Privacy

Navigator Ltd. is committed to keeping personal information confidential and secure. All of our research is conducted according to industry standards set out by the Marketing Research and Intelligence Association (MRIA). Our Privacy Policy is based on the Personal Information Protection and Electronic Documents Act. See Office of the Privacy Commissioner of Canada for more information. This policy describes how Navigator Ltd. adheres to the ten principles of privacy set out in this Act.

The Ten Principles of Privacy

1. Accountability

An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization’s compliance with the following principles. Navigator Ltd. has designated a Privacy Officer who is responsible for the oversight of personal information protection and Navigator’s compliance with the PIPEDA.

2. Identifying Purposes

The purposes for which personal information is collected shall be identified by the organization at or before the time the information is collected. When one of our research professionals contacts an individual by telephone, they will state the purpose of their contact. When Navigator Ltd. sends written correspondence to individuals, the correspondence will clearly identify us as Navigator Ltd. and will explain the purpose of our contact. Our research professionals will advise participants that their responses are used strictly for research purposes. Navigator Ltd. may provide the results of its research, in aggregate form, to clients who sponsor that research or to other third parties. Because this information is in aggregate form, Navigator’s clients or other third parties will be unable to identify an individual’s personal information.

3. Consent

The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate. Participation in our research is entirely voluntary. Consent is obtained from an individual when a participant agrees to participate in our research. An individual may refuse to answer certain questions, discontinue participation in a study, or withdraw consent at any time. Survey responses may be collected, stored or processed by Navigator Ltd. or a non-affiliated service provider, both within and outside Canada. Our service providers will keep all personal information they collect and disclose to us (or we collect and disclose to them) confidential and will protect it with the same security standards as our own. Generally, personal information we collect is not disclosed to other parties. Occasionally, however, a client may want to contact participants directly following or during our research study. In these cases, Navigator Ltd. will not disclose personal information to another party unless it has first clearly explained to the participant the purpose of such disclosure and has obtained the participant’s express or written consent.

4. Limiting Collection

The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means. Navigator Ltd. limits the amount and type of personal information it collects. We collect only the amount and type of information we need for the purposes of our research and as identified to the individual when it is collected.

5. Limiting Use, Disclosure, and Retention

Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfilment of those purposes. Navigator Ltd. uses or discloses personal information only for the reasons it was collected, unless an individual gives consent to use or disclose it for another reason. Navigator Ltd. keeps personal information only as long as necessary. Personal information that is no longer needed for its identified purposes when it was collected or for legal requirements is destroyed, erased or made anonymous.

6. Accuracy

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. Navigator Ltd. makes reasonable efforts to keep personal information it uses on an on-going basis accurate, complete, and current. Navigator Ltd. updates personal information only if it is necessary for the purposes for which it was collected.

7. Safeguards

Personal information shall be protected by security safeguards appropriate to the sensitivity of the information. Navigator Ltd. safeguards personal information in its possession or control from loss or theft and from unauthorized access, disclosure, duplication, use or modification. Personal information is stored in print and electronically onsite at our office. Navigator Ltd. safeguards personal information in its possession or control through security measures, such as:

Physical security – restricted access to offices and filing cabinets;
Organizational security – controlled entry in offices and limited access to relevant information; and
Electronic security – firewalls and passwords.

Navigator Ltd. uses care when disposing of or destroying personal information in order to prevent unauthorized access to the information. All print records are disposed of by shredding.

8. Openness

An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information. Individuals have access to information about these procedures through this Privacy Policy or by contacting the Privacy Officer.

9. Individual Access

Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate. When an individual makes a written request to the Privacy Officer, Navigator Ltd. will:

Inform the individual of the personal information it has in its possession about the individual, what it is being used for, and to whom it has been disclosed;
Provide the individual access to that information; and
Allow the individual to challenge the accuracy and completeness of the personal information, or have their personal information removed from our files.

In certain situations, however, Navigator Ltd. may not be able to give individuals access to all of their personal information. This may occur when:

Providing access to personal information would be likely to reveal personal information about a third party;
Disclosing the information would reveal confidential commercial information; or
The information has been collected for the purposes of a legal investigation.

If Navigator Ltd. denies the individual’s request for access to personal information, the Privacy Officer will advise the individual of the reason for the refusal.

10. Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization’s compliance. Individuals may challenge Navigator Ltd.’s compliance with this Privacy Policy. Individuals are advised to direct their complaints and questions, in writing, to the Privacy Officer.

Contacting Us

To contact our Privacy Officer, call (416) 644-7000 or send an e-mail to privacy @ navltd.com. Written correspondence should be mailed to:

Navigator Ltd.
c/o Privacy Officer
British Colonial Building, Third Floor
8 Wellington Street East
Toronto, ON M5E 1C5

Last revised: January 7, 2007