Privacy Statement
At the School Bus Association of Ontario (“SBO”, “we”, “us”, “our”), we are committed to protecting your privacy and safeguarding your Personal Information (defined below).
We are proud to demonstrate our commitment to your privacy. This Privacy Statement is designed to meet the standards prescribed by Canada’s Personal Information Protection and Electronic Documents Act and the regulations thereunder.
The purpose of this Privacy Statement is to inform you about the types of Personal Information we collect, use and disclose. It explains how we collect, use and disclose that information, the choices you have regarding such use and disclosure, and how you may access and correct that information.
From time to time, we may make changes to this Privacy Statement. The Privacy Statement is current as of the “last revised” date which appears at the top of this page. We will treat Personal Information (as defined below) in a manner consistent with the Privacy Statement under which it was collected, unless we have your consent to treat it differently. This Privacy Statement applies to any information we collect or receive about you, from any source.
The following topics will be covered in this Privacy Statement:
- What Personal Information do we collect?
- How do we collect your Personal Information?
- Why do we collect your Personal Information?
- To whom do we provide your Personal Information?
- When and how do we obtain your consent?
- Where do we store your Personal Information?
- How do we ensure the privacy of your Personal Information when dealing with third parties?
- How long will we utilize, disclose or retain your Personal Information?
- How can you review your Personal Information that we have collected, utilized or disclosed?
- How do you know that the Personal Information we have on you is accurate?
- What if the Personal Information we have on you is inaccurate?
- How fast will we respond to your written requests?
- Are there any costs to you for requesting information about your Personal Information or our privacy practices?
- How do we know that it is really you requesting your Personal Information?
- What safeguards have we implemented to protect your Personal Information?
- How do you contact us regarding access to your Personal Information or our privacy practices?
- What Personal Information do we collect?
“Personal Information” is any information that is identifiable with you, as an individual. We may collect, use, and disclose different kinds of Personal Information, depending on our relationship with you. Generally, the types of Personal Information we may collect can be grouped into the following categories – and not all of these categories apply to every individual:
- identity data, such as your first name, surname, username or similar identifier, title, date of birth;
- contact data, including your address, email address and telephone numbers;
- financial data, including your Social Insurance Number (only applicable to school bus drivers who participate in the School Bus Driver Retention Program (“DRP”);
- technical and usage data when you use our website, including internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our websites;
- health data, including information relating to your disability or other health related status reported in an Exception Application Form as part of the DRP; and
- marketing and communications preferences in receiving marketing from us and our third party providers.
We also collect, use and share aggregated and anonymized data, such as statistical or demographic data for any purpose. Aggregated and anonymized data is not considered Personal Information as it is not identifiable (i.e. it does not reveal your identity).
- How do we collect your Personal Information?
We will collect your Personal Information by fair and lawful means. We may collect Personal Information from you directly and/or from third parties, where we have obtained your consent to do so or as otherwise required or permitted by law.
In addition, to ensure that our website is optimized for ease of use, we or our service provider(s) may use cookies to collect standard information about your use of our site, including your language preferences, your browser type and version, and similar information. These cookies are intended to optimize your experience of our website and only collect anonymous information.
- Why do we collect your Personal Information?
We identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use. We generally use your Personal Information for the following purposes (the “Purposes”):
- to consider you for eligibility in the DRP and to provide bonus payments as part of the DRP;
- to receive, investigate and address operator, driver, or third party inquiries or complaints;
- to conduct internal statistical analysis;
- to investigate legal matters;
- for such purposes, as you may otherwise consent from time to time; and
- as otherwise required or permitted by law.
- To whom do we provide your Personal Information?
We generally identify to whom, and for what purposes, we disclose your Personal Information, at the time we collect such information from you and obtain your consent to such disclosure.
We may transfer your Personal Information to third party service providers with whom we have a contractual agreement (e.g. the service provider that is assisting SBO in administering the DRP) that includes appropriate privacy standards, where such third parties are assisting us with the Purposes.
- When and how do we obtain your consent?
We generally obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your consent to us either orally, electronically or in writing. The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the Personal Information and the reasonable expectations you might have in the circumstances.
For the DRP, there is a specific consent form, available on our website and distributed to school bus operator employers, that must be completed and provided by school bus drivers to their school bus operator employer prior to the school bus operator employer sharing such information with SBO.
- Where do we store your Personal Information?
We will keep the Personal Information that we collect at our office, located in Mississauga, or at the offices and data centres of our third party service providers, as applicable.
- How do we ensure the privacy of your Personal Information when dealing with third parties?
All third parties that are engaged to perform services on our behalf and are provided with Personal Information are generally contractually required to observe the intent of this Privacy Statement and our privacy practices, which practices reflect applicable privacy law.
- How long will we utilize, disclose or retain your Personal Information?
We will utilize, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law.
- How can you review your Personal Information that we have collected, utilized or disclosed?
If you make a written request to review any Personal Information about you that we have collected, utilized or disclosed, we will provide you with any such Personal Information to the extent required by law. We will attempt to make such Personal Information available to you in a form that is generally understandable.
- How fast will we respond to your written requests?
We will attempt to respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit.
- Are there any costs to you for requesting information about your Personal Information or our privacy practices?
We will not charge any costs for you to access your Personal Information in our records without first providing you with an estimate of the approximate costs, if any.
- How do you know that the Personal Information we have on you is accurate?
We will attempt to ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. We will not routinely update your Personal Information, unless such a process is necessary.
- What if the Personal Information we have on you is inaccurate?
At any time, you can challenge the accuracy or completeness of your Personal Information in our records. If you successfully demonstrate that your Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.
- How do we know that it is really you requesting your Personal Information?
We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such identifying information shall be used only for this purpose.
- What safeguards have we implemented to protect your Personal Information?
We have implemented physical, organizational, contractual and technological security measures in an effort to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. We have taken steps to ensure that only associates and third party service providers who are granted access to your Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.
- How do you contact us regarding access to your Personal Information or our privacy practices?
All comments, questions, concerns or complaints regarding your Personal Information or our privacy practices should be forwarded to our Privacy Officer as follows: info@schoolbusontario.ca attention: Privacy Officer