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MultiCast Networks Holdings Inc. 's companies provide a full range of communications services. We are among the world's leading communications organizations, with core investments in webcasting networks, Internet Protocol (IP)-based networks and solutions; electronic commerce; and systems integration. Our vision sees us as "people reaching out to provide the world entertainment and security through Internet based communications with leadership, innovation, teamwork and excellence".
MultiCast Networks Holdings Inc. has long been committed to maintaining the accuracy, confidentiality, security and privacy of customer and employee personal information. This is reflected in existing privacy and confidentiality provisions found in various MultiCast Networks Holdings Inc. policies. It is also reflected in the high regard and trust with which customers and employees view the management of personal information by MultiCast Networks Holdings Inc.
In March 1996, the new Canadian Standards Association Model Code for the Protection of Personal Information, CAN/CSA-Q830-96 (the "CSA Code"), was published as a National Standard of Canada.
MultiCast Networks Holdings Inc. has adopted MultiCast Networks Holdings Inc. 's Code of Fair Information Practices, to describe in detail how we subscribe to the principles of the CSA Code and the requirements of the Personal Information Protection and Electronic Documents Act.
MultiCast Networks Holdings Inc. - all companies providing services under MultiCast Networks Holdings Inc. brand, including:
Customer - an individual who:
Disclosure - making personal information available to a third party.
Employee - an employee or pensioner of a MultiCast Networks Holdings Inc. company.
Personal information - information about an identifiable individual but not aggregated information that cannot be associated with a specific individual.
For a customer, such information includes a customer's credit information, billing records, service and equipment, and any recorded complaints.
For an employee, such information includes information found in personal employment files, performance appraisals and medical and benefits information.
Third party - an individual other than the customer or his agent or an organization other than MultiCast Networks Holdings Inc.
Use - the treatment, handling, and management of personal information by MultiCast Networks Holdings Inc.
MultiCast Networks Holdings Inc. is responsible for personal information under their control and shall designate one or more persons who are accountable for the companies' compliance with the following principles.
1.1. Responsibility for ensuring compliance with the provisions of MMultiCast Networks Holdings Inc. Code rests with the senior management of MultiCast Networks Holdings Inc. , which shall designate one or more persons to be accountable for compliance with MultiCast Networks Holdings Inc. Code. Other individuals within MultiCast Networks Holdings Inc. may be delegated to act on behalf of the designated person(s) or to take responsibility for the day-to-day collection and processing of personal information.
1.2. MultiCast Networks Holdings Inc. shall make known, upon request, the title of the person or persons designated to oversee the companies’ compliance with MultiCast Networks Holdings Inc. Code.
1.3. MultiCast Networks Holdings Inc. are responsible for personal information in their possession or control, including information that has been transferred to a third party for processing. The Companies shall use appropriate means to provide a comparable level of protection while information is being processed by a third party (see Principle 7).
1.4 MultiCast Networks Holdings Inc. have implemented policies and procedures to give effect to MultiCast Networks Holdings Inc. Code, including:
Principle 2 - Identifying Purposes for Collection of Personal Information
MultiCast Networks Holdings Inc. shall identify the purposes for which personal information is collected at or before the time the information is collected.
2.1. MultiCast Networks Holdings Inc. collect personal information only for the following purposes:
2.2. MultiCast Networks Holdings Inc. shall specify orally, electronically or in writing the identified purposes to the customer or employee at or before the time personal information is collected. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within MultiCast Networks Holdings Inc. who shall explain the purposes.
2.3 Unless required by law, MultiCast Networks Holdings Inc. shall not use or disclose, for any new purpose, personal information that has been collected without first identifying and documenting the new purpose and obtaining the consent of the customer or employee.
Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of a customer or employee are required for the collection, use or disclosure of personal information, except where inappropriate.
3.1. In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual. For example, MultiCast Networks Holdings Inc. may collect or use personal information without knowledge or consent if it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is a minor, seriously ill or mentally incapacitated.
MultiCast Networks Holdings Inc. may also collect, use or disclose personal information without knowledge or consent if seeking the consent of the individual might defeat the purpose of collecting the information such as in the investigation of a breach of an agreement or a contravention of a federal or provincial law.
MultiCast Networks Holdings Inc. may also use or disclose personal information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened.
MultiCast Networks Holdings Inc. may disclose personal information without knowledge or consent to a lawyer representing the companies, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required by law.
3.2. In obtaining consent, MultiCast Networks Holdings Inc. shall use reasonable efforts to ensure that a customer or employee is advised of the identified purposes for which personal information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the customer or employee.
3.3. Generally, MultiCast Networks Holdings Inc. shall seek consent to use and disclose personal information at the same time it collects the information. However, MultiCast Networks Holdings Inc. may seek consent to use and disclose personal information after it has been collected but before it is used or disclosed for a new purpose.
3.4. MultiCast Networks Holdings Inc. will require customers to consent to the collection, use or disclosure of personal information as a condition of the supply of a product or service only if such collection, use or disclosure is required to fulfill the identified purposes.
3.5. In determining the appropriate form of consent, MultiCast Networks Holdings Inc. shall take into account the sensitivity of the personal information and the reasonable expectations of its customers and employees.
3.6. In general, the use of products and services by a customer, or the acceptance of employment or benefits by an employee, constitutes implied consent for MultiCast Networks Holdings Inc. to collect, use and disclose personal information for all identified purposes.
3.7. A customer or employee may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Customers and employees may contact MultiCast Networks Holdings Inc. for more information regarding the implications of withdrawing consent.
Principle 4 - Limiting Collection of Personal Information
MultiCast Networks Holdings Inc. shall limit the collection of personal information to that which is necessary for the purposes identified by the company. MultiCast Networks Holdings Inc. shall collect personal information by fair and lawful means.
4.1. MultiCast Networks Holdings Inc. collects personal information primarily from their customers or employees.
4.2. MultiCast Networks Holdings Inc. may also collect personal information from other sources including credit bureaus, employers or personal references, or other third parties that represent that they have the right to disclose the information.
Principle 5 - Limiting Use, Disclosure and Retention of Personal Information
MultiCast Networks Holdings Inc. shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. MultiCast Networks Holdings Inc. shall retain personal information only as long as necessary for the fulfillment of the purposes for which it was collected.
5.1. In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual. (See Principle 3.1)
5.2. In addition, MultiCast Networks Holdings Inc. may disclose a customer's personal information to:
5.3. MultiCast Networks Holdings Inc. may disclose personal information about its employees:
5.4. Only those employees of MultiCast Networks Holdings Inc. who require access for business reasons, or whose duties reasonably so require, are granted access to personal information about customers and employees.
5.5. MultiCast Networks Holdings Inc. shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about a customer or employee, MultiCast Networks Holdings Inc. shall retain, for a period of time that is reasonably sufficient to allow for access by the customer or employee, either the actual information or the rationale for making the decision.
5.6. MultiCast Networks Holdings Inc. shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.
Principle 6 - Accuracy of Personal Information
Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
6.1. Personal information used by MultiCast Networks Holdings Inc. shall be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a customer or employee.
6.2. MultiCast Networks Holdings Inc. shall update personal information about customers and employees as and when necessary to fulfill the identified purposes or upon notification by the individual.
Principle 7 - Security Safeguards
MultiCast Networks Holdings Inc. shall protect personal information by security safeguards appropriate to the sensitivity of the information.
7.1. MultiCast Networks Holdings Inc. shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. MultiCast Networks Holdings Inc. shall protect the information regardless of the format in which it is held.
7.2. MultiCast Networks Holdings Inc. shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.
7.3. All employees of MultiCast Networks Holdings Inc. with access to personal information shall be required as a condition of employment to respect the confidentiality of personal information.
Principle 8 - Openness Concerning Policies and Practices
MultiCast Networks Holdings Inc. shall make readily available to customers and employees specific information about its policies and practices relating to the management of personal information.
Principle 1 - Accountability
8.1. MultiCast Networks Holdings Inc. shall make information about its policies and practices easy to understand, including:
8.2. MultiCast Networks Holdings Inc. shall make available information to help customers and employees exercise choices regarding the use of their personal information and the privacy-enhancing services available from the company.
Principle 9 - Customer and Employee Access to Personal Information
MultiCast Networks Holdings Inc. shall inform a customer or employee of the existence, use and disclosure of his or her personal information upon request and shall give the individual access to that information. A customer or employee shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
9.1. Upon request, MultiCast Networks Holdings Inc. shall afford to a customer or an employee a reasonable opportunity to review the personal information in the individual's file. Personal information shall be provided in understandable form within a reasonable time and at minimal or no cost to the individual.
9.2. In certain situations, MultiCast Networks Holdings Inc. may not be able to provide access to all of the personal information that they hold about a customer or employee. For example, MultiCast Networks Holdings Inc. may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, MultiCast Networks Holdings Inc. may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law. If access to personal information cannot be provided, MultiCast Networks Holdings Inc. shall provide the reasons for denying access upon request.
9.3. Upon request, MultiCast Networks Holdings Inc. shall provide an account of the use and disclosure of personal information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, MultiCast Networks Holdings Inc. shall provide a list of organizations to which it may have disclosed personal information about the individual when it is not possible to provide an actual list.
9.4. In order to safeguard personal information, a customer or employee may be required to provide sufficient identification information to permit MultiCast Networks Holdings Inc. to account for the existence, use and disclosure of personal information and to authorize access to the individual's file. Any such information shall be used only for this purpose.
9.5. MultiCast Networks Holdings Inc. shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual's file. Where appropriate, MultiCast Networks Holdings Inc. shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.
9.6. A customer can obtain information or seek access to his or her individual file by contacting a designated representative at one of MultiCast Networks Holdings Inc. 's business offices.
9.7. An employee can obtain information or seek access to his or her individual file by contacting his or her immediate supervisor within the applicable MultiCast Networks Holdings Inc. . Company.
Principle 10 - Challenging Compliance
A customer or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for the compliance of MultiCast Networks Holdings Inc. with MultiCast Networks Holdings Inc. Code.
10.1. MultiCast Networks Holdings Inc. shall maintain procedures for addressing and responding to all inquiries or complaints from its customers and employees about the companies' handling of personal information.
10.2. MultiCast Networks Holdings Inc. shall inform their customers and employees about the existence of these procedures as well as the availability of complaint procedures.
10.3. The person or persons accountable for compliance with MultiCast Networks Holdings Inc. Code may seek external advice where appropriate before providing a final response to individual complaints.
10.4. MultiCast Networks
Holdings Inc. shall investigate all complaints concerning compliance with the Bell Code. If a complaint is found to be justified, the company shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A customer or employee shall be informed of the outcome of the investigation regarding his or her complaint.
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