Pollara Strategic Insights' Privacy Policy

Pollara Strategic Insights (“Pollara”, “we”, “us”, “our”) understands the importance of privacy and the protection of personal information. We maintain a rigorous privacy and data security program.

Overview

This privacy policy governs the collection, use, and disclosure of personal information by Pollara Strategic Insights.

For the most part, Pollara’s research activities require us to collect attitudinal, behavioural, and demographic information, which we only analyse and share or publicize in aggregate form, without revealing the individual personal identities or contact information of research participants. However, in some cases, we collect, use, and disclose personal information for research purposes and 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 retained only as long as necessary.

When you provide personal information, you agree that we may collect, use, and disclose your personal information in accordance with this privacy policy. In almost all cases, Pollara will provide our research respondents and participants with strict assurances that their identities, participation, and individual responses will be kept anonymous and confidential. If this is not the case, the need or intent to share personal information will be clearly explained as part of our invitation to participate in our research activities, so that respondents can determine if they are comfortable with participating in the research activity under these circumstances.

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. Should you have any questions or concerns, you are invited to contact our Chief Privacy Officer.

Strict Adherence to Privacy Laws and Standards

Pollara adheres strictly to the codes of ethics outlined by our industry association – the Canadian Research Insights Council (CRIC). As a founding, accredited Gold Seal member of CRIC, and are in full compliance with the CRIC Canadian Code of Market, Opinion, and Social Research and Data Analytics, the CRIC Public Opinion Research Standards and Disclosure Requirements, the CRIC Pledge to Canadians, and ISO 20252:2019. As a member of CRIC, Pollara’s research and business practices are regularly audited.

It should also be noted that Pollara adheres strictly to all privacy legislation, including PIPEDA (the Personal Information Protection and Electronic Documents Act), CASL (Canada’s Anti-Spam Law), and FIPPA (The Freedom of Information and Protection of Privacy Act). Complying with privacy laws has several implications for research suppliers and research buyers, such as:

  • Using lists supplied by clients, only where necessary permissions have been obtained in an explicit and recorded fashion;
  • Identifying the purpose for the collection of personal information;
  • Obtaining consent to use personal information;
  • Limiting collection and use of personal information; and
  • Ensuring the accuracy of an individuals’ personal information.

Collection of Personal Information

Personal information is any information, whether recorded or not, about an identifiable individual, or an individual whose identity may be inferred or determined from the information. Examples of personal information include age, name, ID numbers, income, opinions, evaluations, comments, or disciplinary actions.

We may share this de-identified and aggregated information with third parties. We consistently assess our collection, use and disclosure practices to protect personal information, even if the personal information has been de-identified or aggregated.

Retention of Personal Information

We retain personal information for as long as necessary to fulfill the purpose for which it was collected or as otherwise permitted by law. Once this purpose has been fulfilled, subject to any legal exceptions, we destroy the information in a secure manner that protects the privacy of the individual to whom the information relates. Our retention and destruction policy is reviewed and updated regularly.

Safeguards

We endeavour to maintain adequate physical, administrative, and technical security safeguards with respect to our offices and information storage capabilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of personal information. This commitment also applies to the disposal or destruction of personal information.

As part of these precautions, 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 and law enforcement authorities may be informed, if required by law. 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.

At Pollara, we pride ourselves on not just meeting but exceeding industry privacy standards. To this end:

  • All Pollara employees with access to personal information are contractually required to respect the confidentiality of that information.
  • Where required, we protect sensitive data using both physical measures (i.e. locked filling cabinets and a security patrolled office that is only accessible by pass after hours) and technological measures (i.e. use of passwords, encryption, and firewalls).
  • All project folders on shared drives are password-protected, so that only project team and backup team members have access.
  • We only use client sample if/after the client has obtained clear, specific, and explicit permission for the sharing and usage of contact information. Even in cases where all aspects of PIPEDA, FIPPA, and CASL have been respected, we still follow a protocol requiring the client to provide advance notice of the research (including an “opt-out” option).
  • When using client sample, we do not reveal the identity of participants’ responses, or who participated in the survey.
  • When using client sample, we never report on sub-groups of data with fewer than 20 responses, as this compromises the principle of respondent anonymity and response confidentiality.
  • A portion of Pollara’s research activities is conducted for governments, banks, and other organizations that require a level of data protection and security that goes beyond industry standards. With this in mind, Pollara’s computer systems are 100% redundant – that is, the system’s integrity is not compromised by the failure of one server. Rather, data is backed up on a nightly basis from each server and stored off-site. Moreover, Pollara utilizes a triple-layer firewall to ensure the integrity of our client’s information on our systems.

Pollara’s Privacy Commitment: Frequently Asked Questions (FAQ)

The purpose of this statement about our commitment to protecting your privacy is to inform you about Pollara’s practices and procedures when handling Personal Information and to inform you about the Personal Information we collect about you (for example, if you participate in one of our surveys) – and to do so as clearly as possible, with particular reference to the most frequently-asked questions we receive. This statement explains how we use and disclose that information, the choices you have regarding such use and disclosure, and how you may correct that information.

Overall, we are committed to your privacy, and complying with the laws and regulations under applicable privacy laws in Canada. We will treat Personal Information in a manner consistent with applicable laws and any of our own privacy policies which go above an beyond the letter of these laws. This privacy statement applies to any information we collect or receive about you, from any source.

  1. What is Personal Information? Personal Information is any information that is identifiable with you. This information may include but is not limited to your name, mailing address, phone numbers, email address, identification numbers and, in certain circumstances, your opinions and individual preferences. Personal Information, however, does not include (i) your name, business title or business address and business telephone number and fax in your capacity as an employee of an organization; and (ii) depending on the jurisdiction, publicly available information. However, if in your capacity as an employee of an organization you participate in one of our surveys, your responses will be treated as Personal Information.
  2. How do we collect your Personal Information? We will always collect your Personal Information by fair and lawful means (for example, when you respond to one of our surveys). We collect your Personal Information where we have obtained your consent to do so or as otherwise permitted by law.
  3. How do we use your Personal Information? We identify the purposes for which we use your Personal Information at the time we collect such information from you and obtain your consent, in any case, prior to such use. One of the primary purposes for which we collect your Personal Information is to conduct marketing and social research through conducting surveys. We may also use your Personal Information as otherwise permitted by law. If you provide us with sensitive personal information such as health or financial information, we will obtain your express consent for the collection, use and disclosure of sensitive personal information.
  4. To whom do we provide your Personal Information? We identify to whom, and for what purposes, we disclose your Personal Information, at the time we collect such information from you and obtain your consent to such disclosure. For example, we may disclose your Personal Information: (1) to a client for the client’s purposes of conducting further research, but only if you provide us informed, explicit permission to do so; (2) a third party engaged by Pollara to perform functions on its behalf; (3) such other disclosures of Personal Information to such persons for which you provide your consent; and (4) as otherwise permitted by law.
  5. When and how do we obtain your consent? We obtain your consent prior to collecting, and in any case, prior to using or disclosing your Personal Information for any purpose. You may provide your consent to us either orally or in writing. For example, when you respond to a survey, you provide your consent to allow us to use your Personal Information for the purposes of conducting marketing and social research and, in certain circumstances, to disclose your Personal Information to our clients. From time to time, we may collect, use or disclose your Personal Information based on your consent and as permitted by law. If you provide us with sensitive Personal Information such as health or financial information, we will obtain your express consent for the collection, use and disclosure of such sensitive personal information.
  6. How do we ensure the privacy of your Personal Information when dealing with our affiliates and other third parties? We ensure that all our affiliates and other third parties which are engaged to perform services on our behalf and are provided with Personal Information are required by contract to observe the intent of this Privacy Statement and our Privacy Policy and practices or are governed by the same Privacy Policy.
  7. How long will we use, disclose or retain your Personal Information? We will use, disclose or retain your Personal Information for as long as necessary to fulfill the purposes for which it was collected and as permitted or required by law. We have established minimum and maximum retention periods and procedures for maintaining and destroying your Personal Information.
  8. How can you review your Personal Information that we have collected, used or disclosed? We will make available to you any specific Personal Information on you in our custody or control, that we have collected, used or disclosed, upon your written request, to the extent permitted by law. We will make such information available to you in a form that is generally understandable, including explaining any abbreviations or codes.
  9. How do you know that the Personal Information we have on you is accurate? We will ensure that your Personal Information is kept as accurate, complete and up-to-date as possible. When we collect Personal Information from you, we rely on you for its accuracy. When we collect personal information from other sources, we ask for a representation from such source as to the accuracy of such personal information.
  10. What if the Personal Information we have on you is inaccurate? You can at any time, demonstrate in writing the accuracy or completeness of the Personal Information we have on you. If you successfully demonstrate that the Personal Information we have on you is inaccurate or incomplete, we will amend the Personal Information as required. Where appropriate, we will transmit the amended information to third parties having access to your Personal Information.
  11. How fast will we respond to your written requests? We will attempt to respond to each of your written requests not later than thirty (30) days after receipt of such requests. We will advise you in writing if we cannot meet your requests within this time limit. As provided for by PIPEDA, you have the right to make a complaint to the federal Privacy Commissioner in respect of our compliance with this time limit.
  12. Are there any costs to you for requesting information on your Personal Information or on our Privacy Policy or practices? We will not assess any costs to you for access to your Personal Information or on our Privacy Policy or practices without first providing you with an estimate of the approximate costs, if any. You may withdraw your requests for access to information by notifying us within the thirty-day notice period disclosed on the estimate.
  13. How do we know that it is really you requesting your Personal Information? We may request that you provide sufficient identification to permit access to the existence, use or disclosure of your Personal Information. Any such information shall be used only for this purpose.
  14. What safeguards have we implemented to protect your Personal Information? We have implemented physical, organizational, contractual and technological security measures to protect your Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. The only employees, who are granted access to your Personal Information, are those with a business ‘need-to-know’ or whose duties reasonably require such information.
 

Privacy and Security of Personal Information Obtained by Visiting Our Website

This section of our Privacy Policy speaks specifically to our practices related to the privacy and security of the personal information we may obtain from visitors to our websites, including www.pollara.com.

Individuals visiting pollara.com may be asked for identifiable information including name and email address. These requests are typically made only if visitors are using contact forms to send messages to Pollara, or downloading files, subscription forms, or reports. By providing such information, individuals are consenting to Pollara Strategic Insights in the manner described. Consent may be withdrawn by emailing information@pollara.com.

Pollara uses web analytics services, including Google Analytics, to help analyse the use of the website. These tools use cookies to collect and generate information about visits to pollara.com that is transmitted to their servers in an anonymous form for processing. Pollara studies patterns of website activity to improve the experience of visitors to pollara.com

The use of these tools does not allow Pollara Strategic Insights or any analytics service providers to identify individuals.

Individuals can opt-out of analytics activity by setting their browser to notify them when a cookie is sent and block analytics cookies if desired. Please consult the browser’s Help Menu for instructions. Visiting pollara.com with analytics cookies disabled will have no significant impact on the browsing experience.

If an individual elects to share ideas, information, postings, or reports from Pollara’s website to social media sites, their email contacts, or their own personal computers or devices via sharing icons or tools, such as ShareThis, the sharing application, the application’s parent company, and/or the applicable social media application’s privacy policy will govern the use and disclosure of your personal information. For greater certainty, Pollara Strategic Insights does not control and is not responsible for the privacy or data gathering practices for sharing applications and tools, such as ShareThis, or other social media application services. Individuals are subject to such application’s applicable terms and policies, including privacy and data gathering practices, when they use these services. Individuals should be aware that such third party applications may use technologies to track their online activity.

Contacting Pollara about our Privacy Policy

If you would like to contact us about your Personal Information, our Privacy Policy, or our related practices, please contact our Privacy Officer at information@pollara.com or in writing at the mailing address listed on our website.

Pollara understands the importance of privacy and the protection of personal information. We are committed to maintaining a rigorous privacy protection and data security program