Privacy Statement
Commonwealth Connects is committed to maintaining the highest levels of protection of personal information, as reflected in standards and codes of practice adopted at the international level and in the national laws of member countries of the Commonwealth.** In keeping with this commitment, Commonwealth Connects will manage personal information in accordance with the following principles, which shall apply to all personal information that is collected, used or disclosed by Commonwealth Connects in the course of its activities.
Accountability
Commonwealth Connects is responsible for the personal information under its control and shall designate one or more persons who are accountable for its compliance with the principles outlined below.
The designated individual is the Project Executive/Manager, Commonwealth Connects, who can be contacted at:
The Commonwealth Secretariat
Marlborough House
Pall Mall
London
SW1Y 5HX
Commonwealth Connects has implemented policies and procedures to give effect to these principles, including:
a) implementing procedures to protect personal information and to oversee compliance;
b) establishing procedures to receive and respond to inquiries or complaints;
c) communicating to staff about its privacy policies and practices; and
d) providing public information to explain privacy policies and practices.
Commonwealth Connects is responsible for the personal information in its possession or control, including information that has been transferred to a third party for processing, and shall use appropriate means to provide a comparable level of protection while information is being processed by a third party (see below).
Identifying Purposes for Collection of Personal Information
Commonwealth Connects will always identify the purposes for which personal information is collected at or before the time the information is collected.
Commonwealth Connects will normally collect personal information only for the following purposes:
a) to establish and maintain contact with clients, users and members and to
provide ongoing service;
b) to develop and enhance the quality of information and services; or
c) to meet any legal requirements.
Unless required by law, Commonwealth Connects will not use or disclose, for any new purpose, personal information that has been collected without first identifying and documenting the new purpose and obtaining the consent of the individual.
Obtaining Consent
The knowledge and consent of the individual are required for the collection, use or disclosure of his/her personal information, except where required for legal or contractual purposes or in case of an emergency.
“Consent” means an individual’s voluntary agreement to the collection, use and disclosure of personal information for a defined purpose. Consent can be either express or implied and can be provided directly by the individual or by an authorized representative. In obtaining consent, Commonwealth Connects will use reasonable efforts to ensure that a customer or employee is advised of the identified purposes for which personal information will be used or disclosed. In determining the appropriate form of consent, Commonwealth Connects will take into account the sensitivity of the personal information and the reasonable expectations of the individuals involved.
Limiting the Collection of Personal Information
Commonwealth Connects will limit the collection of personal information to that which is necessary for the purposes identified by the individual., and shall only collect personal information by fair and lawful means.
Limiting Use, Disclosure and Retention of Personal Information
Commonwealth Connects will 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 by law, and will .retain personal information only as long as necessary for the fulfilment of the purposes for which it was collected.
Only employees or agents of Commonwealth Connects who require access for business reasons or whose duties reasonably so require will have access to personal information about individual users. Commonwealth Connects shall keep personal information only as long as it remains necessary or relevant for the identified purposes. Personal information that is no longer necessary or relevant for the identified purposes shall be destroyed, erased or made anonymous.
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 Commonwealth Connects shall be sufficiently accurate, complete and up-to-date to minimize he possibility that inappropriate information may be used to make a decision about an individual. Commonwealth Connects will update personal information about customers and employees as and when necessary to fulfil the identified purposes or upon notification by the individual.
Security Safeguards
Commonwealth Connects will protect personal information by security safeguards appropriate to the sensitivity of the information, including such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures.
Commonwealth Connects will take the necessary steps to 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. All employees with access to personal information shall be required as a condition of employment to respect the confidentiality of personal information.
Openness and Transparency
Commonwealth Connects will make readily available specific information about its policies and practices relating to the management and protection of personal information.
Access to Personal Information
Commonwealth Connects will inform an individual of the existence, use and disclosure of his or her personal information upon request and shall give the individual access to that information.
Normally, Commonwealth Connects will only collect and use personal information provided by the individual with his/her consent. The individual shall be able to amend the information as required.Upon request, Commonwealth Connects will provide an account of the use and disclosure of personal information.
Challenging Compliance
An individual can address a challenge concerning Commonwealth Connects’ compliance with the above principles to the designated person responsible for compliance.
Commonwealth Connects will maintain procedures for addressing and responding to all inquiries or complaints about the companies’ handling of personal information, and the existence of these procedures as well as the availability of complaint procedures shall be published on the Web site. The person or persons accountable for compliance may seek external advice where appropriate before providing a final response to individual complaints. Commonwealth Connects will investigate all complaints concerning compliance, and will take appropriate measures to resolve the complaint and advise the complainant of the outcome of the investigation.
** The principles above are consistent with, and their application provides equivalent levels of protection to, the national laws and standards applicable in member countries of the Commonwealth, including the provisions of the EC Privacy Directive.
