Privacy Policy
Introduction
The Toronto Lawyers' Association ("we", "us", "our", or "TLA") is a not for profit organization that represents the interests of lawyers resident or practicing in the City of Toronto. The TLA is committed to fulfilling its responsibilities under the Personal Information Protection and Electronic Documents Act ("PIPEDA") and protecting the personal information of its members and others. For the purposes of this privacy policy (the "Policy"), "you" and "your" refers to both members and non-members of the TLA.
This Policy applies to the TLA and describes how the TLA collects, uses, and discloses your personal information. This Policy describes the choices that you have with respect to how the TLA handles your personal information whether you are a member or non-member and tells you how the TLA is accountable for the personal information that it collects.
TLA may update this Policy from time to time. This Policy is current as of the approval date at the bottom of this Policy, and the TLA encourages you to review this Policy before you provide any personal information to the TLA.
Consent
By visiting the TLA website, by providing your personal information to the TLA, or by completing a transaction with the TLA, you are consenting to the collection and use of your personal information on the terms set out in this Policy. If you provide the TLA with personal information about other individuals, then by doing so you are representing and warranting to us that you have obtained their consent and are doing so in compliance with applicable law.
You can choose not to consent to the collection or use of your personal information. If you do not consent, then do not provide the TLA, or any of its third party service providers, with any of your personal information and do not use any parts or functions of the TLA website that require you to provide personal information.
You can also withdraw your consent at any time by providing the TLA with reasonable notice. However, if you withdraw your consent, the TLA may not be able to offer all or any of its services to you, including membership. If you decide to withdraw your consent, please contact the TLA's privacy officer using the contact information under "Who is Accountable for the TLA's Privacy Policy?".
You cannot withdraw your consent retroactively, and any personal information you previously provided may remain subject to certain contractual or legal obligations that the TLA agreed to before you withdrew your consent.
What is Personal Information?
Under PIPEDA, "personal information" means information about an identifiable individual. This includes any factual or subjective information about an identifiable individual such as, among other things, your name, residential address, email address, gender, phone number and date of birth, but does not include business contact information.
This policy does not apply to non-personal information, such as business contact information that the TLA collects, uses or discloses solely for the purpose of communicating or facilitating communication with you in relation to your business or profession.
What Personal Information Does the TLA Collect?
When you visit the TLA's website or use its services, the TLA may collect the following types of information from you:
- corporate identification information;
- personal identification information;
- financial information (e.g. credit card information, purchase order numbers or any other payment information for billing purposes);
- usage information, including information about your preferences; and
- additional information from or about you when you communicate with us, contact us or respond to a survey.
These types of information may include, among other things, your name, residential address, email address, gender, phone number, credit card and billing information, and information about your employment status.
Why Does the TLA Collect Personal Information?
The TLA may collect personal information from you for the following purposes:
- membership registration and administration;
- to provide you with services which include, among other things, library and research services, educational programming, TLA updates and newsletters, court locker rentals and social events;
- to perform analytics and customize your online experience;
- to advertise to you and perform marketing activities related to TLA events and services; and
- to enable our service providers and suppliers to provide our products, services and promotional information to you.
The TLA may also collect personal information where required to fulfill its legal and regulatory obligations.
How Does the TLA Collect Personal Information?
Personal Information That You Provide
The TLA collects personal information from members and non-members that is provided in writing, via electronic media, verbally over the telephone or in person. For example, the TLA may collect personal information from you when you sign-up to become a new member, when you renew your membership, when you complete a survey, when you sign-up for certain benefits and services, when you register for an event, make a purchase, rent a room or locker at one of the courthouses in Toronto, or use the TLA's copying and scanning services.
The TLA may collect personal information about you if you visit our physical premises to use our services or attend any of the TLA's events. The TLA may also record video or take photographs at the TLA's events, for the purposes of creating content for certain of the TLA's publications. If you have any concerns regarding the use of photographs or video content by TLA, please contact the TLA's privacy officer at the contact information below.
Collection by Third Party Service Providers
When you make a payment to the TLA, whether online or in person, the payment is processed through a third party payment processor on the TLA's behalf. In order to process a payment, the third party payment processor will collect your personal information from you or us (in cases where you have asked us to enter it for you), including your name, email address, credit card number, billing address and other billing and delivery information. In this case, this Policy will no longer apply to the information collected by the payment processor and the collection, use and storage of your personal information will be governed by the payment processor's terms, conditions and privacy policies.
The TLA's website may contain other links to external or third party websites. This Policy only applies to personal information that the TLA collects, uses and discloses, and does not apply to personal information that is collected by third party processors or any other third party suppliers or service providers. The TLA does not possess, have access to, or keep any of the personal information you provide through third party payment processors other than the fact that your purchase has been completed. In order to provide a particular service, third party service providers may transmit or store your personal information outside of Canada, and it may therefore be subject to the laws of that jurisdiction. The TLA is not responsible or liable for the privacy practices, content, or activities of any third party website, whether linked or otherwise. We strongly recommend that you review the privacy policies that are applicable to any external webpages before you disclose any personal information.
Collection of Personal Information Using Tracking Technologies
When you visit or interact with our website, services, tools or messaging, we or other authorized service providers may use cookies, web beacons and other similar technologies to collect information. The TLA may use cookies, web beacons and similar technologies for a variety of reasons, primarily to help us customize your online experience and to help us compile aggregate statistics about your usage of our website and our services. These are the types of cookies and tracking technologies that the TLA may use:
- Essential. These are necessary for the operation of the TLA's websites, services and tools.
- Performance Related. These allow the TLA to assess the performance of the TLA's website, services and tools. It may include analytics to help determine how visitors use the TLA website. These cookies don't collect information that identifies you. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.
- Enhanced Functionality. These identify users when they sign in, keep track of preferences, interests or past items viewed.
- Advertising or Targeting. These can be first or third party cookies and web beacons which can be used to deliver content, including advertisements relevant to member interests, on the TLA website or on third party sites. This includes monitoring whether you have clicked on an advertisement.
You can control and/or choose to delete cookies that are already on your computer and you can set most browsers to prevent them from being placed. If you do this, however, you may not be able to access some services and functionalities of the TLA's website.
What Does the TLA Use Personal Information For?
The TLA only uses personal information for the purposes described in this Policy, and only in accordance with the terms of this Policy and in accordance with all applicable laws. If the TLA intends to use personal information for any other purpose, then the TLA will ask you for your consent for that particular purpose.
Does the TLA Keep Personal Information?
The TLA uses or keeps your personal information for so long as you are a member and for as long as is necessary to fulfil the purposes for which it was collected and as permitted or required by law. If you are not a member, the TLA deletes or destroys your personal information within a reasonable time after you attend an event, or once a transaction that you have requested has been completed and your personal information is no longer reasonably required.
Any personal information that the TLA receives through electronic means is stored in the cloud through a third party service provider whose servers and back-up servers are located in Canada. Any personal information that the TLA collects in person, via mail or over the phone is kept securely, with appropriate safeguards, at the offices of the TLA.
How Does the TLA Keep Personal Information Secure?
TLA has appropriate physical, procedural and technical security safeguards at its premises and information storage facilities to prevent any unauthorized access to personal information. When the TLA shares or discloses your personal information with third party service providers, it requires that these parties agree under contract to (i) limit the use of your personal information to the purposes of performing their contractual obligations, and (ii) have appropriate physical, technical and organizational safeguards to protect your personal information, and to handle it in accordance with all applicable laws.
TLA also restricts access to personal information to those employees who need access to personal information in order to perform their roles and responsibilities. The TLA will take reasonable precautions to protect your personal information from access, loss, misuse or alteration. If there is unauthorized access to or unauthorized disclosure involving your personal information that is under the TLA's control, the TLA must comply with PIPEDA and will notify you and the Office of the Privacy Commissioner of Canada (the "OPC") if it is reasonable in the circumstances to believe that the unauthorized access or disclosure creates a real risk of significant harm to you, which includes physical, financial or reputational harm. In assessing whether there is a real risk of significant harm, the TLA will consider the sensitivity of the personal information, the potential harms that may result from the breach and the probability that the personal information will be misused.
Does the TLA Disclose Personal Information?
The TLA may disclose personal information with the following third party service providers to the extent required to fulfill the purposes described in this Policy:
- digital publishers;
- advertisers, and marketing and communications companies;
- providers of member satisfaction surveys;
- cloud storage providers in Canada; and
- website design and maintenance providers.
The TLA may also sell or lease the name, address, telephone number and e-mail address of its members to affiliated organizations, preferred suppliers and reputable social media organizations when the TLA believes that the service or information is pertinent to its members or the services that the TLA offers.
The TLA may also be justified or compelled to disclose your personal information without your consent or knowledge where required by law, or where necessary to collect fees or payment. If the TLA is required to disclose any of your personal information under the circumstances listed above, it will disclose your personal information only to the extent that it is required under the circumstances.
Access to Your Personal Information
The TLA will give you access to any of your personal information that we have collected, used or disclosed, upon your written request, to the extent permitted or required by law. You can at any time, challenge the accuracy or completeness of the personal information we have that is related to you. The TLA will endeavor to respond to requests that it receives within 30 days of receiving your request. If the TLA is not able to respond to your request within that timeframe, the TLA will notify you in writing. If you have any complaints or concerns about this timeline, please contact the TLA's privacy officer at the contact information below.
Who is Accountable for the TLA's Privacy Policy?
If you would like to withdraw your consent to the use or disclosure of your personal information described in this Policy, or if you have any questions, concerns or complaints about this Policy, please contact the TLA's Executive Director, who is also the TLA's privacy officer, at the contact information below:
Executive DirectorCourthouse Library
361 University Avenue, 3rd Floor
Toronto, ON M5G 1T3
jrataiclang@tlaonline.ca
(416) 327-6012
The TLA takes its obligations and responsibilities under PIPEDA seriously and will make every effort to resolve any concerns you may have about how your personal information is handled. However, if you are not satisfied with the TLA's efforts to resolve your concern, you may contact the OPC by visiting the OPC website at: https://www.priv.gc.ca/en/contact-the-opc/contact-theinformation-centre/, or writing to the OPC at the address below:
Office of the Privacy Commissioner of Canada30 Victoria Street
Gatineau, Québec K1A 1H3
Approved by the TLA Board of Directors on June 11, 2019