PRIVACY POLICY – TURKEY FARMERS OF ONTARIO

Privacy Commitment

The Turkey Farmers of Ontario (TFO) has a longstanding policy on the confidentiality of personal information and is committed to protecting the personal privacy of all those with whom it has dealings. The TFO keeps all information respecting individuals dealing with the TFO in strict confidence. No individual personal information is sold by the TFO. The TFO has procedures to enable individuals to control how the TFO obtains, uses and gives out personal information, to review that information and to correct any errors that may exist. The TFO’s procedures and systems are designed to protect such information from error, loss and unauthorized access. The TFO keeps such information only as long as it is needed. The TFO continually monitors its compliance with applicable privacy legislation. The TFO respects peoples’ privacy when it carries out its roles and responsibilities. These obligations apply to all TFO Directors, staff, consultants and agents and contractors who provide services to or on behalf of the TFO.

The TFO may also use such information to assist other regulatory agencies in undertaking their responsibility on bio-security and food safety issues.

Regulatory Duties

As a local board constituted under the Farm Products Marketing Act, the TFO, through regulation, has information filing requirements. The TFO collects, uses, discloses and retains this information in order to regulate the production and marketing of the turkey in accordance with its regulations, policies, orders, directions and decisions. The TFO may collect such information directly from producers or from others involved in the production and marketing of turkey.

In carrying out these regulatory functions, the TFO, as a not-for-profit body representing turkey producers, is not engaged in commercial activity. Information arising from the TFO’s exercise of these regulatory authorities is not believed to be subject to the Personal Information Protection and Electronic Documents Act (PIPEDA). In those limited circumstances where the TFO may be engaged in commercial activity, it would be subject to PIPEDA and all of that Act’s provisions apply with respect to personal information collected, used, disclosed or retained as part of that commercial activity.

Consent Requirement

The TFO obtains the parties’ express or implied consent before obtaining or using personal information about that person or disclosing that information to anyone in the course of commercial activities. Regulatory requirements as well as biosecurity and food safety concerns are excepted from the consent requirement. Participation in certain TFO programs will constitute consent to the obtaining, use and disclosure of personal information. Details will be set out in program information packages.

Persons not wishing to provide their consent may decline to participate or may notify the TFO and their wishes will be respected. In some cases, participation may not be possible where the necessary personal information is not made available.

Limited Disclosure

There are circumstances, including, but not limited to, those relating to the control or eradication of a suspected or confirmed outbreak of an Infectious Poultry Disease, where use and disclosure of personal information may be justified or permitted under a legal duty or right and the TFO may use and disclose such information without the party’s consent. In such cases where the TFO is of the opinion that it is appropriate or necessary to use or disclose such information, the use and disclosure will be limited so that only that information which is required is used or disclosed.

Producer Information

As a general rule, all producer information is held in strict confidence and, except in very limited circumstances, is not revealed to anyone unless expressly or implicitly authorized by the producer. The TFO guards its producer mailing list from unauthorized use and disclosure. Where disclosure is appropriate to address bio-security or food safety concerns, such disclosure will be subject to appropriate safeguards.

In the event of a suspected or confirmed reportable disease outbreak, the provisions of this Privacy Statement will not apply and TFO will disclose such personal information, as required, to other regulatory agencies, including but not limited to the Canadian Food Inspection Agency, in connection with their statutory mandate to assist in an effective response.

Privacy Officer

The TFO has appointed a Privacy Officer charged with the responsibility for developing, implementing and administering the ID&PS. As part of this mandate, the Privacy Officer has put in place all of the necessary internal controls and procedures and has trained and supervised TFO staff in achieving full compliance with all privacy obligations. The Privacy Officer will receive and follow up on all inquiries. This includes such things as withdrawal of consent, request for disclosure of information on file, corrections to information and termination of consent previously given. All such requests must be in writing and may result in an administrative charge to cover the TFO’s costs in dealing with the same.

Website Policy

A visitor to the TFO website is not required to reveal any individually identifiable information such as name, address or telephone number. Nor is such information collected passively by electronic means. Information is collected when an individual voluntarily completes an online survey. This information is collected, used or disclosed in a manner consistent with this policy statement. E-mail addresses are also collected during any surveys but participants may indicate that they do not wish to receive any unsolicited electronic communication.

The TFO’s web server does not collect visitor information in the form of the visitor’s domain or Internet protocol (IP) address but does collect information regarding which pages are accessed. This information is used internally, only in aggregate form, to help the TFO serve website users better. None of this information is retained after it has been used and is discarded in a secure manner. Any user of the TFO website may access the information held by the TFO about them in connection with their visits to the website. Any inaccuracies that are brought to the TFO’ s attention will be corrected.

Compliance Concerns

Any complaints concerning the access to accuracy, management or use of personal information should be addressed in writing to the Privacy Officer. All such inquiries will be responded to within 30 days of receipt at the TFO office. Any unresolved matters may be referred by the Privacy Officer to the TFO. If a party is still not satisfied, contact should be made with the office of the Privacy Commissioner in Ottawa.

Policy Review

This privacy policy is in effect as of October 6, 2015. The TFO will from time to time review and revise its privacy practices and this privacy policy. In the event of any amendments to this privacy policy, a notice will be posted on the TFO’ s website or communicated to producers through TFO publications. The TFO is committed to meeting all of its privacy obligations. Any questions or suggestions will be welcome and should be addressed to the Privacy Officer – privacyofficer@turkeyfarmers.on.ca