Privacy Policy

Bridgestone Firestone Canada Inc.
Code of Fair Information Practices BFCA Code of Fair Information Practices complies fully with the Personal Information Protection and Electronic Documents Act and incorporates the ten principles of The Canadian Standards Association (CSA) Model Code for the Protection Personal Information (CAN/CSA-Q830-96) which was published in March 1996 as a National Standard of Canada.

Introduction
Bridgestone Firestone Canada Inc. (“BFCA”) is engaged in the business of the manufacture and distribution of tires, textiles and automotive services.

BFCA is committed to maintaining the accuracy, confidentiality, security and privacy of dealer, customer and employee personal information. This is reflected in existing privacy and confidentiality provisions found in various BFCA policies. It is also reflected in the high regard and trust with which dealers, customers and employees view the management of personal information by BFCA.

In March 1996, the new Canadian Standards Association Model Code for the Protection of Personal Information, CAN/CSA-Q830-96 (the "CSA Code"), was published as a National Standard of Canada. BFCA has adopted BFCA Code of Fair Information Practices, to describe in detail how we subscribe to the principles of the CSA Code and the requirements of the Personal Information Protection and Electronic Documents Act.

BFCA Code of Fair Information Practices (the "BFCA Privacy Code") is a formal statement of principles and guidelines concerning the minimum requirements for the protection of personal information provided by BFCA to our dealers, customers and employees. The objective of the BFCA Privacy Code is responsible and transparent practices in the management of personal information, in accordance with the National Standard and federal legislation.

BFCA will continue to review the BFCA Privacy Code at least every five years to make sure it is relevant and remains current with changing technologies and laws and the evolving needs of BFCA, our dealers, customers and employees.

SUMMARY OF PRINCIPLES 
Principle 1 - Accountability
BFCA is responsible for personal information under its control and shall designate one or more persons who are accountable for compliance with the following principles.

Principle 2- Identifying Purposes for Collection of Personal Information
BFCA shall identify the purposes for which personal information is collected at or before the time the information is collected.

Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information
The knowledge and consent of a dealer, customer or employee are required for the collection, use or disclosure of personal information, except where inappropriate.

Principle 4- Limiting Collection of Personal Information
BFCA shall limit the collection of personal information to that which is necessary for the purposes identified. BFCA shall collect personal information by fair and lawful means.

Principle 5- Limiting Use, Disclosure and Retention of Personal Information
BFCA shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. BFCA shall retain personal information only as long as necessary for the fulfillment of those purposes. 

Principle 6- Accuracy of Personal Information
Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.

Principle 7- Security Safeguards
BFCA shall protect personal information by security safeguards appropriate to the sensitivity of the information. 

Principle 8- Openness Concerning Policies and Practices
BFCA shall make readily available to dealers, customers and employees specific information about its policies and practices relating to the management of personal information. 

Principle 9- Dealer, Customer and Employee Access to Personal Information
BFCA shall inform a dealer, customer or employee of the existence, use and disclosure of his or her personal information upon request and shall give the individual access to that information. A dealer, customer or employee shall be able to challenge the accuracy and completeness of the information and to have it amended as appropriate.

Principle 10- Challenging Compliance
A dealer, customer or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for BFCA's compliance with the Code.

SCOPE AND APPLICATION 
The 10 principles that form the basis of the BFCA Privacy Code are interrelated and BFCA shall adhere to the 10 principles as a whole. Each principle must be read in conjunction with the accompanying commentary. As permitted by the CSA Code, the commentary in the BFCA Privacy Code has been tailored to reflect personal information issues specific to BFCA. The scope and application of the BFCA Privacy Code are as follows:

• The BFCA Privacy Code applies to personal information about dealers, customers and employees of BFCA that is collected, used or disclosed by it.

• The BFCA Privacy Code applies to the management of personal information in any form whether oral, electronic or written.

• The BFCA Privacy Code does not impose any limits on the collection, use or disclosure of the name, title or business address or telephone number of an employee of an organization by BFCA 

• The application of the BFCA Privacy Code is subject to the requirements or provisions of any applicable legislation, regulations, tariffs or agreements (such as collective agreements), or the order of any court or other lawful authority. 

Definitions
BFCA - Bridgestone / Firestone Canada Inc.

Collection - the act of gathering, acquiring, recording or obtaining personal information from any source, including third parties, by any means. 

Consent - voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. Express consent can be given orally, electronically or in writing but is always unequivocal and does not require any inference on the part of BFCA. Implied consent is consent that can reasonably be inferred from an individual's action or inaction. 

Customer - an individual who (a)uses, or applies to use, the products or services of BFCA (b)corresponds with BFCA; or (c)participation in a promotional marketing program or enters a contest sponsored by BFCA. 

Dealer – an individual who is an authorized dealer of BFCA and who purchases BFCA product for retail or resale and/or is licensed to use one or more trademarks owned by or licensed to BFCA in connection with providing automotive services. 

Disclosure - making personal information available to a third party.

Employee - an employee or pensioner of BFCA.

Personal information - information about an identifiable individual but not aggregated information that cannot be associated with a specific individual. For a dealer or customer, such information includes a customer's credit information, billing records, personal address and telephone number, VIN number and other particular information regarding vehicles owned or leased by the individual and any recorded complaints. For an employee, such information includes information found in personnel employment files, performance appraisals and medical and benefits information. 

Third party - an individual other than the customer or his agent or an organization other than BFCA. 

Use - the treatment, handling, and management of personal information by BFCA.

BFCA CODE IN DETAIL (PART 1) 
Principle 1 - Accountability
BFCA is responsible for personal information under its control and shall designate one or more persons who are accountable for the company's compliance with the following principles. 

(a) Responsibility for ensuring compliance with the provisions of the BFCA Privacy Code rests with the senior management of BFCA, which shall designate one or more persons to be accountable for compliance with the BFCA Privacy Code. Other individuals within BFCA may be delegated to act on behalf of the designated person(s) or to take responsibility for the day-to-day collection and processing of personal information.

(b) BFCA shall make known, upon request, the title of the person or persons designated to oversee the company's compliance with the BFCA Privacy Code.

BFCA has designated a BFCA Privacy Officer to oversee compliance with the BFCA Privacy Code. BFCA Privacy Officer can be contacted at:

BFCA Privacy Officer 
5770 Hurontario Street, Suite 400 
Mississauga, Ontario 
L5R 3G5 
BFCAprivacyofficer@bfusa.com

(c) BFCA is responsible for personal information in its possession or control, including information that has been transferred to a third party for processing. BFCA shall use appropriate means to provide a comparable level of protection while information is being processed by a third party (see Principle 7). 

(d) BFCA has implemented policies and procedures to give effect to the BFCA Privacy Code, including: 

A. implementing procedures to protect personal information and to oversee the company's compliance with the BFCA Privacy Code; 
B. establishing procedures to receive and respond to inquiries or complaints;
C. training and communicating to staff about BFCA’s policies and practices; and
D. developing public information to explain BFCA’s policies and practices.

Principle 2 - Identifying Purposes for Collection of Personal Information
BFCA shall identify the purposes for which personal information is collected at or before the time the information is collected. 

(a) BFCA collects personal information only for the following purposes: A. To establish and maintain responsible commercial relations with dealers and customers and to provide ongoing service; 
B. In connection with fulfilling its obligations to perform adjustments and other warranty work pursuant to BFCA’s published limited warranties;
C. To understand customer needs; 
D. To develop, enhance, market or provide products and services; 
E. To manage and develop its business and operations, including personnel and employment matters; and 
F. To meet legal and regulatory requirements. 
Further references to "identified purposes" mean the purposes identified in this Principle 2.

(b) BFCA shall specify orally, electronically or in writing the identified purposes to the dealer, customer or employee at or before the time personal information is collected. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within BFCA who shall explain the purposes. 

(c) Unless required by law, BFCA shall not use or disclose, for any new purpose, personal information that has been collected without first identifying and documenting the new purpose and obtaining the consent of the dealer, customer or employee.

Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information 
The knowledge and consent of a dealer, customer or employee are required for the collection, use or disclosure of personal information, except where inappropriate. 

(a) In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual. For example, BFCA may collect or use personal information without knowledge or consent if it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is a minor, seriously ill or mentally incapacitated.

BFCA may also collect, use or disclose personal information without knowledge or consent if seeking the consent of the individual might defeat the purpose of collecting the information such as in the investigation of a breach of an agreement or a contravention of a federal or provincial law. 

BFCA may also use or disclose personal information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened.

BFCA may disclose personal information without knowledge or consent to a lawyer representing the company, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required by law. 

(b) In obtaining consent, BFCA shall use reasonable efforts to ensure that a dealer, customer or employee is advised of the identified purposes for which personal information will be used or disclosed. Purposes shall be stated in a manner that can be reasonably understood by the dealer, customer or employee.

(c) Generally, BFCA shall seek consent to use and disclose personal information at the same time it collects the information. However, BFCA may seek consent to use and disclose personal information after it has been collected but before it is used or disclosed for a new purpose. 

(d) BFCA will require dealers and customers, as applicable, to consent to the collection, use or disclosure of personal information as a condition of the supply of a product or service only if such collection, use or disclosure is required to fulfill the identified purposes.

(e) In determining the appropriate form of consent, BFCA shall take into account the sensitivity of the personal information and the reasonable expectations of its dealers, customers and employees. 

(f) In general, the use of products and services by a dealer, customer, or the acceptance of employment or benefits by an employee, constitutes implied consent for BFCA to collect, use and disclose personal information for all identified purposes. 

(g) A dealer, customer or employee may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Dealers, customers and employees may contact BFCA for more information regarding the implications of withdrawing consent. 

Principle 4 - Limiting Collection of Personal Information
BFCA shall limit the collection of personal information to that which is necessary for the purposes identified by the company. 

BFCA shall collect personal information by fair and lawful means. (a) BFCA collects personal information primarily from its dealers, customers or employees. 

(b) BFCA may also collect personal information from other sources including credit bureaus, employers or personal references, or other third parties that represent that they have the right to disclose the information. 

BFCA CODE IN DETAIL (PART 2) 
Principle 5 - Limiting Use, Disclosure and Retention of Personal Information
BFCA shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law. BFCA shall retain personal information only as long as necessary for the fulfillment of the purposes for which it was collected. (a) In certain circumstances personal information can be collected, used or disclosed without the knowledge and consent of the individual. (See Principle 3.1)

(b) In addition, BFCA may disclose a dealer’s or customer's personal information to:
A. another person for the development, enhancement, marketing or provision of any of the products or services of BFCA; 
B. an agent retained by BFCA in connection with the collection of the customer's account;
C. credit grantors and reporting agencies; and
D. a third party or parties, where the dealer or customer consents to such disclosure or disclosure is required by law. 

(c) BFCA may disclose personal information about its employees: A. for normal personnel and benefits administration; B. in the context of providing references regarding current or former employees in response to requests from prospective employers; or C. where disclosure is required by law. 

(d) Only those employees of BFCA who require access for business reasons, or whose duties reasonably so require, are granted access to personal information about dealers, customers and employees. 

(e) BFCA shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about a dealer, customer or employee, BFCA shall retain, for a period of time that is reasonably sufficient to allow for access by the dealer, customer or employee, either the actual information or the rationale for making the decision. 

(f) BFCA shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous. 

Principle 6 - Accuracy of Personal Information
 
Personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. 

(a) Personal information used by BFCA shall be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a dealer, customer or employee. 

(b) BFCA shall update personal information about dealers, customers and employees as and when necessary to fulfill the identified purposes or upon notification by the individual.

Principle 7 - Security Safeguards
BFCA shall protect personal information by security safeguards appropriate to the sensitivity of the information. 

(a) BFCA shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. BFCA shall protect the information regardless of the format in which it is held. 

(b) BFCA shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used. 

(c) All employees of BFCA with access to personal information shall be required as a condition of employment to respect the confidentiality of personal information.

Principle 8 - Openness Concerning Policies and Practices 
BFCA shall make readily available to dealers, customers and employees specific information about its policies and practices relating to the management of personal information. 

(a) BFCA shall make information about its policies and practices easy to understand, including: A. The title and address of the person or persons accountable for the company's compliance with the BFCA Privacy Code and to whom inquiries or complaints can be forwarded;
B. The means of gaining access to personal information held by BFCA; and 
C. A description of the type of personal information held by BFCA, including a general account of its use.

(b) BFCA shall make available information to help dealers, customers and employees exercise choices regarding the use of their personal information and the privacy-enhancing services available from BFCA.


Principle 9 – Dealer, Customer and Employee Access to Personal Information
BFCA shall inform a dealer, customer or employee of the existence, use and disclosure of his or her personal information upon request and shall give the individual access to that information.

A dealer, customer or employee shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

(a) Upon request, BFCA shall afford to a dealer, customer or an employee a reasonable opportunity to review the personal information in the individual's file. Personal information shall be provided in understandable form within a reasonable time and at minimal or no cost to the individual.

(b) In certain situations, BFCA may not be able to provide access to all of the personal information that it holds about a dealer, customer or employee. For example, BFCA may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, BFCA may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law. If access to personal information cannot be provided, BFCA shall provide the reasons for denying access upon request.

(c) Upon request, BFCA shall provide an account of the use and disclosure of personal information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, BFCA shall provide a list of organizations to which it may have disclosed personal information about the individual when it is not possible to provide an actual list. 

(d) In order to safeguard personal information, a dealer, customer or employee may be required to provide sufficient identification information to permit BFCA to account for the existence, use and disclosure of personal information and to authorize access to the individual's file. Any such information shall be used only for this purpose. 

(e) BFCA shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual's file. Where appropriate, BFCA shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences. 

(f) A customer can obtain information or seek access to his or her individual file by contacting a designated representative at BFCA's business office. 

(g) An employee can obtain information or seek access to his or her individual file by contacting his or her immediate supervisor within BFCA. 

Principle 10 - Challenging Compliance
A dealer, customer or employee shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for the compliance of BFCA with the BFCA Privacy Code. 

(a) BFCA shall maintain procedures for addressing and responding to all inquiries or complaints from its dealers, customers and employees about the company's handling of personal information.

(b) BFCA shall inform their dealers, customers and employees about the existence of these procedures as well as the availability of complaint procedures.

(c) The person or persons accountable for compliance with the BFCA Privacy Code may seek external advice where appropriate before providing a final response to individual complaints. 

(d) BFCA shall investigate all complaints concerning compliance with the BFCA Privacy Code. If a complaint is found to be justified, BFCA shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A dealer, customer or employee shall be informed of the outcome of the investigation regarding his or her complaint.

For more information on BFCA's commitment to privacy, contact BFCA through our website: www.bridgestonetire.ca

For copies of the CSA Model Code for the Protection of Personal Information contact: 
Canadian Standards Association
178 Rexdale Blvd. Etobicoke, Ontario
M9W 1R3