Purpose and Scope
Winnipeg Airport Services Corp. (“WASCO”, “we”, “us” and “our”) respects and upholds an individual’s right to privacy and to protection of his or her personal information. WASCO is committed to ensuring compliance with applicable privacy legislation.
This policy describes our practices with respect to the collection, use storage and disclosure of personal information which we collect from individuals who are customers of WASCO. It does not apply to information collected, used, or disclosed with respect to corporate or commercial entities.
“Personal information” for the purposes of this policy means information about an identifiable individual, including, for example, an individual’s name, home address, telephone number, social insurance number, sex, income and family status, or personal opinions gathered for survey purposes. It does not include aggregate information which cannot be associated with a specific individual. Nor does it include information that would enable an individual to be contacted at a place of business, for example, an employee’s name, title, business address or business telephone number.
“Customer” for the purposes of this policy is any individual who uses or applies to use WASCO’s products, services, or facilities, including the website.
“Third party” for the purposes of this policy is an individual or an organization other than WASCO and the customer.
WASCO is accountable for the personal information under its control. WASCO has appointed a Privacy Officer who is responsible for the corporation’s compliance with this Policy.
Purposes for Collection, Use and Disclosure
WASCO collects and uses personal information you have provided. This information is collected and used for the following purposes:
- To develop, enhance, or provide products and services
For example, we may collect your address information to send you promotional coupons to enjoy products or services at airports we manage.
- To process payment for the use of our products, services and facilities
For example, we collect and use financial information to process payment for your use of managed facilities.
- To comply with legal and regulatory requirements
For example, we may collect and use personal information in response to a court order or to fulfill government reporting requirements.
- To enhance safety and security
For example, we may use cameras to monitor access, egress and use of public and restricted areas at managed facilities.
- To improve the products, services and facilities we provide
For example, we administer customer satisfaction surveys at airports managed by WASCO. WASCO is dedicated to providing superior customer service and we may use information voluntarily provided on customer satisfaction surveys in order to improve products, services and facilities at those managed facilities.
- To understand and respond to questions
For example, where inquiries are e-mailed to us through the “contact us” page on our web site, www.wasco.ca, we collect and use information you provide to us for the purpose of understanding your inquiry and responding to it.
- For identification purposes
For example, we may require personal information such as a photograph to issue passes which enable individuals to be identified in restricted areas and to obtain access to those areas.
- For direct marketing purposes
For example, we may use your contact information to provide you with information about new products, services and facilities at the facilities we manage.
- To enhance your online experience
For example, we may use per-session cookies, which are data files sent to your browser and stored on your hard-drive when you visit our website. These per-session cookies track your usage on our website and can be deleted by clearing your browser history. We may also use log files, which record the IP address of your computer, to track the number of hits to our website.
The only circumstance under which personal information may be disclosed to third parties is for the fulfillment of any purposes identified above, as required by law, or with customer’s consent. Where personal information is disclosed to a third party for the fulfillment of any purposes identified above, WASCO will make reasonable efforts to ensure the third party has appropriate security procedures in place for the protection of the personal information transferred to it.
When you provide us with your personal information, you consent to the use of your personal information as identified in this policy, and as may be further identified at the time of collection. Sometimes you will be asked to give your express consent, such as by checking a box to indicate your consent to receive marketing, or other communications. Other times, we may obtain your consent implicitly when we can reasonably conclude you have given consent by some action you have taken or an action you have decided not to take. Generally this occurs where the purpose for use of your personal information would be reasonably apparent to you.
Unless we hear otherwise from you, your use of WASCO’s products, services and facilities constitutes implicit consent for WASCO to collect, use and disclose personal information for the purposes stated in this policy.
You may refuse or withdraw your consent at any time, subject to legal and contractual restrictions, technological limitations and reasonable notice. Refusal or withdrawal of consent may prevent WASCO from providing to you a product, service or access to certain WASCO facilities.
You may refuse or withdraw your consent by contacting us at CPO@wasco.ca. Our staff will explain your options and any consequences of refusing or withdrawing consent, and will record your choices.
We collect personal information only for the purposes identified above.
Limiting Use, Disclosure and Retention
We do not use or disclose personal information for any purpose other than those for which it was collected, except as required by law, or with consent.
Personal information is retained only as long as is necessary for the fulfillment of the purposes for which it was collected, or as required by law.
WASCO will make all reasonable efforts to ensure personal information is as accurate, complete, and current as required for the purposes for which it was collected. In some cases, WASCO relies on individuals to ensure certain information about them, such as their home address and contact information, is current, complete and accurate.
Storage and Safeguards
WASCO will make all reasonable efforts to ensure personal information is protected against such risks as loss, theft, unauthorized access, disclosure, copying, use, modification or destruction. Safeguards include physical, administrative and electronic security measures.
WASCO may process and store your information in Canada or elsewhere, and therefore governments, courts or law enforcement or regulatory agencies may be able to obtain disclosure of your information through the laws of that country. By consenting to the information practices set out in this policy, you specifically consent to your information being processed and stored in Canada, the United States or elsewhere.
We may use third party service providers (for example, web hosting providers and/or payment processers) to manage one or more aspects of our business operations, including the processing or handling of personal information. When we do use an outside company, we use contractual or other appropriate means to ensure your personal information is used in a manner consistent with this policy. Some of these operations may result in personal information collected by us being stored or processed in Canada or elsewhere and, as a result, your personal information may be accessible to law enforcement and regulatory authorities in accordance with Canadian laws, United States laws, and/or the laws of other foreign jurisdictions.
Openness Concerning Policies and Practices
WASCO will make available specific information about its policies and practices regarding the management of personal information. To contact us to obtain further information regarding our policies and practices, please refer to the “Access” section below.
Customers have the right to access their personal information under the control of WASCO. Access requests should be made, in writing, to Privacy Officer at 201 – 2000 Wellington Avenue, Winnipeg MB R3H 1C2 or by email at CPO@wasco.ca. The Privacy Officer will assist customers with their access requests. This includes:
- Identification of personal information under our custody or control
- Information about how personal information under our control may be or has been used by us, and
- The names of any individuals and organizations to which the individual’s personal information has been disclosed.
In certain exceptional situations WASCO may not be able to provide access to certain personal information it holds about an individual. Examples of where WASCO may not provide access include, but are not limited to, the following:
- Where provision may reveal personal information about another individual;
- Where provision would reveal confidential commercial information;
- Where the information is subject to solicitor-client privilege; or
- Where the information was collected in relation to an investigation of a breach of an agreement or a contravention of a federal or provincial law.
If access cannot be provided, WASCO will notify the individual making the request, in writing, of the reasons for the refusal.
Where access has been provided and where the information is demonstrated to be inaccurate or incomplete, WASCO will amend the information as required. Where appropriate, WASCO will transmit the amended information to third parties having access to the information in question.
Questions or Concerns Regarding WASCO’s Compliance
Individuals may direct their general questions regarding privacy practices at WASCO, as well as any questions or concerns regarding WASCO’s compliance with this policy, to Privacy Officer, 201 – 2000 Wellington Avenue, Winnipeg MB R3H 1C2, by email at CPO@wasco.ca or by calling 1-204-987-9400 or toll free at 1-855-500-6589.
The Privacy Officer will investigate any complaints received in writing. If a complaint is found to be justified, the Privacy Officer will take appropriate measures to resolve the complaint including, if necessary, amending WASCO’s policies and procedures. A customer will be informed, in writing, of the outcome of the investigation regarding his or her complaint.
Each year, the Privacy Officer will report to the WASCO’s Board of Directors on the number, nature and disposition of complaints received in the previous year.
For general questions regarding privacy regulations, or to obtain a copy of the Personal Information Protection and Electronic Documents Act, contact the Office of the Privacy Commissioner of Canada at 112 Kent St., Ottawa ON K1A 1H3, or visit the Office of the Privacy Commissions of Canada’s website at www.privcom.gc.ca.
Last modified February 2017