Privacy Policy
RW Consulting (“we,” “us,” or “our”) is committed to protecting the privacy of our clients, employees, and other stakeholders. This Privacy Policy outlines how we collect, use, disclose, and protect personal information in compliance with applicable privacy laws, including the Personal Information Protection and Electronic Documents Act (PIPEDA) and Newfoundland and Labrador’s Access to Information and Protection of Privacy Act (ATIPPA).
1. SCOPE OF THE POLICY
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This policy applies to personal information collected, used, or disclosed by RW Consulting in the course of providing municipal management consulting services. It also applies to personal information we handle in other capacities, such as employment or partnerships.
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2. WHAT IS PERSONAL INFORMATION?
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Personal information refers to information about an identifiable individual. Examples include:
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Names, addresses, phone numbers, and email addresses
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Employee records
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Financial and billing information
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Opinions and evaluations related to municipal projects​
This does not include business contact information such as a person’s business title, business telephone number, or business address when used for the purpose of communicating with that person in relation to their business duties.
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3. COLLECTION OF PERSONAL INFORMATION
We collect personal information to provide consulting services and to manage our operations. Information may be collected in the following ways:
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Directly from individuals (e.g., during meetings, via email, or through forms)
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Through municipal records, where authorized
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From public sources, where permitted
Examples of purposes for collecting information include:
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Conducting municipal project assessments
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Engaging with stakeholders
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Developing municipal policies, strategies, or reports
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4. USE OF PERSONAL INFORMATION
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We use personal information solely for purposes consistent with our business, including:
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Delivering municipal consulting services
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Communicating with clients and stakeholders
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Meeting legal and regulatory requirements
We do not use personal information for purposes beyond those identified without obtaining further consent.
5. DISCLOSURE OF PERSONAL INFORMATION
We may disclose personal information only as required or permitted by law, or with consent. Examples include:
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To municipal stakeholders as part of consulting deliverables
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To service providers (e.g., IT or administrative support), subject to confidentiality agreements
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Where disclosure is required by law or legal processes. We will not sell, lease, trade, or otherwise disclose personal information for commercial purposes.
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6. SAFEGUARDS AND SECURITY
We take reasonable steps to protect personal information against unauthorized access, use, or disclosure. These include:
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Physical safeguards (e.g., locked filing cabinets)
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Technical measures (e.g., secure data storage and encrypted communications)
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Organizational policies (e.g., confidentiality agreements with employees and contractors)
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7. RETENTION OF PERSONAL INFORMATION
Personal information is retained only as long as necessary to fulfill the identified purposes or as required by law. Once no longer needed, personal information is securely destroyed or anonymized.
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8. ACCESS AND CORRECTION OF PERSONAL INFORMATION
Individuals have the right to:
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Access their personal information held by us, subject to applicable exemptions
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Request corrections to their personal information if it is inaccurate or incomplete.
We will respond to access and correction requests within 30 days. To make such a request, please contact us using the details provided below.
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9. CONSENT
We collect, use, and disclose personal information only with the individual’s knowledge and consent, except where otherwise permitted or required by law. Consent may be implied (e.g., when individuals provide information voluntarily) or explicit (e.g., via written agreements).
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10. THIRD-PARTY SERVICES
We may use third-party service providers to assist in delivering services. These providers are bound by confidentiality obligations and must comply with applicable privacy laws.
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11. PRIVACY CONCERNS AND COMPLAINTS
If you have questions or concerns about our handling of personal information, or if you wish to make a complaint, please contact:
RW Consulting
Roxane Wareham
PO Box 250
Arnold’s Cove, NL A0B 1A0
If you are not satisfied with our response, you have the right to file a complaint with the Office of the Privacy Commissioner of Canada or Newfoundland’s Office of the Information and Privacy Commissioner.
12. UPDATES TO THIS POLICY
This policy is reviewed at least annually to ensure compliance with privacy laws. Any updates will be posted on our website with a notice of the changes, and material changes will take effect 30 days after posting. Continued use of our services after such changes constitutes acceptance of the updated policy.
Effective Date: March 25, 2025
Last Updated: March 25, 2025
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