- Personal Information Protection and Electronic Documents Act (‘PIPEDA’)
- Personal Information Protection Act (‘PIPA Alberta’)
- Personal Information Protection Act (‘PIPA BC’)
- Personal Information Protection and Identity Theft Prevention Act (‘PIPITPA’)
- An Act Respecting the Protection of Personal Information in the Private Sector (‘Quebec Privacy Act’), (collectively, ‘Canadian Privacy Statutes’)
Table of Contents
- Definitions used in this Policy
- Data protection principles we follow
- What rights do you have regarding your Personal Data
- What Personal Data we gather about you
- How we use your Personal Data
- Who else has access to your Personal Data
- How we secure your data
- Information about cookies
- Contact information
Personal Data – any information relating to an identified or identifiable natural person.
Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
Data subject – a natural person whose Personal Data is being Processed.
Child – a natural person under 16 years of age.
We/us (either capitalized or not) – means the Affiliates, officers, directors, employees, agents, contractors, consultants, vendors, invitees and representatives of Transcript Heroes Transcription Services Inc.
Data Protection Principles
We promise to follow the following data protection principles:
- Processing is lawful, fair, and transparent. Our Processing activities have lawful grounds. We will always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
- Processing is limited to a purpose. Our Processing activities fit the purpose for which Personal Data was gathered, that is, providing transcription and typing related services to you.
- Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for the purpose of providing transcription and typing related services.
- Processing is limited to a time period. We will not store your personal data for longer than needed.
- We will do our best to ensure the accuracy of the data.
- We will do our best to ensure the integrity and confidentiality of data.
Data Subject’s rights
The Data Subject has the following rights:
- Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
- Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
- Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
- Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
- Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
- Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
- Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
- Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
- Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
- Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
- Right to withdraw consent – you have the right to withdraw any given consent for Processing your Personal Data.
Data we gather
Information you have provided us with.
This might be audio or video recordings, or copies of documents or notes, your e-mail address, name, billing address, address etc – that is, information that is necessary for delivering you a product/service or to enhance your customer experience with us. We may save the information you provide us with in order for you to perform activities on the website for example, your name and e-mail address, or order details.
Information automatically collected about you
This includes information that is automatically stored by cookies and other session tools. For example, your order information, your IP address, your order history (if there is any) etc. This information is used to improve customer experience. When you use our services or look at the contents of our website, your activities may be logged.
Publicly available information
We might gather information about you that is publicly available, such as business information or information from your business website, or other public profiles e.g. LinkedIn account etc.
How we use your Personal Data
We use your Personal Data in order to:
- Provide our service to you. This includes, for example, creating transcripts from audio or video recordings or hardcopy; registering your account; invoicing and payment processing; providing you with other products and services that you have requested; providing you with promotional items at your request and communicating with you in relation to those products and services; communicating and interacting with you, and notifying you of changes to any services.
- Enhance your customer experience.
- Fulfill an obligation under law or contract.
We will use your Personal Data only on legitimate grounds and/or with your Consent.
On the grounds of entering into a contract or fulfilling contractual obligations, we Process your Personal Data for the following purposes:
- to identify you;
- to provide you with a service eg transcription or to send/offer you a product/service;
- to communicate either for sales or invoicing;
On the grounds of legitimate interest, we Process your Personal Data for the following purposes:
- to administer and analyse our client base (purchasing behaviour and history) in order to improve the quality, variety, and availability of products/ services offered/provided;
- to conduct questionnaires/interviews concerning client satisfaction and service development;
Under Canada’s Anti-Spam Legislation (CASL) we recognise it is prohibited to send, or cause or permit to be sent, a commercial electronic message (defined broadly to include text, sound, voice, or image messages aimed at encouraging participation in commercial activity) unless the recipient has provided express or implied consent and the message complies with the prescribed content and unsubscribe requirements (subject to limited exceptions).
As long as you have not informed us otherwise, we consider offering you products/services that are similar or the same to your purchasing history/browsing behaviour to be our legitimate interest and express or implied consent.
We Process your Personal Data in order to fulfill obligations rising from law and/or use your Personal Data for options provided by law.
We save your billing information and other information gathered about you for as long as needed for accounting purposes or other obligations deriving from law.
Who else can access your Personal Data
We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience. We share:
- Invoice & Order Information – Name, address, number of minutes, total charges etc. We create, send and store your invoices using the Xero accounting software. We share invoice and order info with our accountants.
- Project Management Information – Name, project number, due date, the team assigned to your project etc. We manage your project via the google apps platform (email, spreadsheets). Do note though, the actual project recordings and transcripts are not stored with google, they are encrypted and stored on our Amazon Canadian based website host.
- Website Visiting: We use Google Analytics to review visitor activity on our website.
We only work with Processing partners who are able to ensure an adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.
How we secure your data
- Encryption: We use secure protocols for communication and transferring data, such as encrypting data in transit e.g. HTTPS and encrypting data when it is at rest/stored e.g. AES256.
- Montreal Canada based server: Transcripts and transcript recordings (unless otherwise directed by you) will be encrypted and hosted on our Amazon Canadian based server.
- Deletion: Recordings and Transcripts of those recordings will be deleted from our servers within 60 days of completion.
- Firewalls: We use host-based firewalls on both computers and mobile phones, and where possible on our wifi routers.
- Password-based authentication: Our systems are password-protected, and when possible, we use 2-factor authentication (both a password and a code is needed for access).
- User Access Control: User access to data is limited and is granted on a “need-to-know” basis. Users can only see specific data that they have been granted access too in order to perform their specific role in providing our services (e.g. an accounts person can access client invoicing information but not client recordings. Typists can access specific client recordings they are working on, but not client invoicing information etc.)
- Malware Protection (viruses, worms & spyware): Anti-malware software is deployed on computers and mobile phones.
- Patch management: Software is licensed and supported. Software is removed from devices when no longer supported. Any security patches are applied within 14 days of an update being released.
- Business continuity management is conducted systematically and comprehensively to provide assurance that in the event of a disruption, we can maintain a level of delivery of critical services and activities, and can achieve the timely recovery of other services and activities. Our IT systems are on a rolling backup system enabling fast recovery in the event of failure.
- Security screening of our team is conducted in a way that is effective, rigorous, consistent and fair to provide assurance that individuals can be trusted to safeguard private information and assets and can reliably conduct their work duties
- Security awareness and training is conducted systematically and comprehensively to ensure that our team are informed of their security responsibilities and maintain the necessary knowledge and skills to effectively carry out their functions, and to provide assurance that individuals will not inadvertently compromise security and that they understand the potential consequences of not meeting their security responsibilities.
- Privacy and Security requirements are included in contracts with the team.
- Security event management practices are defined, documented, implemented and maintained to monitor, respond to and report on threats, vulnerabilities, security incidents and other security events, and ensure that such activities are effectively coordinated within the department, with partners and government-wide, to manage potential impacts, support decision-making and enable the application of corrective actions. Without unreasonable delay, we will provide notice to the Commissioner of any incident involving the loss of or unauthorized access to or disclosure of personal information where a reasonable person would consider that there exists a real risk of significant harm to an individual as a result.
Despite the use of best practice and a data breach does occur, we will notify the suitable authorities. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.
If you have an account with us, note that it is your responsibility to keep your username and password secure.
We do not intend to collect or knowingly collect information from children. We do not target children with our services.
Cookies and other technologies we use
A cookie is a tiny text file stored on your computer. Cookies store information that is used to help make sites work. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.
- Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
- Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. For example, these cookies might enable us to remember your name and e-mail on order forms so you don’t have to re-enter this information next time when ordering.
- Analytics cookies – these cookies are used to track the use and performance of our website and services. For example, what pages people are visiting the most, or how long visitors stay on our website.
You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.
Data Protection Officer
The last modification was made 12 July 2020.