Privacy Policy

Compliance Marketing Services, Inc.

Compliance Marketing Services, Inc. (CMS), adheres to the privacy recommendations as set-out by the Canadian Marketing Association (CMA – www.the-cma.org), the Federal privacy laws (the Privacy Act and the Personal Information Protection and Electronic Documents Act) and any applicable Provincial Statutes enacted as of January 1, 2004. All enquires regarding privacy issues and access to consumer and client data maintained and stored by CMS should be referred to our Privacy Officer:

Michael E. Booth
Privacy Officer
Compliance Marketing Services, Inc.
A-1331 Crestlawn Drive
Mississauga, Ontario
Canada L4W 2P9
Tel: 416 503-2825 ext: 204
Fax: 416 503-1665
Email: privacy.officer@compliancems.com
Web: www.compliancems.com

There are 2 broad categories we are concerned with when managing the consumer and business data entrusted to us by our Clients:

    1. Confidentiality of Client Data
    2. Right of a Client’s Customer to Access/Manage Their Personal Data

1. CONFIDENTIALITY OF CLIENT DATA

Confidentiality

Client data files that are entrusted to CMS are absolutely confidential. Client data files are the exclusive property of each CMS Client. Unless we have an explicit instruction to do so by the Client, we do not rent, trade or otherwise provide Client data file(s) in "electronic" or "printed" copy to any of our other clients nor to any third party - individual, company or organization.

Master Files Maintained for "List Rental" or "Trade"

If we maintain a Master File on behalf of a Client for the specific purpose of renting or trading names we do so only on direct instruction from the Client or a list manager who the Client has designated as their representative. Such direction to be in written format only. If a Client wishes us to maintain such a file for "List Rental" or "Trade" purposes it is the responsibility of the Client to ensure that each of the contacts on the list has consented to be on the list for the purpose(s) intended as detailed in the Federal Act, Personal Information Protection and Electronic Documents Act covering the collection, use and disclosure of personal information.

Backup Copies

Where we process Client data, we may retain Client data on our system for up to three weeks and include this data in our regular backup procedures. This is a safeguard against incidents such as, a courier loosing the data we have shipped to a Client or data corruption on the transfer medium due to circumstances beyond our control. Client backup data is accessible by Senior CMS staff only.

Where we host Client databases, we provide daily back up of the data, processing back up files each evening at close of business.

Excluding "No Mail" Records From Mailings/Telemarketing Programs

We encourage all our Clients to respect the code of ethics drafted by the CMA with particular emphasis on requests from people who indicate that they do not want to receive unsolicited mail.

Three steps we recommend to our Clients are:

• Use the CMA "No Mail" file as a kill file for prospect mailings. This file comprises people who have contacted CMA with the request that they not receive unsolicited mail. The CMA also maintains a "No Telemarketing" file and we also advise that telemarketers use it as a kill file.
  
  
• Maintain, in-house, a list of people who have asked you that their names not be traded or rented to other organizations.
  
  
• Offer your customers the opportunity to opt out of future communications within each executed program.

CMS believes that exclusion of people who do not want to receive mail is both a matter of respect for privacy (and the law as of January 1, 2004) and good business practice. Clients should not want to mail to people who will not respond and who may contact you or the CMA.

2. RIGHT OF A CLIENT'S CUSTOMER TO ACCESS/MANAGE THEIR PERSONAL DATA

CMS adheres to the 10 Privacy Principals inherent in the both Federal and Provincial privacy legislation which takes effect as of January 1, 2004. These principals are as follows:

1. Accountability – Every business is responsible for personal information under its control and is required to designate a "Privacy Officer" who is accountable for compliance with Federal and Provincial Privacy Legislation.
   
   Michael E. Booth
   Privacy Officer
   Compliance Marketing Services, Inc.
   A-1331 Crestlawn Drive
   Mississauga, Ontario
   Canada L4W 2P9
   Tel: 416 503-2825 ext: 204
   Fax: 416 503-1665
   Email: privacy.officer@compliancems.com
   Web: www.compliancems.com
   
   
2. Identifying Purpose – Each time a request is made for "Personal Information" the purpose(s) for which the information will be used must be clearly identified.
   
   CMS recommends the use of a clear Disclosure Statement and method for acceptance or rejection of the purpose(s) in close proximity to the location where the customers' personal information is collected.
   
   
3. Consent – Consumers must be knowledgeable and provide consent for the collection, use and/or disclosure of personal information.
   
   Note: See Point 2 immediately above.
   
   
4. Limiting Collection – Personal information collected under the prevailing Privacy Legislation will only be used for the original purpose(s) identified at the time it was collected.
   
   Note: CMS will not recommend a Client use a customer's personal information for marketing initiatives not permitted under the terms of the original consent process.
   
   
5. Limiting Use, Disclosure and Retention – Personal information collected will never be used or disclosed for anything other than that for which the customer consented. Personal information no longer required as per the original consent will be deleted.
   
   
6. Accuracy – CMS strives to ensure that personal information managed on behalf of its Clients is as accurate, complete and up-to-date as possible.
   
   
7. Safeguards – CMS provides industry standard data safeguards for all personal information entrusted to our management.
   
   Note: CMS deploys a robust external firewall to ensure our systems are adequately protected from unauthorized access. CMS also provides complete daily system back-up. These tapes are stored off site in a secure location each evening.
   
   
8. Openness – Through our Privacy Officer, information specific to our policies and practices concerning the management of customer information is accessible.
   
   
9. Individual Access – With Client consent, Client customers can contact the CMS Privacy Officer directly about existence, use and disclosure of their Personal Information stored on-site. An individual will be able to access the personal information, have it amended if required or have the personal information deleted from future marketing programs.
   
   
10. Challenging Compliance – Should a Clients customer have concerns about their Personal Information managed by CMS as detailed in the above Principals, they can present their concerns regarding their Personal Information to the CMS Privacy Officer and expect to have their concerns dealt with in an expedient manner including access the personal information, have it amended if required or have the personal information deleted from future marketing programs.