Privacy Policy

Joseph T. Santoro Professional Corporation has a long standing policy of protecting the privacy of our clients in the course of providing services to them. Our relationship with our clients is based upon trust and maintaining client privacy is given the utmost priority.

The Joseph T. Santoro Professional Corporation Privacy Policy is a formal statement of principles and guidelines that we have adopted for the protection of Personal Information we may collect for or on behalf of our clients. Our objective in developing this privacy policy is to promote responsible practices in the management of Personal Information in accordance with the provisions of the Personal Information Protection and Electronic Documents Act (“PIPEDA”). This Privacy Policy is organized according to the principals of the Canadian Standard’s Associations Model Code, which forms the basis of that law.

Joseph T. Santoro Professional Corporation Privacy Policy
Joseph T. Santoro Professional Corporation recognizes the importance of privacy and the sensitivity of personal information. As a law firm we have a professional obligation to keep confidential all information we receive within a lawyer-client relationship. We are committed to protecting any personal information we hold. This Privacy Policy outlines how we manage your personal information and safeguard your privacy.

Your privacy rights
From January 1, 2004, all businesses engaged in commercial activities must comply with the Personal Information Protection and Electronic Documents Act (PIPEDA) and the Canadian Standards Association Model Code for the Protection of personal information which it incorporates. These obligations extend to lawyers and law firms, including Joseph T. Santoro Professional Corporation. The Act gives you rights concerning the privacy of your personal information.
Joseph T. Santoro Professional Corporation is responsible for the personal information we collect and hold. To ensure this accountability, we have developed this Privacy Policy, and have trained our support staff about our policies and practices.

Why does Joseph T. Santoro Professional Corporation need personal information?
Joseph T. Santoro Professional Corporation provides legal services and products to a wide range of clients. We require (some) personal information to represent you as a client and to create and maintain client lists.

What personal information do we collect?
Personal information is any information that identifies you, or by which your identity could be deduced. If we did not collect and use your personal information we could not provide you with legal services.
Personal information that we collect includes, but is not necessarily limited to, the following:

  • your name, home address, and home telephone and/or cell phone numbers
  • your e-mail address
  • your date of birth
  • financial institution
  • in some limited cases, driver’s license registration number and/or social insurance number
  • names of your immediate family members

How do we collect your personal information?
We collect information only by lawful and fair means and not in an unreasonably intrusive way. Wherever possible we collect your personal information directly from you at the start of a retainer and in the course of our representation.

Sometimes we may obtain information about you from other sources, for example:

  • your insurance company;
  • your real estate agent in a property transaction;
  • from a government agency or registry;
  • your employer, if we are acting for you, at its request;
  • your accountant;
  • other law firms

Consent
In most cases, we shall ask you to specifically consent, if we collect, use, or disclose your personal information. Normally, we ask for your consent in writing but in some circumstances, we may accept your oral consent. Sometimes, your consent may be implied through your conduct with us.

Disclosure of your personal information
Under certain circumstances, Joseph T. Santoro Professional Corporation will disclose your personal information:

  • when we are required or authorized by law to do so. For example, if a court issues a subpoena. In these instances we will only disclose such personal information as is required in these circumstances;
  • when you have consented to the disclosure;
  • when the legal services we are providing to you requires us to give your information to third parties (for example a lender in a real estate mortgage transaction) your consent will be implied, unless you tell us otherwise;
  • where it is necessary to establish or collect fees;
  • if we engage a third party to provide administrative services to us (such as computer back-up services or archival file storage) and the third party is bound by our privacy policy;
  • if we retain other professionals, agents or contractors such as accountants, title searchers, etc., to assist us in completing our work for you or to act on your behalf directly;
  • if the information is already publicly known.

Updating your information
Since we use your personal information to provide legal services to you, it is important that the information be accurate and up-to-date.
If during the course of the retainer, any of your information changes, please inform us so that we can make any necessary changes.

Is my personal information secure?
Joseph T. Santoro Professional Corporation takes all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect your information are:
If we use the services of any third parties to process or store personal information, we will enter into a legal agreement which requires them to protect this personal information in a manner acceptable to us. In entering into these legal agreements, we do not transfer any interest in this personal information to them. This is done to ensure that the personal information delivered to third parties is maintained at a level equivalent to that provided for under this privacy policy.

  • premises security;
  • employee training in the storage, safe guarding and use of personal information;
  • restricted file access to personal information;
  • deploying technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access;
  • internal password and security policies.

Access to your personal information
You may ask for access to any personal information we hold about you.
Summary information is available on request. More detailed requests which require archive or other retrieval costs may be subject to our normal professional and disbursement fees.
We also reserve the right to confirm the identity of the person seeking access to personal information before complying with any access requests. Please submit your access request in writing or e-mail to our privacy officer as identified below.

Correcting Errors
If Joseph T. Santoro Professional Corporation holds information about you and you can establish that it is not accurate, complete and up-to-date, we will take reasonable steps to correct it in a timely manner.

Can I be denied access to my personal information?
In most cases, a client of Joseph T. Santoro Professional Corporation will have access to the personal information we store about you. However, there may be occasions when your rights to access your personal information are denied. As an example, we may be representing a client on a file that involves you in some fashion. In the course of representing their client on this file, we may gather some personal information about you. As such, we could also deny access when:

  • your rights to access your personal information are not absolute;
  • denial of access is required or authorized by law (for example, when a record. containing personal information about you is subject to a claim of legal professional privilege by one of our clients);
  • the information relates to existing or anticipated legal proceedings against you;
  • when granting you access would have an unreasonable impact on other people’s privacy;
  • when to do so would prejudice negotiations with you;
  • to protect our firm’s rights and property;
  • where the request is frivolous or vexatious.
  • If we deny your request for access to, we will explain why.

Can I request anonymity?
Whenever it is legal and practicable, we may offer the opportunity to deal with general inquiries without providing your name (for example, by accessing general information on our website).
The Proceeds of Crime (Money Laundering) and Terrorist Financing Act requires us to confirm the identity of all new clients. It may also require us disclose information to FINTRAC in relation to certain large cash transactions.

Communicating with Us By E-Mail and/or Fax
You should be aware that e-mail and fax are not a 100% secure medium, and you should be aware of this when contacting us to send personal or confidential information or requesting us to respond to you by e-mail.

Changes to this Privacy Policy
Since Joseph T. Santoro Professional Corporation regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time. These changes will be posted to our web-site as soon as is practical.

Requests for Information Access and/or Corrections
If you have any questions, or wish to access your personal information, please write to our office at:

Joseph T. Santoro Professional Corporation
Attention: Privacy Contact
101 – 265 N. Front Street

Sarnia, Ontario

N7T 7X1

905-528-8411

If you are not satisfied with our response, the Privacy Commissioner of Canada can be reached at:

Privacy Commissioner of Canada
112 Kent Street
Ottawa Ontario
K1A 1H3
1-800-282-1376.

We may seek external advice, when appropriate, before providing a final response to individual complaints.

Website
Our website contains links to other sites, which are not governed by this privacy policy. On our website, like most other commercial websites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.

Thank you for taking the time to review our Privacy Policy.