What is personal information?
We consider “personal information” to mean any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information. This policy does not cover “business contact information” (e.g. name, title, business address) or aggregated data from which the identity of the individual cannot be determined. Altus retains the right to use business contact information or aggregated data in any ethical way that it determines appropriate.
Why Altus may collect personal information
Altus may collect and use the personal information provided orally or in writing (including via electronic media) by applicants, educational institutions or other third parties in order to do the following:
- Determine an applicant’s eligibility for Altus’ online services
- Validate the identities of users of Altus’ online services
- Provide and communicate information about Altus services and timetables to applicants, educational institutions or other third parties;
- Provide applicants’ examination results and related data/documentation to participating educational institutions;
- Provide applicants’ required personal information to educational institutions (or their designates) where the applicant has applied for admission;
- Conduct surveys of applicants in order to analyze, for statistical and research purposes, such issues as demographics of applicants, influences on career choices etc.;
- Provide examination and training statistics to participating educational institutions;
- Manage our relationship with applicants and educational institutions;
- Meet legal and regulatory requirements; and
- Such other purposes consistent with these purposes.
How Altus collects and uses personal information
Altus only collects, uses and discloses personal information for purposes that would be considered reasonable in the circumstances and only such information as is required for the purposes listed above. We use only fair and lawful methods to collect personal information. Personal information is routinely collected from all applicants through Altus’ online services, documents submitted via regular mail, electronic mail and fax to be added to the applicant’s file, and telephone calls to Altus for verification purposes. Our use and disclosure of personal information is limited to the purposes described in this policy and Altus does not otherwise sell, trade, barter, exchange or disclose for consideration any personal information it has obtained.
When Altus may disclose your personal information
Altus may disclose your personal information to:
- Individuals or organizations who use our examination services;
- Academic programs that an applicant has indicated they would like results sent to;
- Individuals or organizations that perform services on behalf of Altus, including those involved in verifying the identity of users and maintaining, reviewing and developing our systems, procedures and infrastructure, including testing or upgrading our computer systems.
Where Altus discloses personal information to third party organizations, Altus will enter into a written agreement to require that the organization use and disclose such information solely for specified permitted purposes and have appropriate safeguards for the protection of that personal information. However, Altus is not responsible for how such third party organizations use the personal information. In some cases, the individuals or organizations that perform services on behalf of Altus may use or store personal information outside of Canada. Personal information stored outside Canada may be subject to different laws than those in Canada and may be accessible to law enforcement agencies outside of Canada where permitted by law. Altus is committed to the protection of privacy and will evaluate the privacy implications associated with disclosing personal information to a third party service provider in a given jurisdiction before establishing a relationship in which personal information will be disclosed. Please note that there are circumstances where the use and/or disclosure of personal information may be justified or permitted or where Altus is obliged to disclose information without consent. Such circumstances may include:
- Where required by law or by order or requirement of a court, administrative agency or governmental tribunal;
- Where Altus believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
- Where it is necessary to establish or collect monies owing to Altus;
- Where it is necessary to permit Altus to pursue available remedies or limit any damages that we may sustain; or
- Where the information is public.
- Where obliged or permitted to disclose information without consent, Altus will not disclose more information than is required.
Unless permitted by law, no personal information is collected without first obtaining the consent of the individual concerned to the collection, use and dissemination of that information. However, we may seek consent to use and disclose personal information after it has been collected in those cases where Altus wishes to use the information for a purpose not identified in this policy or for which the individual concerned has not previously consented. The provision of personal information to Altus means that the person concerned agrees and consents that we may collect, use and disclose their personal information in accordance with this policy. In addition, where appropriate, specific authorizations or consents may be obtained from time to time. In most cases and subject to legal and contractual restrictions, an individual is free to refuse or withdraw his or her consent at any time upon reasonable, advance notice. It should be noted that in certain circumstances, services can only be offered if a person provides personal information to Altus. Consequently, if an individual chooses not provide us with any required personal information, we may not be able to offer the services requested.
The accuracy and retention of personal information
Altus endeavors to ensure that any personal information provided and in its possession is as accurate, current and complete as necessary for the purposes for which we use that information. Altus provides the opportunity for individuals to update their personal information to ensure accuracy and currency. Individuals are responsible for ensuring that their personal information is accurate and have access to change it at any time. Altus will use its best efforts to inform third parties which were provided with inaccurate information so that those third parties may also correct their records. We keep your personal information only as long as it is required for the reasons it was collected. This period may extend beyond the end of an individual’s relationship with us but it will be only for so long as it is necessary for us to have sufficient information to conduct research, respond to issues that may arise at a later date, and for any other reason consistent with the purposes for which the information was collected.
Protection of personal information
Altus endeavors to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of personal information. This also applies to our disposal or destruction of personal information. Altus further protects personal information by restricting access to it to those employees with a need to know that information in order for us to provide our services or information. If any employee of Altus misuses personal information, this will be considered a serious offence for which disciplinary action may be taken, up to and including termination of employment. If any individual or organization misuses personal information that was provided for the purpose of providing services to or for Altus, this will be considered a serious issue for which action may be taken, up to and including termination of any agreement between Altus and that individual or organization.
Access to your personal information
Altus permits the reasonable right of access and review of personal information held by us about an individual and will endeavor to provide the information in question within a reasonable time, usually within 30 days following the request. To guard against fraudulent requests for access, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or making corrections. Altus reserves the right not to change any personal information but will append any alternative text the individual concerned believes to be appropriate. Altus reserves the right to decline to provide access to personal information where the information requested:
- Would disclose (i) personal information, including opinions, about another individual or about a deceased individual; or (ii) trade secrets or other confidential business information that may harm Altus or the competitive position of a third party or interfere with contractual or other negotiations of Altus or a third party;
- Is subject to solicitor-client or litigation privilege;
- Is not readily retrievable and the burden or cost of providing it would be disproportionate to the nature or value of the information;
- Does not exist, is not held, or cannot be found by Altus;
- Could reasonably result in (i) serious harm to the treatment or recovery of the individual concerned, (ii) serious emotional harm to the individual concerned or another individual, or (iii) serious bodily harm to another individual;
May harm or interfere with law enforcement activities and other investigative
- or regulatory functions of a body authorized by law to perform such functions; or
- Any other grounds under applicable legislation.
Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure. Altus will not respond to repetitious or vexatious requests for access and in making such a determination, we will consider such factors as the frequency with which information is updated, the purpose for which the information is used and the nature of the information. Altus will not charge you for verifying or correcting your information; however, to the extent permitted by applicable law, there may be a minimal charge imposed if you need a copy of records.
Resolving your privacy concerns
In the event of questions about: (i) access to your personal information; (ii) our collection, use, management or disclosure of personal information; or (iii) this policy, please contact firstname.lastname@example.org. Altus will investigate all complaints and if a complaint is justified, we will take all reasonable steps to resolve the issue.