Martin Kingston Associates

	Our Approach
	Our Difference
	Our Values
	Our Practice Areas
	Our Search Process i) Candidate Identification ii) Candidate Assessment & Matching
	Our Team i) Martin Kingston ii) Annette Filler iii) Bruce Hunter iv) Don Norris v) Joining Us
	Our Fees and Guarantees
	Our Privacy Policy

Martin Kingston & Associates Incorporated ("MKA") is committed to personal information privacy. This Policy describes how MKA collects, uses and discloses personal information. Please read this Policy carefully and if you have any questions or concerns, please contact our Privacy Officer at martin@martinkingston.com

I. Application

This Policy governs the collection, use and disclosure of personal information by MKA from and about individuals who are not employed by MKA, and applies to every branch office of MKA.

It is our policy to comply with the privacy legislation within each jurisdiction in which we operate. This Policy covers only those activities that are subject to the provisions of Canada's federal and provincial privacy laws, as applicable.

II. What is Personal Information?

In this Policy "personal information" refers to any information about an identifiable individual other than the person's business title or business contact information.

III. What Personal Information Do We Collect?

We collect and maintain different types of personal information in respect of individuals with whom we interact. This includes:

contact and identification information, such as your name, address, telephone number and e-mail address;
product and service related information concerning the products and services that we provide to, or receive from, you;
customer relationship information such as customer requests and feedback and information requested or provided by or from you; and
business relationship information, including information related to your agreements, preferences, advisors and decision-makers.

In order to provide recruitment services to our clients we may also collect:

resume information such as your employment history, clients/transactions lists, academic history and transcripts;
remuneration information such as previous or expected salary, benefits and bonuses;
job search information such as the history of jobs/employers that the you have applied to, interview notes and personal evaluations by MKA consultant(s) and correspondence between candidates and MKA; and
payroll information, if applicable, including your Social Insurance Number and direct deposit bank account information. We may also collect market-related information, which may include personal information, concerning market trends and activities impacting our business and information related to our media and public relations activities.

IV. Why Do We Collect Personal Information?

We collect personal information to enable us to manage and develop our business and operations, including:

to establish, maintain and manage relations with you so that we may provide you with, or receive from you, the products and services that have been requested (for example, we will use your personal information to determine your suitability for a position);
to be able to review the services that we provide to you so that we may understand your requirements for our services and so that we may work to improve our services;
to be able to inform you of our services other than those that you have specifically requested, including sending you information promoting our other services;
to be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number or e-mail address and advise us of your preference, we will use this information to contact you at that number or e-mail address);
to protect us against error, fraud, theft and damage to our goods and property;
to enable us to comply with applicable law or regulatory requirements; and
any other reasonable purpose to which you consent.

V. How do we Use and Disclose Your Personal Information?

We use and disclose your personal information:

for the purposes described in this Privacy Policy; or
for any additional purposes for which we have obtained your consent to the use or disclosure of your personal information (which consent may be express, deemed or implied, as explained below). We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so. If you are a candidate, please rest assured that your personal information will not be disclosed to any potential employer without your prior consent.

VI. Our Website

You can visit our website (www.martinkingston.com) without telling us who you are or revealing any information about yourself, including your e-mail address. Our web server may collect information related to your visit to our website, including the IP address and domain used to access our site, the type and version of your browser, the website you came from to access our site, the page you entered and exited at, any website page that is viewed by that IP address and what country you are from. We use this information to monitor our website's performance (such as number of visits, average time spent, page views) and for our business purposes such as working to continually upgrade our website.

When you apply for a position on our website, we imply that you have consented to the collection, use and disclosure of your personal information for the purposes and in the manner set out in this Privacy Policy.

VII. Who Has Access to Your Information?

We share your personal information with our employees, contractors, consultants and other parties who require such information to assist us with establishing, maintaining and managing our relationship with you, including: third parties that provide services to us or on our behalf; third parties that collaborate with us in the provision of services to you; and third parties whose services we use to perform our services.

In addition, personal information may be disclosed or transferred to another party in the event of a change in ownership of, or a grant of a security interest in, all or a part of MKA through, for an example, an asset or share sale, or some other form of business combination, merger or joint venture, provided that such party is bound by appropriate agreements or obligations and required to use or disclose your personal information in a manner consistent with the use and disclosure provisions of this Privacy Policy, unless you consent otherwise.

VIII. Your Consent Is Important To Us

It is important to us that where we collect, use or disclose your personal information we have your consent to do so. Depending on the sensitivity of the personal information, your consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your action or inaction. For example, if you submit a resume or other personal information by mail, fax, or e-mail, whether in response to an advertisement or to MKA in general, we will assume your consent to the collection, use and disclosure of your personal information for purposes related to your recruitment and placement by MKA.

You may change or withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting our Privacy Officer using the contact information set out below. In some circumstances, a change in or withdrawal of consent may severely limit our ability to provide services to, or acquire products or services from, you. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to your consultant or our Privacy Officer.

IX. Protecting Personal Information

We understand the importance of protecting your personal information. For that reason MKA endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure. Documents, which contain personal information, are kept in filing cabinets, which are maintained in our offices. All electronic information is stored on our data base, which is maintained in Toronto.

X. Is Your Personal Information Accurate?

Please let us know if you believe that your personal information is inaccurate. You have the right to ask for it to be corrected or updated. We may ask you to provide documentation to support your request for correction or updating. If we do not agree with your request, we will include your request in our file.

XI. Access to Your Personal Information

You have the right to see your personal information held by MKA. If you would like to see your personal information we ask that you fill out and submit an Access to Information Form. This form may be requested by contacting your MKA consultant or our Privacy Officer.

When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. If you require assistance in preparing your request, please contact your MKA consultant or our Privacy Officer.

Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.

In the event that we cannot provide you with access to your personal information, we will endeavor to inform you of the reasons why, subject to any legal or regulatory restrictions.

XII. Privacy Officer

We have appointed a Privacy Officer to oversee compliance with this Privacy Policy. The contact information for our Privacy Officer is as follows:

Martin Kingston
Privacy Officer
4950 Yonge Street, Suite 1008
Toronto, Ontario M2N 6K1
martin@martinkingston.com
(416) 440-1937

XIII. Revisions and Interpretation

MKA may from time to time make changes to this Policy. We will post any revised versions of this Policy on our website www.martinkingston.com. Any changes to this Policy will be effective from the date they are posted. If any changes are made to MKA's use, collection or disclosure of your personal information that require your consent, we will not implement such changes until your consent has been obtained.

This Policy has a limited scope and application and the rights and obligations contained in this Policy may not be available to all individuals or in all jurisdictions. This Privacy Policy does not create or confer upon any individual any rights, or impose upon MKA any rights or obligations outside of, or in addition to, any rights or obligations imposed by Canada's federal and provincial privacy laws, as applicable. Should there be, in a specific case, any inconsistency between this Privacy Policy and Canada's federal and provincial privacy laws, as applicable, this Privacy Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy laws.