Privacy Policy

Introduction

MacKay & Associates Advisors Inc. (“MacKay”) offers a range of executive coaching and consulting services to our clients.  This privacy policy addresses our compliance with the Personal Information Protection Act (British Columbia) (the “Act”).  “Personal Information” means all information about an identifiable individual.  MacKay recognizes the importance of privacy and recognizes the sensitivity of information received by us in the course of our services.

Coaching Sessions

In order to be able to provide services to our members, information of both a confidential commercial nature, and of a personal nature about our members or other individuals can be disclosed in our coaching sessions or in our CEO, Executive or Human Resource peer-to-peer groups.  When this information is voluntarily provided in session by a client it is understood, unless specifically indicated to the contrary, that we have consent to collect, use and disclose this commercial information and personal information provided to us for the purposes of the providing coaching services to that member, but for no other purpose.

Other participants in MacKay forums such as our CEO, Executive or Human Resource peer-to-peer groups, as a condition of participating in that group, are required to sign a membership agreement with MacKay.  That membership agreement specifies that the member must keep confidential any confidential commercial information, or personal information, disclosed and received in such peer-to-peer forums, and may not use or disclose it in any manner outside that forum.

Other Information Collection

MacKay may also collect, use and disclose personal information about members, including credit card information,  as reasonably appropriate to establish or collect fees and otherwise manage the business relationship between MacKay and its members.  All such additional information will only be used to manage the member relationship with MacKay.

The Act provides that an individual is considered to have consented to our collection, use or disclosure of personal information about that individual if, at the time the consent is deemed to be given, the purpose would be considered obvious to a reasonable person.  In such circumstances, we will collect, use or disclose personal information without obtaining a written or verbal consent to do so.  The Act also permits us to collect, use or disclose personal information about an individual in some circumstances without the individual’s consent. Those include (but are not limited to) circumstances in which:

• the collection, use or disclosure is clearly in the interests of the individual and consent cannot be obtained in a timely way;
• the personal information is available to the public from a prescribed source;
• the collection, use or disclosure of personal information is required or authorized by law.

Membership Directory

We consider part of the value that we add to the member relationship to be the provision of commentary, newsletters and other items of interest on executive training, including upcoming MacKay events.  Member contact information will be added to our distribution and marketing lists as appropriate.  If a member does not wish to receive this material, they can contact us to remove their name from our distribution lists at any time, by contacting robert@mackayandassociates.ca.

Member contact information is also maintained in a membership directory database, which is available to all members of MacKay.  All members of MacKay have signed a membership agreement which restrict their use and disclosure of membership database information to analysis, discussion, problem solving during MacKay group meetings and not to use such information for solicitation of business or to compile marketing and contact lists of any kind, other than for member-to-member communication.

If a client does not wish to be listed in our membership database, they can contact us to remove their listing, by contacting robert@mackayandassociates.ca.

Security of Personal Information

Personal Information in the custody of MacKay is secured and maintained at our premises, using physical and electronic system safeguards appropriate to the nature and sensitivity of the information.  Certain closed filed may be stored off-site in secure arrangements with contract service providers.  Our computer systems and the information stored in them are protected by appropriate electronic security systems.

Accuracy of Personal Information

MacKay is committed to the accuracy of any personal information in its custody and control, but relies on its members who are the source of such information to affirm accuracy.

Retention/Destruction of Personal Information

Personal information in closed files is retained for a number of years as required by law and standard business practices.  After such periods have expired, secure destruction of closed files occurs on a regular basis. 

Access to Personal Information

The Act permits individuals to submit written requests to us to provide them with:

• their personal information under our custody or control;
• information about how their personal information under our control has been and is being used by us;
• the names of the individuals and organizations to whom their personal information under our control may have been disclosed by us.

We will respond to requests in the time allowed by the Act and will make a reasonable effort to assist applicants and to respond as accurately and completely as reasonably possible. All requests may be subject to any fees and disbursements the law permits us to charge.
An individual’s ability to access his or her personal information under our control is not absolute. The Act provides that we must not disclose personal information in certain circumstances, including when:

• the disclosure would reveal personal information about another individual; or
• the disclosure would reveal the identity of an individual who has provided personal information about another individual and the individual providing the personal information does not consent to disclosure of his or her identity.

The Act further provides that in some circumstances we are not required to disclose personal information, for example when the personal information is protected by solicitor-client privilege, or the disclosure of the personal information would reveal confidential commercial information that if disclosed could, in the opinion of a reasonable person, harm the competitive position of an organization.

Chief Privacy Officer

Our Chief Privacy Officer is Robert MacKay who can be reached at robert@mackayandassociates.ca.

Inquiries and Complaints

If an individual has an inquiry or complaint about our privacy practices, they should contact the Chief Privacy Officer in writing.  As appropriate, the Chief Privacy Officer will consult with others in the organization.  A written response will be provided normally within 45 days.

Our Website

Like many other web sites, our websites automatically collect certain non-personal information regarding web site users that does not identify you.  Examples include the Internet Protocol (IP) address of your computer, the IP address of your Internet Service Provider, the date and time you access the web site, the internet address of the website from which you linked directly to the web site, the operating system you are using, the sections of the web site you visit, the web site pages read and images viewed, and the content you download from the web site.  This non-personal information is used for web site and system administration purposes and to improve the web site.

Our web site may contain links to other web sites or internet resources.  When you click on one of those links you are contacting another web site or internet resource.  We have no responsibility or liability for or control over those other web sites or internet resources or their collection, use and disclosure of your personal information.  We encourage you to read the privacy policies of those other sites to learn how they collect and use information about you.

Updates

This privacy policy may be updated periodically.  The most current version can always be found on our website at www.mackayandassociates.ca.

Last Updated:  April, 2011