ZSA Legal Recruitment Limited (“ZSA”) is committed to protecting your personal information. This Policy describes how ZSA collects, uses and discloses personal information. Please read this Policy carefully and if you have any questions or concerns, contact our Chief Privacy & Data Protection Officer at privacy@zsa.ca.
I. Application
This Policy governs the collection, use and disclosure of personal information by ZSA from and about individuals who are not employed by ZSA, and applies to every branch office of ZSA including our offices in Vancouver, Calgary, Toronto, and Montreal. This Policy also applies to each division within ZSA; including ZSA Legal Recruitment, ZSA Quebec, and LexLocom. It is our policy to comply with the legislation within each jurisdiction in which we operate, as well as with applicable data privacy regulations for candidates outside of Canada. This Policy covers those activities that are subject to the provisions of applicable federal, provincial, and international laws and regulations.
II. What is Personal Information?
In this Policy “personal information” refers to any information about an identifiable individual other than the person’s business title or business contact information.
III. What Personal Information Do We Collect?
We collect and maintain different types of personal information in respect of individuals with whom we interact. This includes:
- contact and identification information, such as your name, address, telephone number and e-mail address;
- product and service related information concerning the products and services that we provide to, or receive from, you;
- customer relationship information such as customer requests and feed-back and information requested or provided by or from you; and
- business relationship information, including information related to your agreements, preferences, advisors and decision-makers.
- In order to provide recruitment services to our clients we may also collect:
- resume information such as your employment history, clients/transactions lists, academic history and transcripts
- remuneration information such as previous or expected salary, benefits and bonuses;
- job search information such as the history of jobs/employers that you have applied to, interview notes and personal preferences;
- evaluations by ZSA consultant(s) and correspondence between candidates and ZSA; and
- payroll information, if applicable, including your Social Insurance Number and direct deposit bank account information.
We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business and information related to our media and public relations activities.
IV. Why Do We Collect Personal Information?
We collect personal information to enable us to manage and develop our business and operations, including:
- to establish, maintain and manage relations with you so that we may provide you with, or receive from you, the products and services that have been requested (for example, we will use your personal information to determine your suitability for a position);
- to be able to review the services that we provide to you so that we may understand your requirements for our services and so that we may work to improve our services;
- to be able to inform you of our services other than those that you have specifically requested, including sending you information promoting our other services;
- to be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number or e-mail address and advise us of your preference, we will use this information to contact you at that number or e-mail address);
- to protect us against error, fraud, theft and damage to our goods and property;
- to enable us to comply with applicable law or regulatory requirements; and any other reasonable purpose to which you consent.
V. How do we Use and Disclose Your Personal Information?
We use and disclose your personal information:
- for the purposes described in this Policy; or
- for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information (which consent may be express, deemed or implied, as explained below).
We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so. If you are a candidate, please rest assured that your personal information will not be disclosed to any potential employer without your prior consent.
VI. Our Website
You can visit our website (www.zsa.ca) without telling us who you are or revealing any information about yourself, including your e-mail address. Our web server may collect information related to your visit to our website, including the IP address and domain used to access our site, the type and version of your browser, the website you came from to access our site, the page you entered and exited at, any website page that is viewed by that IP address and what country you are from. We use this information to monitor our website’s performance (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our website.When you apply for a position on our website, we imply that you have consented to the collection, use and disclosure of your personal information for the purposes of recruitment and placement by ZSA.
VII. Who Has Access to Your Information?
We share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with establishing, maintaining and managing our relationship with you, including: third parties that provide services to us or on our behalf; third parties that collaborate with us in the provision of services to you; and third parties whose services we use to perform our services. In addition, personal information may be disclosed or transferred to another party in the event of a change in ownership of, or a grant of a security interest in, all or a part of ZSA through, for an example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Policy, unless you consent otherwise.
VIII. Your Consent Is Important To Us
It is important to us that where we collect, use or disclose your personal information we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, if you submit a resume or other personal information by mail, fax, or e-mail, whether in response to an advertisement or to ZSA in general, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to your recruitment and placement by ZSA. You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our Chief Privacy & Data Protection Officer using the contact information set out below. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide services to, or acquire products or services from, you. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to your consultant or our Chief Privacy & Data Protection Officer.
IX. Protecting Personal Information
We understand the importance of protecting your personal information. For that reason ZSA endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure. Documents which contain personal information are kept in filing cabinets which are maintained in each of our regional offices. All electronic information is stored on our server which is maintained in Toronto.
IMPORTANT: Please be advised that all data is now stored and transferred on our database, with a cloud provider who stores data outside of Canada, namely, it is a United States cloud service provider. The transfer of personal information does not entitle ZSA to use that information for purposes other than those for which you have expressly or impliedly consented. ZSA remains accountable for the protection of the personal information that has been transferred. The organization we have hired that receives the personal information provides a comparable level of data security as would be required under Canadian law. Thus, your personal information will be transferred outside of Canada for processing and storage, and your personal information will be subject to the laws of the foreign jurisdiction. ZSA is committed to protecting its computer networks and has established a protocol for preventing and mitigating the effects of threats or breaches to our networks pursuant to our Data Security Policy, which all ZSA employees are required to abide by. For a copy of our Data Security Policy, please contact our Chief Privacy & Data Protection Officer.
X. Is Your Personal Information Accurate?
Please let us know if you believe that your personal information is inaccurate. You have the right to ask for it to be corrected or updated. We may ask you to provide documentation to support your request for correction or updating. If we do not agree with your request, we will include your request in our file.
XI. Access to Your Personal Information
You have the right to see your personal information held by ZSA. If you would like to see your personal information we ask that you fill out and submit an Access to Information Form. This form may be found on our website or by contacting your consultant or our Chief Privacy & Data Protection Officer. When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact your consultant or our Chief Privacy & Data Protection Officer. Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices. In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions. You also have the right to request that ZSA delete your name and personal information from our records at any time. This can be done by contacting our Chief Privacy & Data Protection Officer.
XII. Chief Privacy & Data Protection Officer
We have appointed a Chief Privacy & Data Protection Officer to oversee compliance with this Policy. The contact information for our Chief Privacy & Data Protection Officer is as follows:
Chief Privacy & Data Protection Officer
200 University Avenue, Suite 1000
Toronto, Ontario
M5H 3C6 privacy@zsa.ca
XIII. Revisions and Interpretation
ZSA may from time to time make changes to this Policy. We will post any revised versions of this Policy on our website at www.zsa.ca. Any changes to this Policy will be effective from the date they are posted. If any changes are made to ZSA’s use, collection or disclosure of your personal information that require your consent, we will not implement such changes until your consent has been obtained.
