PRIVACY POLICY
LEGAL DISCLAIMER
At The Jefferson Hawthorne Group (“The Jefferson Hawthorne Group”), we are committed to protecting your privacy rights. The nature of our business involves obtaining certain personal details related to executives, decision-makers, and other stakeholders within organizations. Keeping your information confidential is vital to our primary objective of providing the best service possible to our clients.
This Privacy Policy represents our commitment to safeguard your personal information and provides you with the details of how your privacy and your personal information are protected. At The Jefferson Hawthorne Group, we are accountable for compliance with the principles set out herein with respect to any personal information under our control. Our employees are informed in the use and safeguarding of personal information in accordance with this Policy and receive training on our privacy procedures.
What is Personal Information?
Personal information is any information, either factual or subjective, about an identifiable individual. However, personal information does not include the name, title, business address, or business telephone number of an employee of an organization.
How does The Jefferson Hawthorne Group use Personal Information?
The Jefferson Hawthorne Group uses personal information primarily for delivering strategic leadership advisory services. We obtain and use information necessary to understand client needs, create tailored strategies, and support leaders in critical decision-making processes. The information we obtain is used strictly in connection with our consulting engagements and related activities.
We use this personal information with utmost respect and appropriate safeguards. Personal information is not used or transmitted to anyone else for any other purpose but those listed above. Personal information will only be used or disclosed for purposes that a reasonable person would consider appropriate in our business.
How does The Jefferson Hawthorne Group Collect Personal Information?
Typically, personal information will come either from individuals directly or from third parties authorized by individuals, such as senior executives or decision-makers who engage our services. This information may also be obtained through public records or sources provided with consent from the individual.
The Jefferson Hawthorne Group does not collect your information for any purpose other than those identified in this Policy. Personal information may be collected to tailor our advisory services.
Ordinarily, we will not use or disclose your personal information other than for the purposes outlined above. However, in the course of conducting our business and to carry out certain lawful purposes, other parties, such as affiliated companies, strategic partners, and other suppliers or agents who facilitate our services may require access to your personal information.
Why do we Collect Personal Information?
We collect, use, and disclose personal information about you so that we can:
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Establish your identity;
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Protect you and us from error and fraud; and
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Comply with legal and regulatory requirements.
It is important that you are made aware of the purpose behind our use of personal information. The purpose may be communicated to you verbally or in writing.
The Jefferson Hawthorne Group will not use your information for any purpose other than what you would reasonably expect us to. We never sell personal information to third parties and only use or share personal information as necessary in providing our services to you and our clients in accordance with applicable privacy laws.
The Jefferson Hawthorne Group’s Actions to Protect Your Personal Information
The Jefferson Hawthorne Group safeguards your personal information through physical, organizational, and technological processes and systems designed to protect your personal information from unauthorized access, disclosure, use, or modification, and against loss or theft. We review and audit our security policies and procedures on a periodic basis to ensure that our systems are secure and protected.
We use industry-leading technologies and data protection standards to ensure that all client and leadership data remain secure, confidential, and protected against unauthorized access.
Obtaining your Consent
The Jefferson Hawthorne Group follows privacy laws applicable in Ontario and Canada, ensuring that with limited exceptions, we obtain your consent before collecting, using, or disclosing your personal information. Consent can be implied or express and may be provided in writing, orally, or electronically.
Implied consent is granted when you engage our services. We assume you consent to the necessary use of your information in delivering these services effectively.
Compliance with PIPEDA
The Jefferson Hawthorne Group complies with the Personal Information Protection and Electronic Documents Act (PIPEDA) and all relevant provincial privacy legislation applicable in Ontario. We ensure that all personal information collected, used, or disclosed is handled in accordance with these laws and regulations, which govern the privacy and confidentiality of individuals’ personal data.
We adhere to the highest privacy standards, maintaining the integrity and confidentiality of all executive and client information as required by law.
Data Breach Procedures
In the event of a data breach that affects personal information, The Jefferson Hawthorne Group follows a data breach response protocol in compliance with PIPEDA. We will assess the breach, mitigate any potential harm, and notify affected individuals if the breach poses a significant risk of harm. We will also report the breach to the Office of the Privacy Commissioner of Canada as required by law.
Privacy at The Jefferson Hawthorne Group
The Jefferson Hawthorne Group has created this Privacy Policy to outline our privacy process and procedures and to inform you of our commitment to managing and protecting your personal information in accordance with best practices and applicable privacy legislation. This Policy is available on our website at www.jeffersonhawthorne.com and may be requested in paper form by contacting the Chief Privacy Officer at the address set out below.
If you have any questions or concerns about this Policy or about privacy at The Jefferson Hawthorne Group, please contact our Chief Privacy Officer by phone, mail, or email, and we will address your concerns to the best of our ability.
Please note that privacy laws provide for certain limited exceptions to matters included in this Policy. At times, these exceptions will affect our privacy practices. For example, at times, The Jefferson Hawthorne Group may collect, use, or disclose your personal information if one of the following situations arises:
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If the personal information is deemed "publicly available" under relevant privacy legislation. For example, if the personal information appears online or in a public document, like a telephone directory.
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If the collection and use of your personal information is clearly in your best interests and for some reason consent cannot be obtained from you in a timely way. This situation may arise if we are retained to locate you to help reunite you with unclaimed assets.
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If a situation arises where we are required to disclose personal information by law. For example, if we are required to provide information to the Canada Revenue Agency for tax purposes.
From time to time, we may change our internal privacy policies and procedures to update them in accordance with changes in relevant privacy legislation and industry practice. Any changes to The Jefferson Hawthorne Group’s privacy policies and procedures will be reflected in this Policy.
Responding to Your Privacy Concerns
We encourage you to contact us with any questions or concerns you may have with respect to this Policy or our internal privacy policies and procedures. All questions will be investigated and responded to promptly.
Contact Details:
T. 647.621.2646
M. 2345 Yonge Street, Suite 300, Toronto, Ontario M4P 2E5
E. privacy@jeffersonhawthorne.com
If you are contacting us regarding a privacy concern, please provide your name, address, preferred method of communication, the nature of your question, and any relevant details, including previous communications you may have had with us regarding your concerns. Any personal information you provide to us when you contact us will help us to better research and respond to your inquiry. Any personal information you provide to us when you contact us with your concern will be used only for that purpose.