Objective and Scope
For the purposes of this Policy, “personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred or determined from the information. This Policy does not cover any information, recorded in any form, about more than one individual when the identity of the individuals is unknown and cannot be inferred from the information (aggregated information). DEI retains the right to use aggregated information in any way we deem appropriate.
Using contractual or other arrangements, DEI shall ensure that agents, contractors or third-party service providers who may receive personal information while providing services to us will protect that information according to the principles articulated in this Policy.
DEI will keep all information concerning the business and affairs of a person or organization acquired (either to determine whether we will begin a professional relationship or during such a relationship) in strict confidence and only reveal information unless expressly or implicitly authorized by the person or organization concerned. A professional relationship develops when DEI agrees to be retained to provide services to an individual or organization. To protect your own interests, do not send confidential information to DEI until you have had a direct discussion with a professional at our firm about retaining DEI to provide professional services.
Collection, Use and Disclosure of Personal Information
DEI only collects personal information from individuals or organizations when required for the purposes of providing services or information. DEI collects email and mailing addresses when individuals subscribe to one of our publications and agree to receive information that may be of possible interest.
DEI does not sell, trade, barter or exchange for consideration any personal information we have obtained. Unless permitted by law, no personal information is collected about an individual without first obtaining that person’s consent to us collecting, using and disseminating that information.
Personal information will be collected, to the extent possible, directly from the individual concerned. DEI does not knowingly collect personal information from anyone under the age of 18, especially children under 13, and we do not use such information if we discover that it is has been provided by a minor.
DEI may disclose personal information to organizations that perform services on our behalf, but only if they agree to use such information solely to provide services to DEI under our instruction in a manner consistent with the relevant principles of this Policy.
Personal information may also be transferred to another organization if all or part of DEI merges or changes ownership, and only if the parties have agreed to collecting, using and disclosing the information only for purposes relating to the business transaction.
There are circumstances in which using and/or disclosing personal information may be justified or permitted or where DEI is obliged to disclose information without consent, in instances where:
- Required by law or by order or requirement of a court, administrative agency or another governmental tribunal;
- DEI believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
- It is necessary to establish or collect monies owning to DEI;
- It is necessary to permit DEI to pursue available remedies or limit any damages that DEI may sustain; or
- The information is public.
When obliged or permitted to disclose information without consent, DEI will only disclose required information.
DEI endeavours to ensure that any personal information provided is as accurate, current and complete as necessary for the purposes for which DEI uses it.
DEI keeps personal information only as required for the reasons it was collected. The length of time varies, depending on the product or service being provided and the nature of the information. The retention period may extend beyond the end of a person's relationship with us, but only as long as necessary to respond to issues that may arise at a later date. When your personal information is no longer required by DEI, we follow disciplined procedures to destroy, delete, erase or convert it into an anonymous form.
DEI endeavours to maintain adequate physical, procedural and technical security with respect to its offices and information storage facilities to prevent loss, misuse, unauthorized access, disclosure, or modification of personal information. DEI also restricts access to those employees whom our management has determined need to have the information to provide our services.
When communicating personal information to DEI, remember that no method of transmitting or storing data is completely secure. Mail, telephone calls, faxes, scans and emails all leave your information susceptible to possible loss, misrouting, interception and misuse during transmission.
Like many organizations, DEI attempts to strike a reasonable balance between security and convenience. We often request the right to communicate in a way that is less secure than some less-convenient alternatives. For example, when we use email, it may be sent as unencrypted plain text because many of our clients and others cannot readily process encrypted email. We email for their convenience despite the security concern that, if misrouted or intercepted, the message could be read more easily than encrypted email.
DEI provides clients and others with general access to public websites and restricted access to extranets. Our web servers track general information about visitors such as their domain names and times of visit. DEI's web servers also collect and aggregate information regarding which pages are being accessed as well as information volunteered by visitors through online surveys or subscriptions to electronic newsletters. We use this information internally, only in aggregate form, to help us to diagnose technical problems and improve the content of our website to serve visitors better.
DEI Practices and This Policy