required for an identified purpose or a legal requirement.


Accurate information is vital to S.G. Smallwood Inc.’s ability to provide high quality services. To this end, S.G. Smallwood Inc. strives to keep personal information as accurate, complete and up-to-date as necessary taking into account its use and the interests of the individual to whom the information relates.

In certain cases, S.G. Smallwood Inc. may contact individuals who have provided their personal information to verify the accuracy of the information. Otherwise, individuals should be encouraged to inform S.G. Smallwood Inc. promptly if there are any changes to their personal information.


S.G. Smallwood Inc. recognizes that appropriate safeguards are fundamental to maintaining the privacy and confidentiality of personal information.

S.G. Smallwood Inc. takes reasonable steps to protect personal information it receives or creates against theft, loss, misuse, unauthorized access, disclosure, modification or destruction by employing the following safeguards as appropriate to the situation:

  1. Physical safeguards: locked filing cabinets, restricting access, alarm systems;
  2. Technological safeguards: passwords, access privileges, encryption, firewalls; and
  3. Organizational safeguards: security clearances, limiting access on a “need-to-know” basis, staff training, agreements


S. G. Smallwood Inc. has procedures in place to inform customers, clients and employees that we have policies and practices for the management of personal information.

Accessing Personal Information

An individual may request to be informed of the existence, use, and disclosure of their personal information and shall be given access to that information subject to exceptions set out in Section 9 of the Act.

An individual may request access to their personal information that is under the custody or control of S.G. Smallwood Inc. with regards to the following:

  • confirmation of existence of personal information about them
  • how it is or has been used
  • what, if any, organizations to which it has been disclosed
  • receive a copy of the information
  • correct or amend any personal information if its accuracy and completeness is found to be deficient
  • access to the information, or reasons for not providing access, subject to exceptions set out in Section 9 of the Act

Examples of Section 9 (of the Act) exceptions to access of personal information include, but are not limited to:

  1. a legal privilege restricting disclosure applies;
  2. another law prohibits the disclosure;
  3. it may harm or interfere with law enforcement activities and other investigative regulatory functions of any regulator;
  4. it does not exist, is not held, or cannot be found by S.G. Smallwood Inc.;
  5. it would disclose trade secrets or other confidential information of S.G. Smallwood Inc.;
  6. it would interfere with contractual or other negotiations of S.G. Smallwood Inc. or a third party; and
  7. it is not readily retrievable and the burden or cost of providing the information would be disproportionate to the nature or value of the information.

Any disagreement may be noted on the file and third parties advised where appropriate.

We will endeavour to provide the requested personal information within a reasonable time, generally no later than 30 days following its receipt of the request.



Personal Information

PIPEDA Interpretations

Changes to this privacy policy

S. G. Smallwood Inc. has the discretion to update this privacy policy at any time. When we do so, we will revise the last updated date at the bottom of this page. We encourage Users to frequently check this page for any changes to stay informed about how we are helping to protect the personal information we collect. You acknowledge and agree by continued use of this website that it is your responsibility to review this privacy policy periodically and become aware of modifications.

Your acceptance of these terms

By using this Site, you signify your acceptance of this policy. If you do not agree to this policy, please do not use our Site. Your continued use of the Site following the posting of changes to this policy will be deemed your acceptance of those changes.

Contacting us

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

S. G. Smallwood Inc.
Attn: Privacy Officer
699 Wabanaki Dr, Kitchener, ON N2C 2G4
Tel: (519) 894-2280
Fax: (519) 894-0007

This document was last updated on June 25, 2018.