Northwestel privacy policy and code

The Northwestel commitment to privacy

At Northwestel, we know you are the reason we are in business. Our longstanding commitment to safeguarding your right to privacy is fundamental to our business.

Each year, we ensure that our employees review and acknowledge their adherence to our Code of Business Ethics that requires the safeguarding and proper use of customer personal information. We also place strict controls on the protection and use of personal information within our systems and web sites and ensure that our employees are trained to respect your privacy at all times.

The Northwestel Customer Privacy Policy (the “Privacy Policy”) and the Northwestel Code of Fair Information Practices (the “Code”) spell out the commitments of Northwestel and our subsidiaries and the rights of customers regarding personal information.Our policies comply fully with the Personal Information Protection and Electronic Documents Act (“PIPEDA”).

Policy applies to Northwestel and our affiliates

The Privacy Policy applies to Northwestel and our affiliates, Latitude Wireless Inc., Tundra Communications Inc., Tahltan River Communications Inc. and Waterways Communications Limited Partnership.

In addition to the Privacy Policy, we are also subject to the requirements of applicable legislation, tariffs and regulations and the orders of any court or other lawful authority.

Any time you do business with us, or with anyone acting as an agent on our behalf, you are protected by the rights and safeguards contained in the Privacy Policy and the Code.

The Northwestel code of fair information practices

To ensure our commitment to your privacy is upheld, we have developed a formal privacy code setting out your rights and our obligations respecting the treatment of your personal information by us. The Code complies with the requirements of PIPEDA as well as the Canadian Standards Association Model Code for the Protection of Personal Information.(A summary of the principles underlying the Code is included at the end of this Privacy Policy.)The Privacy Policy that you are reading is intended as a less formal summary of our approach to customer privacy.

Employees and agents

The Codealso governs the behaviour of our employees and agents acting on our behalf.All of our employees who have access to personal information are trained on the handling of such information.New employees receive training on privacy as a fundamental part of their initial company training. All of our employees must review and commit to the Codeannually.

Personal information

Personal information is information about an identifiable individual. This includes information about your product and service subscriptions and usage.Publicly available information, such as a public directory listing of your name, address, telephone number or e-mail address, is not considered to be personal information.

1. Collecting information helps us serve you better

We collect personal information only for the following purposes:

• to establish and maintain responsible commercial relations with you and provide you with ongoing service;
• to understand your needs, preferences and eligibility for products & services;
• to recommend particular products & services to meet your needs;
• to develop, enhance, market or provide products and services;
• to manage and develop our business and operations, including personnel and employment matters;
• to verify credit worthiness; and
• to meet legal and regulatory requirements.

Your personal information will not be used for any other purpose without your consent.

Sharing Information Among Northwestel and its Affiliates Will Help Us Understand Your Full Needs

The purpose for sharing information between Northwestel and our affiliates is to help us identify your information, communication, and entertainment needs, and to provide you with relevant information, advice and solutions. Should you identify incorrect or outdated information to us, we will make the necessary changes promptly.

2. Other parties with whom Northwestel Inc. and its affiliates may share personal information

While our general policy is not to provide personal information to any third party, there are certain limited circumstances, outlined below, in which it is necessary to do so.When we do provide personal information to third parties, we provide only that information that is required in the circumstance. Information provided to third parties is used only for the purpose stipulated and is subject to strict terms of confidentiality. Employees of the companies to whom we may provide information must adhere to our privacy standards.Third parties include:

• an agent acting on the customer's behalf, such as an attorney under a Power of Attorney signed by a customer
• companies we select as our business partners
• a company that publishes a directory or provides directory-related services
• a collection agency
• a credit bureau

We may also disclose personal information to meet legal or regulatory requirements, such as under a court order or to a government institution if required or authorized by law; to public authorities or their agents in cases of emergency (e.g., a 911 call); to another communications service provider, in order to offer efficient and effective services (e.g., to provide wireless service while roaming in another company’s coverage area).

Personal information stored outside of Canada

In some cases, personal information collected by Northwestel or its affiliates may be stored and processed outside of Canada to provide you with service or to support operations.

While the information may be subject to the legal jurisdictions of these countries, the companies that provide us with these services have obligations to protect such information. For example, the information is typically provided only after detailed confidentiality agreements are exchanged with the companies that provide us with these services. Moreover, the information may only be used for the purposes of providing the services in question.

Our commitment to privacy

We take all of the necessary precautions to ensure that your personal information is safeguarded, whether it is stored electronically or in paper format. In all cases, personal information is retained in secure facilities, protected from unauthorized access and kept only as long as is reasonably required.For example, our electronic files are backed up for redundancy, password protected and accessible only by authorized employees, on a need-to-know basis.

Use of 'cookies'

During user interaction with one of our Internet sites, we may use a browser feature called a 'cookie' to collect information anonymously and track user patterns on our web sites.A cookie is a small text file containing a unique identification number that identifies your browser - but not you - to our computers each time you visit one of our sites that uses cookies. Cookies tell us which pages of our sites are visited and by how many people.This helps us to enhance the on-line experience of visitors to our sites.

Unless you specifically advise us, we will not know who you are, even though we may assign your computer a cookie. We cannot use cookies, by themselves, to disclose the individual identity of any site user, and we never combine information gathered by a cookie with personally identifiable information like your name, telephone number, or even your e-mail address.

You will find that most major web sites use cookies and most major browsers are set up to accept them.If you wish, you can reset your browser either to notify you when you have received a cookie, or to refuse to accept cookies. You do not need cookies to visit Northwestel sites.However, if you refuse to accept cookies, you may not be able to use some of the features available on our sites such as personalization features.

Enhance your privacy with our services

We offer a number of services to help balance the privacy interests of customers and the people they call.You can find information about our services (e.g., Call Number Display, Call Blocking, Call Trace, Non-Published Numbers, etc.) in the introductory pages of the telephone directory, by calling our offices during business hours, or by visiting our website at www.nwtel.ca.

Questions or concerns

If you have questions or concerns about your privacy, you can contact us through one of the websites listed above or call us at 1 888 423-2333. Our customer service representatives will assist you in resolving the situation

Our privacy representatives

If you still have unresolved concerns with respect to the treatment of your personal information by us, you may address these concerns, in writing, to our privacy officer, who has overall responsibility for compliance with our privacy policies.You should write to:

Attention: Senior Manager - Regulatory Compliance

Northwestel Inc.

P.O. Box 2727
Whitehorse, Y.T.
Y1A 4Y4

or via email at RegulatoryAffairs@nwtel.ca

Further complaint procedure

 If our privacy officer is unable to resolve the issue to your satisfaction, you may file a complaint with the Privacy Commissioner of Canada by calling 1 800-282-1376 or writing to:

The Privacy Commissioner of Canada
112 Kent Street
Ottawa ON K1A 1H3

Customer choice

You may decide that you prefer us not to share your personal information with our affiliates to promote products and services.If this is the case, you may advise us by calling us at 1 888 423-2333.

Northwestel code of fair information practices
 

Summary of principles

• Accountability: We are responsible for customer personal information under our control and have designated specific representatives as accountable for our compliance with these principles.
• Identifying purposes for collection of customer information: We will identify the purposes for collecting personal information at or before the time the information is collected.
• Obtaining consent for collection, use or disclosure of customer information: We require the knowledge and consent of our customer for the collection, use, or disclosure of personal information, except where inappropriate or impractical (e.g., in emergency situations).
• Limiting collection of customer information: We will limit the collection of personal information - by fair and lawful means - to that which is necessary for the purposes identified to our customers.
• Limiting use, disclosure and retention of customer information: We will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of our customer or as required by law.We will retain personal information only as long as necessary to fulfill those purposes.
• Accuracy of customer information: Personal information will be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
• Security safeguards: We will protect personal information by security safeguards appropriate to the sensitivity of the information.
• Openness concerning policies and practices: We will make specific information about our policies and practices relating to the management of personal information readily available to customers.
• Customer access to customer information: Upon request, we will inform a customer of the existence, use, and disclosure of his or her personal information and will give the customer access to that information. A customer may challenge the accuracy and completeness of their personal information and have it amended as appropriate.
• Challenging compliance: A customer may address a challenge concerning compliance with these principles to our privacy officer.