Privacy Policy

Your privacy is important to Phoenix Strategic Perspectives Inc. (Phoenix SPI). We take this matter very seriously, and are committed to respecting the privacy of research participants and the general public. Any time you participate in research conducted by Phoenix SPI, you can be confident that your personal information will be secure with us.

All of our research is conducted in accordance with applicable privacy law and the professional standards that apply to our work, including standards established by the Canadian Research Insights Council (CRIC). The following outlines the ten fair information principles reflected in the Personal Information Protection and Electronic Documents Act (PIPEDA) and how Phoenix SPI applies them.

1. Accountability

• All privacy concerns and inquiries can be directed to the Privacy Officer, a senior member of the Phoenix SPI team who is accountable for the organization’s privacy practices and for responding to privacy-related questions, requests and complaints. Privacy-related inquiries may be directed in writing to:

  Privacy Officer
  PO Box 82022 RPO Riverside South
  Ottawa, ON K1V 2N9
  Canada
  Email: privacy@phoenixspi.ca

• Consistent with industry codes of practice, Phoenix SPI maintains policies and procedures designed to protect personal information and communicates relevant requirements to employees.
• Where subcontractors or third parties handle personal information on Phoenix SPI’s behalf, Phoenix SPI uses contractual or other appropriate measures to require protection consistent with applicable privacy and security requirements.

2. Identifying Purposes for Collection of Personal Information

Before or at the time personal information is collected, research participants are informed, as appropriate to the methodology, about the purposes for which the information is being collected and used. This may include:

• that their information is being collected as part of survey, market, public opinion or social research activities;
• the research purposes for which their information will be used;
• how confidentiality and anonymity or de-identification will be protected; and
• whether and in what form research findings or data may be provided to the client or other authorized parties.

3. Consent

• Participation in Phoenix SPI research is voluntary. Consent is obtained in a manner appropriate to the research activity and the nature and sensitivity of the information.
• Phoenix SPI does not normally disclose information that identifies an individual research participant to a client or third party. Where identifiable information is to be disclosed, Phoenix SPI will obtain the participant’s consent unless the disclosure is otherwise authorized or required by law and will explain the purpose of the disclosure.

4. Limiting Collection of Personal Information

Phoenix SPI limits the amount and type of personal information collected to what is reasonably necessary for the identified research purposes. Standard demographic information may be collected where relevant to those purposes.

5. Limiting Use, Disclosure and Retention

• Phoenix SPI uses and discloses personal information only for the purpose(s) for which it is collected, unless the individual consents to another use or disclosure or the use or disclosure is authorized or required by law.
• Phoenix SPI retains personal information only as long as necessary to fulfil the identified research, contractual, legal, security and quality-assurance purposes.
• Completed paper questionnaires are retained only as long as necessary to complete data entry, verification, data cleaning and quality assurance, and to resolve any discrepancies. Once these activities are complete and the electronic research data have been verified, the paper questionnaires are securely destroyed, unless a longer retention period is required by the client, contract, applicable research standard or law.
• Electronic research records containing personal information, as well as notes and audio or video recordings of focus groups or interviews, are retained only as long as necessary for the purposes for which they were collected and in accordance with applicable contractual, legal, security or research-standard requirements.
• Where no other retention requirement applies, records containing personal information are retained for no more than 24 months. Records may be destroyed earlier once they are no longer required for an identified purpose.
• De-identified or anonymized research data and technical records may be retained for longer periods where required for research integrity, replication, contractual obligations or applicable research standards, provided they no longer identify individual participants.
• Paper records are securely shredded. Electronic records are securely deleted or otherwise rendered inaccessible when their retention period ends.

6. Accuracy of Personal Information

• Phoenix SPI takes reasonable steps to ensure that the personal information used for an identified purpose is as accurate, complete and up to date as necessary for that purpose.
• Phoenix SPI will address requests to correct personal information in its custody or control where appropriate. Where information originated from a third-party source, Phoenix SPI may refer the correction to, or notify, that source as appropriate.

7. Safeguards

• Phoenix SPI protects personal information against unauthorized access, disclosure, copying, use, loss or modification using administrative, technical and physical safeguards appropriate to the sensitivity of the information.
• Access to personal information is limited to authorized personnel who require it for their work.
• Before respondent-level research data are provided to clients, Phoenix SPI removes direct personal identifiers such as names, residential addresses, telephone numbers and email addresses unless disclosure of identifiable information has been specifically consented to or is otherwise authorized or required.
• Phoenix SPI requires third parties that handle personal information on its behalf to protect the information and limit its use to the authorized purpose(s).
• Phoenix SPI personnel obtain Government of Canada security clearances where required for the work they perform.
• Phoenix SPI maintains procedures for responding to privacy and security incidents, including assessment, containment, documentation and notification where required by applicable law, contract or policy.

8. Openness

Phoenix SPI makes information about its privacy practices available through this policy and through its Privacy Officer. Individuals may contact the Privacy Officer with questions about Phoenix SPI’s management of personal information.

9. Individual Access to Personal Information

• Phoenix SPI handles all requests for access to personal information in its custody or control on a case-by-case basis through its Privacy Officer, subject to applicable legal exceptions.
• Before providing access to personal information or acting on instructions concerning it, Phoenix SPI may take reasonable steps to verify the identity and authority of the requester.
• Phoenix SPI will respond to reasonable inquiries from research participants about how their contact information was obtained. Where appropriate, Phoenix SPI will remove an individual from Phoenix SPI-maintained contact lists and may ask a supplier to record an applicable do-not-contact request.
• In some circumstances, Phoenix SPI may be unable to provide particular information, including where disclosure would reveal confidential information about another party or create a risk of identifying another individual.

10. Challenging Compliance

Phoenix SPI investigates complaints and concerns regarding compliance with its privacy policy and, where appropriate, seeks external advice. Questions, access or correction requests, and complaints concerning Phoenix SPI’s handling of personal information should be directed to the Privacy Officer at privacy@phoenixspi.ca.