Reviewed/Updated February 7, 2022

At Probe Research (“we,” “us,” “our”), respecting privacy is an important part of our commitment to our respondents and the general public. Our privacy policy is meant to be easy to follow, clear and comprehensive.

Probe Research will continue to review its Privacy Policy to make sure that it is relevant and remains current with changing industry standards, technologies and laws.

Probe Research is a member of the Canadian Research Insights Council (CRIC). This organization sets standards to which members must adhere and which also protect your privacy.

If you have any concerns about how your privacy is protected at Probe Research, please contact our Privacy Officer by e-mail at [email protected], or by mail at 603-191 Lombard Avenue, Winnipeg, MB R3B 0X1.

Overview

This privacy policy governs the collection, use and disclosure of personal information by Probe Research (together, “personal information.”)

We collect, use, and disclose personal information, including electronic information, for reasons that are consistent with the purposes described in this policy, or as otherwise permitted or mandated by law. Personal information is kept securely by us and our service providers and is retained only as long as necessary. Except in limited circumstances, you (your, yours) have a right to access the information collected about you, within a reasonable time frame, in accordance with existing legislation.

We will, from time to time, review and revise our privacy practices and this privacy policy. Policy changes will apply to the information collected from the date of the revised privacy policy as well as to existing information held by us at the time of the amendment. Updates to this privacy policy will be published on our website (www.probe-research.com/resources/privacy). Should you have any questions or concerns, you are invited to contact us at [email protected]

When you provide personal information, you agree that we may collect, use, and disclose your personal information in accordance with this privacy policy. You are free to withdraw your consent at any time. However, if you choose not to provide us with consent to collect, use, or disclose personal information, we will not be able to offer some of the services requested.

The Detailed Probe Research Corporate Privacy Policy

Scope and Application

The 10 principles that form the basis of the Probe Research Privacy Policy are interrelated and Probe Research shall adhere to the 10 principles as a whole.  Each principle must be read in conjunction with the accompanying commentary.  As permitted by the Personal Information Protection and Electronic Documents Act (Canada), the commentary in The Probe Research Privacy Policy has been drafted to reflect personal information issues specific to Probe Research.

The scope and application of The Probe Research Privacy Policy are as follows:

• The Probe Research Privacy Policy applies to personal information collected, used, or disclosed by Probe Research in the course of commercial activities.
• The Probe Research Privacy Policy applies to the management of personal information in any form whether oral, electronic or written.
• The Probe Research Privacy Policy does not impose any limits on the collection, use or disclosure of the following information by Probe Research:
  • non-personally identifiable information;
  • the name, title, business address and/or telephone number of an employee of an organization;
  • other information about an individual that is publicly available and is specified by regulation pursuant to the Personal Information Protection and Electronic Documents Act (Canada).
• The application of the Probe Research Privacy Policy is subject to the requirements and provisions of the Personal Information Protection and Electronic Documents Act (Canada), the regulations enacted thereunder, and any other applicable legislation or regulation.

Definitions

collection: The act of gathering, acquiring, recording, or obtaining personal information from any source, including third parties, by any means.

consent: Voluntary agreement for the collection, use and disclosure of personal information for defined purposes.  Consent can be either expressed 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 Probe Research.  Implied consent is consent that can reasonably be inferred from an individual’s action or inaction.

disclosure: Making personal information available to a third party.

employee: An employee of or independent contractor to Probe Research

personal information: Information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization, and does not include descriptive, factual information about an organization.

respondent: A member of the public who provides personal information to Probe Research in the course of a survey conducted by our firm. For example, a respondent is an individual who discloses personal information to Probe Research in the course of quantitative or qualitative marketing or social research.

third party: An individual or organization outside of Probe Research.

use: The treatment, handling, and management of personal information by and within Probe Research or by a third party with the knowledge and approval of Probe Research.

The Ten Principles of Privacy

Principle 1 - Accountability

Probe Research is responsible for personal information under its control and shall designate one or more persons who are accountable for Probe Research’s compliance with the following principles.

Responsibility for compliance with the provisions of the Probe Research Privacy Policy rests with the Probe Research Privacy Officer who can be reached by e-mail at [email protected] or by mail at 603-191 Lombard Avenue, Winnipeg, MB R3B 0X1.  Other individuals within Probe Research may be delegated to act on behalf of the Privacy Officer or to take responsibility for the day-to-day collection and/or processing of personal information.

Probe Research is responsible for personal information in its possession or control and shall use contractual or other means to provide a comparable level of protection while information is being processed or used by a third party.

Principle 2 - Identifying Purposes for Collection of Personal Information

Probe Research shall identify the purposes for which personal information is collected at or before the time the information is collected.

Probe Research collects personal information from the public only for the following purposes:

• To conduct quantitative or qualitative market, public opinion and social research;
• To understand respondents’ opinions, demographic/socio-economic profile and product/service use to establish suitability for further participation in research on specific topics;
• To communicate with you, including for direct marketing purposes that you have agreed to receive and that are relevant to you;
• To respond to your communications to us; and
• To meet legal and regulatory requirements.

Further reference to “identified purposes” mean the purposes identified in this Principle.

Probe Research shall specify orally, electronically or in writing the identified purposes to the respondent at or before the time personal information is collected in a survey. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within Probe Research who can explain the purposes.

When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identified prior to use.  Unless the new purpose is permitted or required by law, the consent of the respondent will be acquired before the information will be used or disclosed for the new purpose.

Probe Research may provide clients or other third parties with information from any survey in aggregate form. In aggregate form, it is impossible to identify an individual respondent’s personal information. By participating in Probe Research market, public opinion and social research studies, you agree that we may de-identify your personal information for the purposes consistent with this policy.

Principle 3 - Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of an individual are required for the collection, use, or disclosure of personal information, except where inappropriate.

Participation by respondents in survey research is always voluntary. When a respondent agrees to participate in a survey, they give consent to the interview by participating.

Generally, any personal information collected in the course of an interview is not disclosed to third parties.  However, occasionally, a client sponsoring a research project may want to contact respondents directly. In these cases, Probe Research always explains the reason for the disclosure to the respondent and obtains express permission from the respondent before making any such disclosure.

A respondent is always free to choose whether to participate in a survey, free to choose not to answer any specific questions and free to discontinue participation at any time.

In obtaining consent, Probe Research shall use reasonable efforts to ensure that a respondent is advised of the identified purposes for which personal information will be used or disclosed. The identified purposes shall be stated in a manner that can be reasonably understood by the respondent.

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

In determining the appropriate form of consent, Probe Research shall take into account the sensitivity of the personal information and the reasonable expectations of its respondents.

The participation of a respondent in a quantitative or qualitative market, public opinion or social research study may constitute implied consent for Probe Research to collect, use and disclose personal information for the identified purposes.

Principle 4 - Limiting Collection of Personal Information

Probe Research shall limit the collection of personal information to that which is necessary for the purposes of the research project. Probe Research shall collect personal information by fair and lawful means.

In conducting quantitative and qualitative research, Probe Research limits the amount and type of personal information it collects.  We collect only the amount and type of information needed for the purposes identified to individuals.

Probe Research collects personal information about an individual primarily from that individual or a member of that individual’s household.  Except as permitted by law, Probe Research will only collect personal information from external sources, such as client organizations, if individuals have consented to such collection.

Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information

Probe Research 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 or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

Probe Research may disclose a respondent’s personal information to:

(a)        a client of Probe Research where the respondent has consented to such disclosure;

(b)        a third party engaged by Probe Research to perform functions on its behalf;

(c)        a public authority or agent of a public authority if, in the reasonable judgment of Probe Research, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or

(d)        a third party or parties, where the respondent consents to such disclosure or disclosure is required or permitted by law.

Only Probe Research’s employees and contractors with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about respondents. All Probe Research employees and contractors are required to adhere to policies and best practices related to the protection of privacy and security of personal information.

Probe Research 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 a respondent may have to be re-contacted for purposes of clarifying responses to a survey, or to seek additional responses, Probe Research shall retain the personal information for a period of time that is reasonably sufficient to allow this re-contact.

Probe Research 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. Our retention and destruction policy is also reviewed and updated regularly.

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.

Personal information used by Probe Research 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 respondent.

Probe Research shall update personal information about respondents and employees as necessary to fulfill the identified purposes or upon notification by the individual.

Principle 7 - Security Safeguards

Probe Research shall protect personal information by security safeguards appropriate to the sensitivity of the information.

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

All of Probe Research’s employees with access to personal information shall be required to respect the confidentiality of that information, including by signing confidentiality agreements. We restrict access to personal information to those employees and, under appropriate contractual arrangements, third party service providers we determine need to know that information in order that we may provide our services. We treat employee misuse of personal information as a serious offence for which disciplinary action may be taken. We are also prepared to take all appropriate steps to enforce the provisions of confidentiality agreements with external parties.

Probe Research 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. We are also prepared to take all appropriate steps to enforce the provisions of confidentiality agreements with external parties.

We may rely on external service providers who are located outside of Canada. Some personal information collected by us may therefore be retained in countries other than Canada where privacy laws may offer different levels of protection, and personal information may be subject to access by and disclosure to law enforcement agencies in those jurisdictions.

Principle 8 - Openness Concerning Policies and Procedures

Probe Research shall make readily available to individuals specific information about its policies and procedures relating to the management of personal information.

Probe Research shall make information about its policies and procedures easy to understand, including:

(a)        the title and address of the person or persons accountable for Probe Research’s compliance with its Privacy Policy and to whom inquiries and/or complaints can be forwarded;

(b)        the means of gaining access to personal information held by Probe Research; 

(c)        a description of the type of personal information held by Probe Research including a general account of its use; and

(d)        a description of what personal information is made available to related organizations (e.g. subsidiaries).

Principle 9 – Individual Access to Personal Information

Upon request, Probe Research shall inform an individual of the existence, use, and disclosure of his or her personal information and shall give the individual access to that information.  An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Upon written request to the Privacy Officer, Probe Research will inform an individual of the existence, use and disclosure of their personal information and shall be given access to that information within five (5) business days.

In certain situations, Probe Research may not be able to provide access to all the personal information that it holds about a respondent. For example, Probe Research 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, Probe Research may not provide access to information if disclosure would reveal confidential commercial information.

In order to safeguard personal information, a respondent may be required to provide sufficient identification information to permit Probe Research 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.

Probe Research 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, Probe Research shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.

Respondents and employees can obtain information or seek access to their individual files by contacting the Probe Research Privacy Officer.

Principle 10 - Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Probe Research’s compliance with the Probe Research Privacy Policy.

Probe Research shall maintain procedures for addressing and responding to all inquiries or complaints from its respondents regarding our handling of personal information.

Probe Research shall, on written request, inform its respondents about the existence of these procedures as well as the availability of complaint procedures within five (5) business days of receiving the request.

The person or persons accountable for compliance with the Probe Research Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

Probe Research shall investigate all complaints concerning compliance with its Privacy Policy.  If a complaint is found to be justified, Probe Research shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures.  The respondent shall be informed of the outcome of the investigation regarding his or her complaint within 14 days of the conclusion of the investigation.

Additional Information

For more information regarding the Probe Research Privacy Policy, please contact the Probe Research Privacy Officer by e-mail at [email protected], or by mail at 603-191 Lombard Avenue, Winnipeg, MB  R3B 0X1.

Please visit the Privacy Commissioner of Canada’s website at www.privcom.gc.ca.