CUBE FOR TEACHERS' COMMITMENT TO PRIVACY
Commitment #1: Accountability
Commitment #2: Identifying Purposes for Collecting Personal Information
Cube for Teachers will, either directly or through a user, identify to an individual the purposes for which it collects, uses and discloses personal information (the "Purposes"), before or at the time the information is collected, or where the information is to be used or disclosed for a new purpose, before that use or disclosure. The Purposes may include:
(a) understanding, developing and administering social media products, services and resources that meet individuals' and other users' educational and professional needs; (b) processing registration and payment; (c) administering accounts, bills and collections relating to individuals' and organizations' relationships with Cube for Teachers; (d) responding to user inquiries; (e) protecting against fraud and error; (f) communicating with individuals in connection with the purposes in (a) through (e); and (g) offering individuals and/or their organizations new social media products, services and resources that may be of interest to them (provided that individuals have not opted out of receiving, or having their organizations receive, such offers).
Commitment #3: Obtaining Consent
Cube for Teachers will make a reasonable effort, either directly or through a user, to advise an individual as to how personal information will be used or disclosed by Cube for Teachers. Generally, Cube for Teachers or a user, on behalf of Cube for Teachers, will obtain the individual's consent to the collection, use and disclosure of personal information for the Purposes before or at the time it collects the information. An individual's consent may be express or implied, depending on the sensitivity of the information.
An individual may withdraw or vary his or her consent on reasonable notice to Cube for Teachers, subject to legal or contractual restrictions. Cube for Teachers will generally be able to give effect to such withdrawal or variation on thirty (30) days' notice, and will, if it has not already done so, advise the individual of the implications of his or her withdrawal or variation.
Commitment #4: Limits on the Collection of Personal Information
Cube for Teachers will limit the personal information it collects to information necessary for the Purposes. Cube for Teachers will only collect personal information by fair and lawful means. Cube for Teachers will not collect personal information from any third party (other than a user acting on behalf of Cube for Teachers) without an individual's consent unless the collection is clearly in the individual's interest and Cube for Teachers is unable to obtain consent in a timely way, or as otherwise permitted by law.
Cube for Teachers will not, as a condition of supplying a product, service or resource, require an individual's consent to the collection, use or disclosure of his or her personal information beyond that reasonably required to supply the product, service or resource, to comply with its obligations under applicable law or for related internal business or management or legal purposes.
Commitment #5: Limits on the Use, Disclosure and Retention of Personal Information
Cube for Teachers will only use, disclose and retain personal information for the Purposes. Cube for Teachers will identify any third parties to whom personal information will be disclosed at the time of collection and obtain individuals' consent to such disclosure. For example, Cube for Teachers may transfer personal information to third parties for processing (e.g., data processing or hosting), pursuant to contractual agreements that provide a level of protection for the personal information comparable to that provided by Cube for Teachers, as well as assurances that such third parties will not use or disclose the personal information for any purpose other than processing.
Under certain statutory exceptions, Cube for Teachers may have a legal duty or right to disclose personal information without individuals' consent. Examples of permitted disclosures of personal information to non-affiliated third parties may include disclosures required to comply with a subpoena or warrant, made pursuant to a request by a government institution, made to an investigative body or government institution where Cube for Teachers has reasonable grounds to believe that the information relates to a breach of an agreement or law or disclosures otherwise required by law.
Cube for Teachers may from time to time disclose de-identified, aggregated information to an individual's organization for the purposes of understanding and administering products, services and resources that meet the organization's educational and professional needs, and communicating with the organization for that purpose, and/or offering the organization new products, services and resources that may be of interest to it.
Cube for Teachers will use, disclose and retain personal information only for as long as is necessary to fulfill the Purposes or as otherwise permitted or required by law. Cube for Teachers has established minimum and maximum retention periods and procedures for retaining and destroying personal information.
Commitment #6: Accuracy of Personal Information
Cube for Teachers will use reasonable efforts to keep personal information as accurate, complete and up-to-date as necessary for the Purposes. That said, Cube for Teachers will not routinely update personal information unless necessary. Cube for Teachers expects individuals, from time to time, to inform Cube for Teachers of any updates that may be required by contacting Cube for Teachers using the contact information above.
Commitment #7: Safeguarding Personal Information
Cube for Teachers is committed to protecting the security of personal information. Cube for Teachers uses security safeguards appropriate to the sensitivity of personal information to protect it from loss or theft, as well as unauthorized access, disclosure, copying, use or modification. These safeguards include physical measures, such as restricted access to offices and equipment, organizational measures, such as security clearances and limiting access on a "need to know" basis and technological measures, such as the use of passwords, encryption and other secure methods by which to verify the identity of individuals.
Cube for Teachers' staff are made aware, through orientation and refresher training programs, of the importance of maintaining the confidentiality of personal information. Cube for Teachers conducts periodic internal and independent audits of its security safeguards and any breach of Cube for Teachers' security safeguards is a disciplinary matter. Cube for Teachers' security safeguards extend to the destruction of personal information.
Cube for Teachers remains responsible for all personal information transferred to third parties for processing. As such, Cube for Teachers ensures that all third parties engaged to perform services on Cube for Teachers' behalf are required to provide a level of protection for personal information comparable to the level of protection provided by Cube for Teachers, and that such third parties are prohibited from using or disclosing personal information for any purpose other than processing.
Commitment #8: Availability of Information about Cube for Teachers' Policies and Practices
Commitment #9: Access to Personal Information
Upon written request, Cube for Teachers will generally tell an individual what personal information it has, what it is being used for and to whom it has been disclosed and will grant the individual access to the information. Cube for Teachers will make such information available to an individual in a form that is generally understandable, including by explaining any abbreviations or codes or by employing an alternative format, if required. Written requests, including the individual's name and contact information, should be sent to Cube for Teachers' Chief Privacy Officer using the contact information above. Cube for Teachers will make every reasonable effort to respond to written requests within thirty (30) days of receipt and will advise individuals in writing if for any reason this time limit cannot be met.
Cube for Teachers may request individuals who submit written requests to provide sufficient information to enable Cube for Teachers to verify their identity. Any such information will be used only for the purpose of identification.
Cube for Teachers will not assess any costs to individuals for accessing their personal information without first providing individuals with an estimate of such costs, which will be minimal, if any. Individuals are asked to confirm their wish to proceed in writing within the thirty (30) day notice period set out in any estimate. If an individual does not notify Cube for Teachers in writing of his or her wish to proceed within such notice period, then Cube for Teachers will deem the individual to have withdrawn his or her request for access and will provide him or her with a written notice to that effect.
An individual may challenge the accuracy and completeness of personal information and request that it be amended. Cube for Teachers will, if appropriate, amend the information and advise third parties to whom the information as been disclosed of the amendment.
Commitment #10: Handling Complaints and Questions
Prior to making a complaint to the Chief Privacy Officer, or if a complaint is not resolved to the individual's satisfaction, the individual may also make a complaint to the applicable Privacy Commissioner.