Privacy Policy

Please note: As of March 10, 2020, the following sections have been added to this version of the Privacy Policy.

  • Section 2C. Automated Technologies or Interactions
  • Section 7ii. Cross border transfer of information

Introduction

The Canadian Administrator of VRS (“CAV”) is committed to protecting Customers’ privacy and confidentiality in accordance with principles set out in the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and our obligations under applicable privacy law and Canadian Radio-television and Telecommunications Commission (“CRTC”) Telecom Regulatory Policy CRTC 2014-187, as such laws and policies relate to the delivery of the Video Relay Service (“VRS Service” or “Service”).

The “Service” is a telecommunications service that enables people who are Deaf, Hard of Hearing or Speech-Impaired and who use sign language to communicate with voice telephone users. The sign language user connects to a VRS operator using Internet-based videoconferencing. The operator then places a voice telephone call to the other party and relays the conversation from sign language to voice and vice versa.

This Privacy Policy (this “Policy”) explains how CAV collects, uses and discloses Customers’ Personal Information in the course of providing the Service. By registering for the Service, you agree to the terms of this Policy. This Policy covers the following:

This Policy covers the following:

  1. What is Personal Information
  2. What Personal Information does CAV collect
  3. Why does CAV collect Customer’s Personal Information
  4. How does CAV collect Customer’s Personal Information
  5. How does CAV collect Personal Information from Minors
  6. How does CAV use Customer’s Personal Information
  7. When may CAV disclose Customer’s Personal Information
  8. Where Personal Information may be Used or Disclosed Without Consent
  9. How Customers may access or correct their Personal Information
  10. How CAV protects Customer’s Personal Information
  11. Links to other websites
  12. Resolving Customer privacy concerns
  13. Changes to this Privacy Policy

In the delivery of the Service, CAV complies with the following principles set out in Schedule I to PIPEDA:

Principle 4.1 (Accountability) – An organization is responsible for personal information under its control and must designate an individual responsible for compliance with PIPEDA;

Principle 4.2 (Identifying Purposes) – An organization must specify why it is collecting Personal Information, and such purposes must be identified at or before the information is collected;

Principle 4.3 (Consent) – An organization must obtain an individual’s consent for the collection of Personal Information and subsequent use and disclosure;

Principle 4.4 (Limiting Collection) – An organization must limit the collection of information to that which is necessary for the identified purposes;

Principle 4.5 (Limiting Use, Disclosure, and Retention) – An organization must not use or disclose Personal Information for a purpose other than for which it was collected, except with the consent of the individual or where required or permitted by law;

Principle 4.6 (Accuracy) – An organization must ensure that Personal Information it maintains is accurate, complete, and up to date;

Principle 4.7 (Safeguards) – An organization must take appropriate safeguards to protect Personal Information;

Principle 4.8 (Openness) – An organization must be open about its policies and practices;

Principle 4.9 (Individual Access) – An organization must provide individuals with a right of access to their Personal Information, subject to certain restrictions as set out in PIPEDA; and

Principle 4.10 (Challenging Compliance) – An organization must advise individuals of its complaint procedures.

1. What is Personal Information?

“Personal Information” means any information, recorded in any form, about an identifiable individual.

This Policy does not cover business contact information (e.g., name, title, business address) used solely for the business purposes, or aggregated data from which the identity of an individual cannot be determined. CAV retains the right to use business contact information and aggregated data in any way that CAV determines appropriate.

2. What Personal Information does CAV collect?

A. Personal Information collected during the Registration Process

Some examples of the type of information CAV collects from Customers during the registration process to become a user of the Service are:

1. Customer name
2. Customer complete physical address
3. Customer email address
4. Customer birth month and year. For users under the age of majority: if a Customer is under the age of majority, CAV will obtain parental consent prior to collection of their personal information).
5. Password(s) Customer is asked to create in order to use the Service
6. Type and version of the electronic device(s) Customer uses to access the Service
7. Customer’s Assigned VRS number
8. Customer’s selected preferences, such as primary language of Service (English or French), etc.
9. Confirmation of Deaf, Hard of Hearing or Speech-Impaired and use of sign language.

CAV may also collect certain information about Customers’ use of our Service or website when they interact with or use our Service or website, or respond to e-mails, newsletters or promotional or other information communications.

B. Personal Information collected during a VRS Telephone Call

CAV has contractual agreements with third-party sign-language interpreters (“Interpreters”), which obligate the Interpreters to maintain strict confidentiality with respect to the contents of the VRS call, as follows:

    • Interpreters must respect the privacy of the Customers of the Service, hold in strict confidence, and not disclose to any other party, any and all information the interpreter may obtain during the course of providing the Service to users;
    • confidentiality obligations shall survive forever, and the interpreter shall only be released from these obligations with the prior written consent of CAV, when required by law or where, in order to provide consistent quality services, it is necessary to disclose pertinent information to a colleague who is subject to similar confidentiality obligations as contained in the confidentiality agreement with the interpreter; and
    • where it is necessary to exchange pertinent information with a colleague in order to provide consistent quality of service, this shall be done in a manner that protects the Personal Information of the Customers.

CAV shall also obtain appropriate forms of consent from Customers with respect to the Interpreters’ access to the contents of the VRS call.

CAV makes recordings of Call Record Details, such as time, duration, completion status, source number, and destination number. CAV does not make any audio or video recordings of the contents of the VRS calls and will not be collecting any Personal Information Customers may reveal in conversation during a VRS call.

C. Automated Technologies or Interactions

As you interact with our Website, we may automatically collect technical data about your equipment, browsing actions and patterns. We collect this information by using cookies, server logs and other similar technologies. The information is used for website analytics purposes only.

3. Why does CAV collect Personal Information?

CAV only collects Personal Information for purposes that would be considered reasonable in the circumstances and only such information as is required for the purposes of providing the Service. CAV collects Customers’ Personal Information to enable Customers to use the Service and associated purposes, including the following:

  • initiating or providing Customers with the Service and access to the website;
  • providing Customers with ongoing technical support;
  • providing ongoing administration of Customer registration;
  • complying with legal requirements;
  • facilitating 911 calls or other emergencies;
  • detecting, preventing, or otherwise addressing fraud, identity theft, security or other technical issues;
  • protecting the rights, property or safety of CAV, our employees or Customers, or the public, as required or permitted by law; and
  • other purposes consistent with these purposes.

Information regarding Customers’ physical addresses is collected solely for the purposes of facilitating 911 calls.

Information regarding the type of electronic device and software version that Customers use to access the Service is collected for the purpose of enabling CAV to distribute the correct VRS user software to the Customers and provide appropriate customer service, including the distribution of patches and upgrades. In addition, this information is used for the purposes of providing technical support and planning for future software development.

4. How does CAV collect Customers’ Personal Information?

CAV uses only fair and lawful methods to collect Personal Information. Unless permitted by law, no Personal Information is collected, without first obtaining the consent of the individual. Consent may be express or implied as required by the circumstances and applicable laws. CAV may seek additional consent from Customers after Personal Information has been collected where CAV wishes to use or disclose the information for a new or different purpose.

Subject to legal and contractual restrictions, Customers are free to refuse or withdraw their consent at any time upon reasonable, advance notice to CAV. In certain circumstances, the Service can only be offered if Customers provide their Personal Information to CAV. Consequently, if a Customer chooses not to provide us with the required Personal Information, CAV may not be able to offer the Service to said Customer. CAV will inform the Customer of the consequences of the withdrawal of consent.

5. How does CAV collect Personal Information from Minors?

An individual under the legal age of majority (a “Minor”) may use the Service, as long as CAV obtains a Parental/Guardian Consent Form to allow the Minor to use the Service. A written notice of our privacy practices and a Parental/Guardian Consent Form Request may be found on our website or by contacting Customer Service at [email protected] The Consent Form must be signed and returned to CAV by email or regular mail prior to the Minor having access to the Service.

When a Customer registers to use the Service on behalf of their Minor child, in addition to the Personal Information CAV collects from all Customers, CAV collects the Minor’s month and year of birth to determine such time when parental consent is no longer required.

6. How does CAV Use Customers’ Personal Information?

CAV uses Customers’ Personal Information to provide Customers with the Service and the website, and to respond to Customers’ questions. CAV also uses it to provide a better user experience and to continue improving the quality of our products and services. CAV may use Personal Information and other information to communicate with Customers about our Service, including updates or newsletters, or to deliver content that may be of interest to Customers.

CAV also uses the information collected to ensure that our Service and website remain functioning and secure, or to investigate, prevent or act on any illegal activities or violations of our Service Agreements. Our use of Personal Information is limited to the purposes described in this Policy and CAV does not otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information it has obtained.
CAV may use Personal Information to generate aggregate or non-identifying information, which CAV may use and disclose in its sole discretion.

7. When may CAV Disclose Customers’ Personal Information?

CAV may disclose Customers’ Personal Information to:

  • Individuals or organizations who are our advisers or service providers; and
  • Individuals or organizations who are, or may be, involved in maintaining, reviewing and developing our systems, procedures and infrastructure including testing or upgrading our computer systems.
    • Third party service providers or contractors: CAV contracts with third-party Interpreters to provide sign language interpretation required during the provision of the Service. Where CAV transfers Personal Information to service providers or contractors that perform services on our behalf, CAV will require those third parties to use such information solely for the purposes of providing services to CAV or our users, and to have appropriate safeguards for the protection of that Personal Information. Sharing of information with third-party service providers and contractors will occur only after those entities have entered into a confidentiality agreement that:
      1. prohibits them from using, allowing access to, or disclosing Customer Personal Information to any other party (unless required to do so by law);
      2. requires them to have appropriate protections in place to ensure the ongoing confidentiality of Customer’s Personal Information; and
      3. in the case of Interpreters, prohibits them from disclosing the contents of any VRS call.
    • Cross border transfer of information: CAV contracts with Interpreters located in the U.S to provide sign language interpretation required during the provision of the Service. Personal Information, including the date and time of the call, and the name and VRS number of the caller, is collected by the Interpreter workstation, and used and stored in the U.S. in cases where CAV has contracted with service providers with U.S. operations for purposes of providing the Service by CAV. The privacy laws in the U.S. may offer different levels of protection from those in Canada, and the Personal Information may be subject to access by and disclosure to law enforcement agencies under the applicable legislation in the U.S. Please contact CAV’s Privacy Officer at [email protected] with any questions.

8. Where Personal Information may be Used or Disclosed Without Consent

There are circumstances where the use and/or disclosure of Personal Information by CAV may be permitted or required without consent. Such circumstances may include, without limitation:

1. where required by law or by order or requirement of a court, administrative agency or governmental tribunal;

2. where CAV believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;

3. where it is necessary to permit CAV to pursue available remedies or limit any damages that CAV may sustain;

4. where the information is public as permitted by law;

5. where it is reasonable for the purposes of investigating a breach of an agreement, or actual or suspected illegal activity; or

6. where it is necessary for the purpose of a prospective business transaction as permitted by PIPEDA.

Where required or permitted by applicable privacy law to disclose information without consent, CAV will not disclose more information than is required.

9. How can Customers access or correct any inaccuracies in their Personal Information?

CAV endeavors to ensure that any Personal Information in its control is as accurate, current and as complete as necessary for the purposes for which CAV uses that information. If a Customer advises CAV that Personal Information is inaccurate, incomplete or out of date, CAV will revise the Personal Information and, if necessary, use its best efforts to inform third-party service providers or contractors so that those third parties may also correct their records.

CAV permits the reasonable right of access and review of Personal Information held by CAV and will endeavour to provide the information within a reasonable time, generally no later than 30 days following the request. CAV requires sufficient information to confirm that the individual making the request is authorized to do so. CAV will not charge Customers for verifying or correcting their information, however, to the extent permitted by applicable law, there may be a minimal charge imposed if you need a copy of records.

CAV keeps Customers’ Personal Information only as long as it is required for legal or business purposes. The length of time CAV retains information varies, depending on the purpose for which it was collected, the nature of the information and applicable data retention requirements. When Customers’ Personal Information is no longer required for CAV’s purposes, CAV has procedures to destroy, delete, erase, or convert it into an anonymous form.

10. How does CAV protect Customers’ Personal Information?

CAV endeavours to maintain appropriate physical, procedural, and technical security with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. CAV restricts access to Personal Information to those employees that require access for provision of the Service.

If any officer, employee, or volunteer of CAV misuses Personal Information, this will be considered a serious offence for which disciplinary action may be taken, up to and including termination of employment/volunteer contract. If any third-party individual or organization misuses Personal Information obtained solely for the purpose of providing services to CAV, this will be considered a serious issue for which action may be taken, up to and including termination of any agreement between CAV and that individual or organization.

Given the use of Interpreters outside Canada, as identified above, the privacy laws in the U.S. may offer different levels of protection from those in Canada, and the Personal Information may be subject to access by and disclosure to law enforcement agencies under the applicable legislation in the U.S. There is also the risk of hacking or other form of unintended intrusion.

A “breach of security safeguards” is defined as the loss of, unauthorized access to or unauthorized disclosure of Personal Information resulting from a breach of an organization’s security safeguards or from a failure to establish those safeguards. In case of a breach of security safeguards involving Personal Information under CAV’s control, CAV will comply with applicable privacy law, which may include notifying the applicable privacy commissioner and notifying the individual, if it is reasonable in the circumstances to believe that the breach creates a real risk of significant harm to the individual.

11. Links to other websites

CAV may provide links to, or automatically produce search results for, third-party websites or resources or third-party information referencing or linking to third-party websites or resources. CAV has no control over such third-party websites and resources, and Customers acknowledge and agree that CAV is not responsible for the content or information contained therein. When Customers follow such a link, they are no longer protected by our Privacy Policy, and CAV encourage all Customers to read the privacy statements or other disclaimers of such other parties. CAV is not responsible for the privacy or security practices or the content of non-CAV websites, services or products.

CAV cannot and does not guarantee, represent or warrant that the content or information contained in such third-party websites and resources is accurate, legal, non-infringing or inoffensive. CAV does not endorse the content or information of any third-party website or resource and, further, CAV does not warrant that such websites or resources will not contain viruses or other malicious code or will not otherwise affect your computer. By using any of CAV’s systems or websites to search for or link to a third-party website, Customers agree and understand that CAV shall not be responsible or liable, directly or indirectly, for any damages or losses caused or alleged to be caused by or in connection with their use of, or reliance on, CAV to obtain search results or to link to a third-party website.

12. Resolving Customer privacy concerns

In the event of questions or complaints about CAV’s privacy practices or questions on how a Customer can access their Personal Information, contact CAV’s Privacy Officer by sending an e-mail to Sue Decker at [email protected]

13. Changes to this Privacy Policy

CAV will update this Policy from time to time if our practices change or if the law requires changes. CAV will update the Effective Date of this Policy to reflect changes and post any changes on our website and, if the changes are significant, CAV will provide a more prominent notice and a summary of the relevant changes at the top of the page. Customers should review this Policy regularly for changes. If Customers do not agree to the terms of this Policy or any other CAV policy, agreement, or disclaimer, they should exit the site and cease use of all CAV services immediately.

Customers’ continued use following the posting of any changes to this Policy means they agree to be bound by the terms of this Policy.

Effective Date: This Policy was last updated on March 10, 2020 and will be effective as of the date of the opening of online registration for the VRS service.

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Sue Decker

CEO and Executive Director, Canadian Administrator of VRS (CAV), Inc.

Sue is responsible for leading the development, implementation and administration of Canada’s inaugural video relay service, SRV Canada VRS. In the Spring of 2015, Sue assumed the leadership of the CRTCs vision to build a video relay service for Deaf Canadians, transforming a start-up organization to a fully operationalized telecommunications relay service which launched in the Fall of 2016.  Prior to becoming CAV’s Executive Director, Sue managed AT&T’s Accessible Communications Services business which included Text and VRS Relay Services. In her 20 years of service with AT&T she developed extensive experience in product development and providing telecommunications services for people who are Deaf and Hard of Hearing. Post AT&T, she served as a consultant to other VRS companies located throughout U.S. and Europe, making her one of the foremost VRS experts in the world.

J. Scott Fletcher

Board Secretary​

Scott Fletcher is a senior partner in Gowling WLG’s Ottawa office, practicing in general corporate and commercial law with significant emphasis on telecommunications, technology, energy and government relations.

He is one of the firm’s authorities in providing corporate and commercial advice relating to commercial alliances, strategic and policy Board advice and privatizations, as well as in general corporate and commercial matters. Scott also provides advice on a number of regulatory matters in the telecommunications, energy and gaming/lotteries industries. In addition, he routinely provides strategic counsel to corporate clients on telecommunications industry-based matters, the divestiture of government departments and programs into the private sector, and other corporate and commercial issues.

Scott is the firm client team leader for several major firm clients in the telecommunications and energy sectors. He has served as a director of a number of federal Canadian corporations and has represented numerous federal Crown corporations.  Scott also serves as an executive team member for a number of firm clients.

Tony D’Onofrio, CFA, ICD.D

Interim Board Chair

Tony is an independent board member of CAV.  He gained extensive advisory and capital markets experience over a 20-year career in finance and investment banking. He has been working with the Canadian Coalition for Good Governance (CCGG) since 2010.  He is responsible for leading CCGG’s board engagement efforts and he regularly meets with the directors of leading public companies to discuss governance matters on behalf of Canada’s largest institutional investors.  He has been a frequent guest speaker and advises independently on governance matters and shareholder engagement.  Tony holds a Masters in Business Administration (Schulich School) and the Chartered Financial Analyst designation. He is a member of the Institute of Corporate Directors and a faculty member of The Directors College.

Renu Sangha, CPA, CGA

DHH ASL/LSQ Director

Renu is a DHH Director of CAV. She has 10 years of experience in accounting, finance, information technology, and change management. Renu has been working as a Business Analyst at HSBC Bank Canada since 2014. She is responsible for gathering, analyzing, and documenting business needs and requirements as well as liaising between business and technical stakeholders to ensure final solutions meet business objectives and add to the bottom line. Renu holds Bachelor degrees in Information Technology and Business Administration and the Chartered Professional Accountant designation. She is also AgileBA Foundation certified and a certified Scrum Product Owner.

Dr. Marty Taylor

Invitee

Marty Taylor is an interpreter educator and a nationally certified interpreter in Canada and the US. Dr. Taylor has been involved in video relay interpreting research for over ten years and has been a CAV Board Member since its inception. Marty has written two seminal books in the interpreting field: Interpretation Skills: English to American Sign Language and Interpretation Skill: American Sign Language to English which are used in over 100 interpreter education programs. Her current projects involve research on interpreting in educational settings, spoken language skills of native-English speakers, creating and supporting distance education, and developing materials to enhance interpreter skills development.

Jonathan Daniels

TSP Director

Jonathan Daniels, B.A. (McGill) 1990, J.D. (Toronto) 1994, is Vice President Regulatory Law at Bell. He has worked with Bell in various capacities since 2004. His primary focus is on major telecommunications regulatory policy issues. Previously he served as VP Regulatory for Cable & Wireless Caribbean, VP of Regulatory and Carrier Relations for C1 Communications in Toronto, Director of Regulatory for Covad Communications and Director of Regulatory Affairs for Sprint Canada. After law school, Mr. Daniels articled and was an associate with the law firm Stikeman, Elliott. In his various roles, Mr. Daniels has appeared before Committees of the House of Commons, the Senate, the CRTC and numerous regulators in the Caribbean. Mr. Daniels taught telecommunications law at the University of Toronto Faculty of Law and telecommunications market dynamics at Ryerson University.

Dr. Jessica Dunkley

DHH ASL Director​

Dr. Dunkley is the American Sign Language (ASL) Board Member of CAV. She is a family physician and resident physician in dermatology at the University of BC with a 16-year career in healthcare, including clinical medicine, health program evaluations and delivering professional development workshops. She is involved in clinical research in dermatology, having presented at numerous conferences in North America. She is a frequent speaker for various conferences related to accessibility and health care and provides mentorship to aspiring deaf and hard of hearing health professionals. Dr. Dunkley holds a Bachelor of Physical Therapy & Masters of Clinical Epidemiology from UBC and a Doctorate of Medicine from University of Ottawa.

Dr. Gary Birch

Independent Director

Gary Birch was appointed Director of Research and Development at the Neil Squire Society in 1988 and then in 1994 was appointed Executive Director. Dr. Birch earned his B.A. Sc. in Electrical Engineering in 1983, and in 1988 received a Doctorate in Electrical Engineering (Biomedical Signal Processing), both from the University of British Columbia. His specific areas of expertise are assistive technologies, direct brain-computer interface, digital signal processing, human-machine interface systems and service delivery programs for persons with disabilities.

 

In 2008 Dr. Birch was appointed an Officer of the Order of Canada, Canada’s highest civilian honor for lifetime achievement, for his work with the Neil Squire Society. In 2012 he was awarded the Queen Elizabeth Diamond Jubilee Medal, and in 2017 he was appointed to the Order of British Columbia, the Province’s highest form of recognition.

Eric Edora

TSP Director

Since January 2008, Eric has been employed at TELUS Communications Inc. as Director, Regulatory Affairs. Eric leads a team of Regulatory Senior Advisors to develop TELUS’ policy positions on major regulatory issues and to deliver comprehensive sound regulatory advice and advocacy. This role includes responsibility over TELUS’ positions about accessibility of wireline and wireless telecommunications services and compliance with applicable regulatory rules. He has appeared before the Canadian Radio-television and Telecommunications Commission (CRTC) for the 2008 Accessibility Policy proceeding and the 2014 proceeding to examine the feasibility of implementation of video relay services.

 

Previous to his current position, Eric was an advisor in TELUS’ Corporate Strategy department. Prior to that position, Eric was a Senior Policy Advisor in the Corporate Policy and Government Relations department at the Insurance Corporation of British Columbia.

 

Eric is a Barrister and Solicitor and has been a member of the British Columbia Law Society since August 1996. Eric attended the University of British Columbia’s Faculty of Law and obtained a Bachelor of Laws degree in 1995. He also obtained a Master’s in Business Administration degree from Simon Fraser University.

David Joseph

LSQ Director​

David currently works as a Financial Analyst at Health Canada. With his 11 years tenure in the Federal Government, he has acquired experiences in various divisions such as accounting operations, financial system, financial policy and corporate accounting. His goal is to continue acquiring more experience so he can get a promotion and manage a team. He is an analytical and critical thinking person that loves to be involved in various non-profit organizations. In addition to CAV, he is the Treasurer for the Canadian Deaf Sports Association (CDSA). David is fluent in 4 languages: LSQ, ASL, French and English. His first languages are LSQ and French. He also teaches American Sign Language (ASL) at Carleton University for the past 10 years.

Anne Missud

Permanent Invitee

Anne Missud is a permanent invitee, representing the French-LSQ interpreters at the CAV board. She acquired long standing and wide interpreting experience over a 20-year career in various public and private settings. She is actively involved in the training of interpreters as a teacher at the University of Quebec in Montreal. She is currently completing her Ph.D./Psy. D in community psychology, her research focuses on the wellbeing of the deaf community. She is a certified member of the Ordre des traducteurs, terminologues et interprètes agréés du Québec.

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