Privacy Code - Coach Terminal and Insurance Company

Privacy Code – For the Toronto Coach Terminal Inc. and the TTC Insurance Company Ltd.


1.0 Accountability

For the purposes of this Privacy Code, “The Organizations” shall mean the following entities:

  • Toronto Coach Terminal Inc.; and
  • TTC Insurance Company Limited.

The organizations are responsible for personal information under their control. The Coordinator – Records Management/Freedom of Information, Commission Services Department has been designated by each of the organizations as the individual accountable for compliance in accordance with Personal Information Protection and Electronic Documents Act (“PIPEDA”) and this Privacy Code.

A request to any one of the organizations in accordance with PIPEDA shall be:

  1. in writing;
  2. made to the Toronto Transit Commission’s Co-ordinator – Records Management/Freedom of Information; and
  3. specify the information that is requested and the authority (i.e. PIPEDA) in which the information is being requested.

2.0 Purposes

The organizations will use personal information that is collected for the following purposes:

  • to communicate with you;
  • assess and process your application for employee benefits, and/or any similar service, as applicable;
  • evaluate and administer claims for, accident benefits, insurance benefits and/or any similar requirement within the jurisdiction of the organization;
  • detection and prevention of fraud;
  • capture injury/witness data;
  • analyze business results;
  • safety and security;
  • process payments;
  • administer insurance benefits;
  • issue travelling documents;
  • statistical and actuarial purposes;
  • auditing internal procedures;
  • in a manner consistent with why the personal information was collected; and
  • as required or as otherwise requested by law.

If any organization requires personal information for any other purpose, save and except for as stated in 2.0 above, we will ask for and obtain verbal or written proof of your expressed consent before using it.

3.0 Consent

When you do business with an organization, we ask that you provide information that we use in the course of providing various services to you or to help in the investigation of claims.  By providing this information you consent to the use of this information in order for the organization (s) and / or the TTC to provide you with various services and/or evaluate applications for various benefits.

Individuals can give consent in many ways. For example:

  1. an application form may be used to seek consent, collect information, and inform the individual of the use that will be made of the information. By completing and signing the form, the individual is giving consent to the collection and the specified uses;
  2. a check off box may be used to allow individuals to request that their names and addresses not be given to other organizations. Individuals who do not check the box are assumed to consent to the transfer of this information to third parties;
  3. consent may be given orally when information is collected over the telephone; or
  4. consent may be given at the time that individuals use a product or service.

The organizations may collect, use or disclose personal information without your knowledge or consent in certain circumstances, including detection and/or prevention of fraud.

You may withdraw your consent at any time, subject to legal or contractual restrictions and the requirement to maintain the integrity of the statistics and data necessary to carry on our business.  However, the withdrawal of consent may affect our ability to respond to your requests and to provide you services.

4.0 Limiting Collection

The collection of personal information by the organizations is limited to that which is necessary for the purposes identified in section 2.0 above. All personal information is collected by the organizations in a fair and lawful manner.

5.0 Limiting Use, Disclosure, and Retention

Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as permitted by law. Personal information shall be retained in accordance with applicable TTC record retention by-law or as long as necessary for the fulfilment of those purposes.

6.0 Accuracy

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

7.0 Safeguards

All personal information collected by the organizations will be protected by using appropriate procedural, electronic, technical and physical safeguards against loss, theft and unauthorized access, disclosure, copying, use or modification.

8.0 Openness

The organizations are committed to ensuring that specific information about their policies and practices relating to the management of personal information are provided. For further information, please contact the Toronto Transit Commission Freedom of Information at 416-472-2011.

The information made available includes:

  1. the name or title, and the address, of the person who is accountable for the organizations policies and practices and to whom complaints or inquiries can be forwarded;
  2. the means of gaining access to personal information held by any of the organizations;
  3. a description of the type of personal information held by any of the organizations, including a general account of its use;
  4. a copy of any brochures or other information that explain any of the organizations policies, standards, or codes; and
  5. what personal information is made available to other organizations and the TTC (e.g., subsidiaries).

9.0 Individual Access

An individual may make a written request for access to his/her personal information in any of the organizations possession. An individual may be required to provide sufficient information to permit the organizations to properly provide an account of the existence, use, and disclosure of personal information. The information provided shall only be used for this purpose. We will attempt to respond to any request within 30 days of receiving such a request. We may charge an individual for providing access to his/her information, but only after first advising the individual of the approximate cost.

If an individual successfully demonstrates the inaccuracy or incompleteness of personal information, the organizations shall amend the information as required.

Depending upon the nature of the information challenged, amendment may involve the correction, deletion, or addition of information. Where appropriate, the amended information shall be transmitted to third parties having access to the information at issue.

10.0 Challenging Compliance

If an individual believes that an organization is not complying with the principles set out in PIPEDA, please contact the TTC’s Co-ordinator – Records Management/Freedom of Information, who will investigate an individual’s concerns. If a complaint is found to be justified, the organization shall take appropriate measures, including, if necessary, amending its policies and practices.
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