Business Travel Network Privacy Policy
The following policy statement (hereby referred to as the policy), outlines the privacy policies and practices for Business Travel Network, its subsidiaries and affiliates (collectively referred to as, BTN) with respect to the collection, use and disclosure of personal information. This policy may be amended by BTN giving reasonable notice of the revised policy (including by email or by positing on BTN websites) and this policy may be supplemented or modified by agreements entered into between BTN and an individual from time to time.
Personal information is any information about an identifiable individual, as defined under the Canadian Privacy Act and the Personal Information Protection & Electronic Documents Act (PIPEDA) or other applicable laws.
Collection, Use and Disclosure
Except where otherwise required or permitted by law, BTN will inform individuals of the purpose for the collection, use or disclosure of the individual’s personal information, prior to the collecting, using or disclosing that personal information.
BTN collects information from clients and potential clients through various means including application forms, web-form registrations, marketing campaign, purchase/sale agreements and survey responses. The type of information collected will vary depending on the means through which an individual submits his/her personal information. The type of information collected may include an individual’s name, residential address, email address, home phone number, age group, preferences, credit information and specific comments.
BTN uses information collected from clients and potential clients to provide services or products, in respond to the requests for information or the purchase of BTN’s products & services; for mailing contacts for BTN publications, marketing materials, special events or other marketing activity and for additional purposes that may be identified at or before the time that the information is collected. BTN also uses personal information from purchasers for accounting and transactional completion purposes.
BTN may disclose personal information to legal, financial and other professional advisors or in connection with the sale or reorganization of all or part of or its business or operations.
Requirement for consent to the collection, use or disclosure of personal information vary depending on circumstances and on the type of personal information that is intended to be collected, used or disclosed. In determining whether consent is required and, if so, which form of consent is appropriate, BTN will take into account both the sensitivity of the personal information at issue and the purposes for which BTN will use the information.
Consent may be express, implied through the use of opt-out consent where applicable or deemed. On giving reasonable written notice to BTN, an individual may withdraw consent to the collections, use or disclosure of his or her personal information. Upon receipt of this withdrawal, BTN will notify the individual of the likely consequences of withdrawing their consent. Except where otherwise required or permitted by law, BTN will then cease collecting, using or disclosing the individual’s personal information.
Limits to the Collection of Personal Information
Except where required or permitted by law, BTN will limit the collection of personal information to that which is necessary to fulfill the purpose for which it is collected. Personal information will be collected by fair and lawful means.
Usage, Disclosure and Retention
BTN will not use or disclose personal information for purposes other than those for which it was collected, except with consent of the individual or as required or permitted by law.
Once the information is no longer required to fulfill its intended purpose, and is no longer required or permitted to be retained for legal or business purpose, it will be destroyed, erased or made anonymous.
BTN may disclose certain information to third party service providers and to affiliated entities in order to carry out work on behalf of BTN. Prior to making this disclosure, BTN will take appropriate steps to ensure that such recipients safeguard the personal information and use the information only for authorized purposes.
Accuracy
BTN will make reasonable efforts to ensure that any personal information collected by it, or on its behalf, is accurate and complete if the personal information is likely to be used by BTN to make a decision that affects the individual to whom the personal information relates or if the information is likely to be disclosed to a third party.
Security
BTN will protect personal information with security safeguards appropriate to the sensitivity of the information. Security safeguards are employed to protect personal information against loss, theft and unauthorized access, collections, use, disclosure, copying, modifications or disposal or similar risks. The nature of these safeguards will vary depending on the sensitivity of the personal information that has been collected. The methods of safeguards include:
Physical security measures
Security clearance and limiting access
Technological measures such as user ID and passwords
BTN will inform employees about BTN’s policies and practices for protecting personal information and employees are required to comply with BTN’s Privacy Policy.
Individual Access
Upon written request, with sufficient detail to enable BTN to identify the individual and the personal information being sought, BTN will inform an individual of the existence, use and the disclosure of his or her personal information under BTN’s control and will provide access to such information, unless otherwise prohibited or permitted by law. BTN will respond to all requests within 30 days. BTN may extend the time limit for a further 30 days, or for a longer period with the Privacy Commissioner’s consent or as otherwise permitted by law.
Challenging Compliance
An individual may direct a complaint concerning compliance with the policy to BTN’s Privacy Officer.
The complaint must be in writing. Within a reasonable time of receipt of the complaint, the Privacy Officer will conduct an investigation into the complaint.
Within a reasonable time of conclusion of the investigation, the Privacy Officer will inform the complainant, either verbally or in writing, of their findings. If the Privacy Officer finds merit in the complaint, BTN will take appropriate measures necessary to rectify the source of the complaint.