“Consumers expect
transparency by businesses about their privacy
practices, and clear privacy policies are a
key part of that openness.
I commend this year’s
winners of the Nymity award for their efforts
in building trust with their customers."
David Loukidelis, BC’s
Information and Privacy Commissioner
"Strengthening one’s
privacy policies and improving the quality of
the notice provided makes good business sense.
My mantra has always been ‘privacy is
good for business,’
Congratulations to this
year’s winners.”
Dr. Ann Cavoukian Information
and Privacy Commissioner of Ontario
Transparency
"Transparency is clear, complete and
readily available notice on an organization's
privacy policies and practices."
Nymity Definition
Canadian Notice Index- 2004
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2006 Top Privacy Policies in Canada
Awards for Transparency
| For privacy, Nymity
defines Transparency as "Clear, complete
and readily available notice on an organization's
privacy policies and practices."
Transparency allows consumers to make informed
decisions while increasing an organization's accountability
and compliance with privacy laws.
Nymity's 2006 Top Privacy Policies in Canada
awards recognizes organizations with the
highest level of Transparency. To measure Transparency
objectively, Nymity assessed hundreds of organizations
in Canada using 63 transparency considerations
found in the Canadian
Notice Index.
Visit Awards Background
for details on the awards assessment methodology.
2006 Top Privacy Policy
in Canada
In 2006, the awards for transparency go to:
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| Banking
- TD Bank Financial Group
- Scotiabank
- CIBC
- Laurentian Bank
- RBC Royal Bank
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Telcos
- TELUS
- Telebec
- Bell
- Rogers
- Aliant
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Retail
- Chapters Indigo
- Holt Renfrew
- Sears Canada
- Costco Canada
- Roots Canada
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| Financial
Services
(outside of banking)
- Vancity
- MCAP
- ATB Financial
- Financialinx
- GMAC Financial Services
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Insurance
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Media
- CanWest Global Communications Corp
- Thomson Nelson
- Alliance Atlantis
- Transcontinental
- Chum Limited
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| Consumer
Services
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Business Services
(outsourcing sector)
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Ceridian Canada
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Ipsos Canada
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Aon Canada
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ADP Canada
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Kelly Services
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Awards
Background
History
In 2004, Nymity initiated a comprehensive
study of Canadian privacy notices and privacy policies
that identified over 130 privacy policy provisions used
by corporate Canada when being transparent about the
organization's personal information handling policies
and practices. Transparency, which Nymity defines
as: "Clear, complete and readily available
notice on an organization's privacy policies and practices",
is critical for organizations to built trust with consumers
and to mitigate privacy risk associated with non-compliance
with privacy laws.
In 2005, Nymity used a subset of the 130
policy provisions to identify the top privacy policies
in Canada. Nymity's goal is to demonstrate Transparency
best-practices and recognize the organizations that
were most Transparent. The organizations with
the most Transparent privacy policies received the 2005
Top Privacy Policies in Canada award. The 130 privacy
provisions are published in Nymity's Canadian
Notice Index.
2006 Awards
To produce the 2006 Awards, Nymity assessed
over 200 companies in eight industries against 63 key
Transparency Considerations found in the Canadian
Notice Index. Nymity used a combination of
a public nomination process and research processes to
determine the 20 to 30 companies assessed per industry.
Only the Award winners are identified and the 63 Transparency
Considerations were held secret until after the announcement.
Objective Assessment
The assessments were conducted by one
of Nymity's lawyers to ensure a consistent methodology
was applied. The Transparency Considerations provided
an objective assessment that couldn't be influenced
by an opinion of the content. For example, when
assessing privacy notices based on the Transparency
Consideration,"Does the notice address
the use of personal information for secondary purposes?",
an organization that states, "We use personal
information for secondary purposes we feel may be of
interest to you," would rank equal to an organization
that states,"We do not use personal information
for secondary purposes." But an organization
that didn't address use for secondary purposes would
not be considered Transparent. The key is providing
notice on this matter to allow consumers to make informed
choices.
Example Assessment Criterion
Some examples of the 63 Transparency Considerations
used for the assessment are:
- Does the notice address whether an organization
does or does not transfer personal information
outside of Canada?
- Does the notice address the use of 3rd parties?
- Does the notice address how or by what method
an individual may provide consent?
- Does the notice address the implications of
withdrawing consent?
- Does the notice address the renting and/or leasing
of personal information?
- Does the notice address how personal information
in the possession and/or control of the organization
will be handled in the event the organization
is merged, acquired or sold?
- Does the notice provide a Frequently Asked Questions
section?
- Does the notice provide examples of the type
of personal information collected?
- Does the notice provide the date the notice
was last amended?
Policies Made Readily Available
Nymity assessed privacy notices made readily
available to consumers via the organization's website.
This includes privacy policies, codes, statements, promises
as well as documents they linked to which could include
customer terms and conditions and security policies.
Compliance with Privacy Laws
Nymity research has revealed that organizations
that invest in Transparency typically make substantial
investments in their privacy management programs in
order to minimize data breaches and to ensure compliance
with privacy laws. This is partially due to transparent
privacy policies increases an organization's accountability
to consumers, regulators and business partners.
Outsourcing Service Providers
New for 2006 is an assessment of the Business
Services industry. Nymity assessed Business Services
because our research found that businesses and government
entities are assessing service provider online privacy
policies when selecting outsourcing suppliers. Business
Services industry privacy policies are being used to
assess an organizations understanding and commitment
to privacy and compliance with privacy laws.
Nominations for 2007 Awards
Nominations are now being accepted for
the 2007 assessment. In 2007, Nymity will use
an updated set of Transparency Considerations as established
by Nymity and its advisors. In 2007, Nymity will look
to a weighted assessment criteria and more emphasis
will be placed on the use of multi-layered privacy notices.
To learn more about the Awards, the Canadian Notice
Index or to submit a nomination for 2007, contact Nymity
at 416 214 7838, toll-free at 1 866-3-NYMITY or by email
at info@nymity.com.
About Nymity
Nymity is a privacy research firm that
provides pragmatic privacy risk management solutions
that help organizations mitigate risks that lead to
privacy breaches, customer complaints and non-compliance
with privacy laws. Our clients include privacy officers,
lawyers with privacy practices, privacy consultants
and privacy commissioners' offices across Canada.
Nymity's focus is 100% privacy research and training.
For privacy consulting or legal services visit Nymity's
partners.
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