SUBARU CANADA, INC. PERSONAL INFORMATION PRIVACY POLICY for CUSTOMERS, SUPPLIERS, DEALERS AND PARTNERS
OUR PRIVACY COMMITMENT Subaru Canada, Inc. (“Subaru”) values its relationship with
you, our existing or potential customers, suppliers, dealers and partners,
and is committed to maintaining the security, confidentiality and privacy
of your personal information. Subaru has developed a Personal
Information Privacy Policy incorporating the principles
set out below, to reflect its on-going commitment to you. Subaru has ensured
that its Privacy Policy is in compliance with Canadian privacy laws which
apply to the collection, use and disclosure of personal information.
SCOPE OF POLICY “Personal Information”
as used in this Privacy Policy means information about an identifiable
individual. This Privacy Policy does not apply to the collection, use
or disclosure of business contact information (for example the name, title,
business address and telephone number of an employee of an organization),
to Subaru’s employees, or in part to certain publicly available
information.
ACCOUNTABILITY Accountability for Subaru’s compliance with its Privacy Policy
rests with Subaru’s Privacy
Officer, even though other individuals within Subaru may have
responsibility for management of personal information or may be delegated
to act on behalf of the Privacy Officer.
Subaru will be responsible for personal information in its possession
or custody, and will also use contractual or other available means to
provide a comparable level of protection when the information is being
processed or managed by a third party on Subaru’s behalf.
PURPOSES
In general, Subaru has collected, and will continue to collect, use and
disclose personal information for purposes authorized or required by law,
as well as for the following purposes:
to maintain accurate customer records to satisfy legal and industry-wide
regulatory obligations (for example, notification of service campaigns
and recalls)
to fulfil individual customer service and warranty-related needs
to establish and maintain communications with you relating to our
existing, past or future relationships, and our products and services,
including responding to your inquiries
to conduct surveys which help Subaru identify ways to better manage
its business and provide products and services
to distribute Six Star Review, The Magazine for Canadian Subaru
Owners and similar Subaru magazines and publications
to provide you with information about products and services related
to the maintenance of your vehicle and new product offerings
to allow you to participate in Subaru vehicle test drives
to receive communications from Subaru about special offers made jointly
with carefully selected industry partners (all correspondence of this
nature is conducted or directly managed by Subaru)
to share some of your information under strictly limited and confidential
circumstances with our affiliates, dealers, representatives, suppliers
and Subaru business partners such as the Canadian Automobile Association
(CAA) who assist us in providing products and services and allow us
to more effectively carry on our business
to establish, administer and document training, development and educational
requirements and programs
to establish, administer and document incentive programs
to evaluate potential suppliers and their staff, make decisions about
entering into product and/or supply relationships with them, and to
monitor, assess and address these relationships
to evaluate potential dealers and their staff, make decisions about
entering into dealer relationships with them, and to monitor, assess
and address these relationships
to evaluate potential partners and/or co-suppliers and their staff,
make decisions about entering into relationships with them, and to monitor,
assess and address these relationships
to evaluate potential employees and make decisions about hiring (including
employment history, reference checks, academic history and medical evaluations)
to implement and manage security programs and internal controls (including
computer monitoring and video surveillance)
to protect Subaru, and its customers, suppliers, dealers and partners,
from theft, fraud and similar risks
Unless applicable privacy laws provide otherwise, Subaru will make a
reasonable effort to specify the identified purposes in a readily understandable
way to the individual from whom the personal information is being collected,
either at the time of collection or after collection but before its use
or disclosure.
CONSENT
The way in which Subaru obtains your consent to collecting, using or disclosing
your personal information will vary depending upon its sensitivity. An
individual can withdraw consent at any time, subject to legal or contractual
restrictions, by giving to Subaru reasonable notice. In appropriate cases,
Subaru will inform individuals of any implications of withdrawing consent.
Subaru will not, as a condition of the supply of services, require an
individual to consent to the collection, use, or disclosure of personal
information beyond that required to fulfil the specified purposes.
In certain circumstances as permitted or required by law, Subaru may
collect, use or disclose personal information without the knowledge or
consent of the individual. These circumstances include the following:
to investigate a breach of an agreement or a contravention of a law; where
collection or use is clearly in the interests of the individual and consent
cannot be obtained in a timely way; personal information subject to solicitor-client
privilege; for debt collection; to act in respect to an emergency that
threatens an individual; or to comply with a subpoena, warrant or court
order.
LIMITS FOR COLLECTING, USING AND DISCLOSING PERSONAL
INFORMATION
Subaru will limit the amount and type of personal information collected
to that which is necessary for our identified purposes. Personal information
will 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 will be retained only as long as necessary to fulfil
the identified purposes, and will be destroyed or made anonymous as soon
as reasonably possible after the original purpose is no longer served
by the retention of the information, provided the personal information
no longer required for legal purposes. Personal information which has
been used to make a decision about an individual will be retained long
enough to reasonably allow the individual access to the information after
the decision, and long enough to exhaust any access request or a challenge
an individual may bring under applicable privacy laws.
ACCESS
All individuals generally have a right to access their personal information
in Subaru’s possession or custody. Upon receiving a written request
(mail, e-mail or fax) addressed to Subaru’s Privacy Officer clearly
identifying the requested information with adequate identification of
the requesting individual, Subaru will inform the individual of the existence,
use, and disclosure of the personal information and give the individual
access to that personal information. If Subaru is not able to provide
a list of the organizations to which it may have actually disclosed the
personal information, it will provide a list of organizations to which
it may have disclosed the information.
Subaru will respond to an individual’s written access request,
with information in a form that is generally understandable, within a
reasonable time (generally within 30 days) or will provide an explanation
if additional time is required to fulfil the request. While Subaru’s
response will typically be provided at no cost to an individual, depending
on the nature of the request and the amount of information involved, Subaru
reserves the right to impose charges. In such case Subaru will inform
the individual of the approximate cost to provide the response, and will
provide the information upon receipt of payment.
Individuals can question the accuracy and completeness of their personal
information and request that it be amended as appropriate. If an individual
demonstrates in a reasonable manner the inaccuracy or incompleteness of
their personal information, Subaru will amend the information as required.
If a request is not resolved to the satisfaction of the individual, Subaru
will record the substance of the unresolved request. Where appropriate,
the amended information or the existence of the unresolved request will
be transmitted to third parties having access to the information in question.
In some situations, Subaru may be permitted to refuse or not be able
to provide access to certain personal information, and will upon request
provide an explanation. Exceptions to the access right which are permitted
or required by applicable privacy laws include: information that contains
references to other individuals or contains confidential commercial information
(where such information cannot be severed from the record); information
collected in the course of investigating a breach of an agreement or in
the course of a formal dispute resolution process; and information that
is subject to solicitor-client privilege.
ACCURACY
Subaru will strive to ensure that the personal information it uses on
an ongoing basis is accurate, complete and up-to-date as necessary for
the purposes for which it is to be used, including information that is
disclosed to third parties, and information that is used to make a decision
about an individual.
SAFEGUARDS
Subaru protects the personal information it holds or controls, by establishing
reasonable security arrangements against loss, theft, unauthorized access,
use, disclosure, copying or modification. Subaru will make its employees
aware of the importance of maintaining the confidentiality of personal
information, and will exercise care in the disposal or destruction of
personal information. Examples of safeguards include physical measures
(such as locked filing cabinets and access cards), organizational measures
(such as security clearances and restrictions on employee access to files
and databases) and technological measures (such as passwords and firewalls).
OPENNESS Subaru will make the following readily available: general information
concerning our Privacy Policy; how to gain access to your personal information;
the type of personal information held by Subaru; a general account of
the use and disclosure of the personal information; and how to contact
our Privacy Officer.
CHALLENGING COMPLIANCE Subaru will, on request, provide information regarding its procedure
for addressing any complaints made with respect to Subaru’s application
of privacy laws. Subaru will investigate all written complaints, and if
it finds a complaint to be justified, Subaru will take the appropriate
measures, including, if necessary, amending our policies and practices.
Please direct any questions about the complaint procedure or any other
aspect of this Privacy Policy to Subaru’s Privacy Officer at: