Last modified: March 9, 2021
FPDI supports the development of capacity within First Nations, and assists in addressing training and employment barriers to increase First Nation members’ (each, a “Sub-Agreement Holder“) participation in the labour market by developing and delivering programs and services designed to assist Sub-Agreement Holders at the community level. These, and such other training activities and other products and services as may be provided by FPDI, from time to time, including the FPDI website www.fdpinc.ca (our “Site“), are collectively referred to as the “FPDI Services“.
This Policy describes how we collect, use, disclose, and protect the personal information we receive from users of the FPDI Services (collectively referred to herein as “you“), including general public users of our Site.
Privacy laws in Canada generally define “personal information” as any information about an identifiable individual, which includes information that can be used on its own or with other information to identify, contact, or locate a single person. Personal information does not include business contact information, including your name, title, or business contact information.
We will collect, use and disclose personal information in accordance with this Policy, unless otherwise required by applicable law. We take reasonable steps to ensure that any personal information we collect about you is adequate, relevant, not excessive, and used for limited purposes.
This Policy does not apply to personal information collected outside the FPDI Services or by any third party, including information collected through an application or content that may link to or be accessible from or on our Site.
Please read this Policy carefully to understand our policies and practices for collecting, processing, and storing personal information. By accessing or using the FPDI Services, you indicate that you understand, accept, and consent to the practices described in this Policy.
1.2 INFORMATION WE COLLECT ABOUT YOU
We collect and use several types of information from and about you, including:
- Personal information, that we can reasonably use to directly or indirectly identify you, which may include your: Social insurance number; name; date of birth; gender; Indigenous group; marital status; number of dependents; language(s) spoken; disability; address; Indigenous Skills and Employment Training agreement – First Nations Distinct Funding Agreement number; highest level of education; employment information; social assistance or employment insurance information; client status; action plan start date, end date and result; intervention start date, end date, outcome, code, and related National Occupational Classification; employment results; return to school results; Internet protocol (IP) address used to connect your computer to the Internet, user name or other similar identifier, account and log-in information, and any other identifier we may use to contact you; and information collected from FPDI’s employees and independent contractors for the purposes of administering our relationship with them (“personal information“).
- Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an identifiable individual, such as demographic information, or statistical or aggregated information. Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users participating in a certain program or accessing a specific feature on our Site.
- Technical information, including your login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform, or information about your internet connection, the equipment you use to access our Site, and usage details.
- Non-personal details about your interactions with our Site, including the full Uniform Resource Locators (URLs), clickstream to, through and from our Site (including date and time), information you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or any phone number used to contact us.
1.3 HOW WE COLLECT INFORMATION ABOUT YOU
We use different methods to collect your information, including through:
- INFORMATION YOU PROVIDE TO US, for example, by:
- Filling in forms, online polls, or questionnaires.
- Registering for an account, program, or services.
Corresponding with us by phone, email, or otherwise. Records of correspondence, including copies of emails, may be kept by FPDI to assist us in delivering our programs and services to you.
- Providing information for us to publish or display on public Site areas (hereinafter, “posted” or “posting”) or to transmit to other Site users or third parties (collectively, “User Contributions“), as and when such features are made available from time to time. Any User Contributions are posted and transmitted to others at your own risk. FPDI cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that unauthorized persons will not view your User Contributions.
- Details of your visits to our Site, including traffic data, and other communication data and the resources that you access and use on the Site.
- Information about your computer and internet connection, including your IP address, operating system, and browser type.
The information we collect automatically is statistical data. It helps us to improve our Site and to deliver a better and more personalized service, including by enabling us to estimate our audience size and usage patterns, store information about your preferences, and recognize you when you return to our Site.
The technologies we use for this automatic data collection may include:
- Web Beacons. Web beacons (also known as pixel tags, Internet tags, clear GIFs, or single-pixel GIFs) are electronic images embedded into a Web page. Web Beacons permit an organization to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
- THIRD PARTIES, including:
- Service providers who deliver training programs or are engaged for specific projects or services as part of FPDI’s programs. Where FPDI engages a service provider to collect or manage personal information on our behalf (either directly or indirectly) for a specific project, we will explain to you (in this Policy or otherwise) what personal information we are collecting, for what purposes it is being collected, and with whom that information will be shared (if anyone). Service providers who collect or manage personal information on FPDI’s behalf are contractually obligated to keep personal information confidential, collect it only for the purposes for which we have engaged them, and to process the personal information with the same standards set out in this Policy. FPDI remains responsible for any personal information collected for us by service providers, as set out in this Policy.
- Sub-Agreement Holders who collect information about individuals through surveys, forms or other means, with the individual’s consent. This may include, for example, information collected for general statistics and reporting as part of the Accountability and Resource Management System (“ARMS“), information about individuals collected as part of a special project, such as a labour market or other surveys, or other programs, as may be implemented from time to time.
- the Government of Canada (“Canada”), via Canada’s EIBIS/ LMDA web-based access portal, in order to determine entitlements to benefits an individual may have under various programs.
A NOTE ABOUT THIRD PARTY TRACKING TECHNOLOGIES
We do not control these third parties’ tracking technologies or how they are used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
To learn more about online behavioural advertising and how to stop websites from placing cookies on your device, you can access materials and information provided by the Digital Advertising Alliance of Canada or the Network Advertising Initiative.
1.4 USE OF YOUR INFORMATION
We may use information that we collect about you or that you provide to us, including any personal information:
- To present our Site and its contents to you.
- To provide the FPDI Services, including providing you with information or services that you request from us.
- To fulfill the purposes for which you provided the information or that were described when it was collected, or any other purpose for which you provide it.
- To carry out our obligations and enforce our rights arising from any contracts with you. • To notify you about changes to the FPDI Services, including changes to our Site.
- To improve the FPDI Services, including our Site, communications, client relationships and experiences.
- To allow you to participate in interactive or similar features on our Site, such as a member or Sub Agreement Holder portal, as such features may be made available from time to time.
- In any other way we may describe when you provide the information.
- For any other purpose with your consent.
If you are a Sub-Agreement Holder, we may also use your information to provide you with information related to the FPDI Services, including programming, educational and employment opportunities available in a particular geographic location that may be of interest to you, as permitted by law. If you do not want us to use your information in this way, please use the unsubscribe mechanism at the bottom of our e-mails or contact us for more information, see Choices About How We Use and Disclose Your Information.
1.5 DISCLOSURE OF YOUR INFORMATION
We may disclose personal information that we collect or you provide as described in this Policy:
- To provide the FPDI Services.
- In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of FPDI’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by FPDI about our Sub-Agreement Holders, clients, individual program participants, and users is among the assets transferred.
- To Canada, in order for Canada to:
- Measure the results of the Indigenous Skills and Employment Training Program First Nations Distinction Funding Agreement (the “ISET Agreement“) and evaluate the ISET Agreement’s success;
- Evaluate the success of any program in achieving its objectives; and
- Meet FPDI’s obligation of accountability by reporting on the results of the program and its success in achieving its objectives.
Information, when provided to Canada, is administered in accordance with the Privacy Act (RSC, 1985, c P 21), the Department of Employment and Social Development Canada Act (SC 2005, c 34) and the Access to Information Act (RSC, 1985, c A-1)]
- To Sub-Agreement Holders, to provide the activities set out in our agreements with those Sub-Agreement Holders, or to otherwise meet our obligations to Sub-Agreement Holders and their participants, as part of our provision of FPDI Services.
- To fulfill the purpose for which you provide it.
- For any other purpose disclosed by us when you provide the information.
- With your consent.
We may also disclose your personal information:
- To comply with any court order, law, or legal process, including to respond to any government or regulatory request, in accordance with applicable law.
- If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of FPDI, our clients, or others.
1.6 TRANSFERRING YOUR PERSONAL INFORMATION
We may transfer limited personal information that we collect or that you provide as described in this Policy to contractors, service providers, and other third parties we use to support the FPDI Services (such as analytics and search engine providers that assist us with Site improvement and optimization) and who are contractually obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them, and to process the personal information with the same standards set out in this Policy.
We may process, store, and transfer your personal information in and to a foreign country, with different privacy laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts, law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and security standards adhere to this Policy and applicable Canadian privacy legislation.
You are welcome to contact us to obtain further information about FPDI policies regarding service providers outside of Canada. See Contact Information.
By submitting your personal information to us or engaging with the FPDI Services, you consent to this transfer, storage, or processing.
1.7 CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION
We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:
- Programming Information from FPDI. If you have opted in to receive certain emails from us but no longer wish to have your contact information used by FPDI to provide information about educational, employment, or other programming opportunities we think may be of interest to you, you can opt-out by contacting us stating your request. If we have sent you a general informational email, you may unsubscribe by clicking the unsubscribe link we have included in the email. This opt-out does not apply to information provided by FPDI as part of its requirements under an agreement with you.
- Information Used and Disclosed as part of the FPDI Services, generally. When it comes to the FPDI Services, generally, FPDI may have certain contractual obligations relating to the use and disclosure of personal information you have provided to us, as described in this Policy. If you wish to have more information about FPDI’s privacy practices and your choices related to how we use and disclose your information as part of the FPDI Services, please contact us at the information provided below in the Contact Information section.
1.8 DATA SECURITY
The security of your personal information is very important to us. We use physical, electronic, and administrative measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. We store all information you provide to us in compliance with policies, procedures and guidelines described in this Policy and our other contractual obligations.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, as such functionality is offered from time to time, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.
Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.
1.9 DATA RETENTION
Except as otherwise permitted or required by applicable law or regulation, we will retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. This includes personal information collected under an ISET Agreement, which will be maintained in accordance with the terms of that agreement.
Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose under FPDI’s mandate without further notice to you or your consent.
1.10 CHILDREN UNDER THE AGE OF 13
We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Site or on or through any of its features. If we learn we have collected or received personal information from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any personal information from or about a child under 13, please contact us.
1.11 ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes. By law you have the right to request access to and to correct the personal information that we hold about you. We will provide access to your personal information, subject to exceptions set out in applicable privacy legislation.
If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also contact us to request access to, correct, or delete any personal information that you have provided to us. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
If you are concerned about our response or would like to correct the information provided, you may contact our Privacy Officer.
1.12 WITHDRAWING YOUR CONSENT
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, please contact us. Please note that if you withdraw your consent we may not be able to provide you with particular services. We will explain the impact to you at the time to help you with your decision.
This Policy may change from time to time. Changes we make to this Policy will be posted on this page. If we make material changes to how we treat our users’ personal information, we may notify you by email or through a notice on the Site home page. We include the date the Policy was last revised at the top of this Policy. You are responsible for periodically visiting our Site and this Policy to check for any changes. Your continued use of the FPDI Services after such notice constitutes your acceptance of such changes.
1.14 CONTACT INFORMATION
If you have any questions about this Policy and FPDI’s privacy practices, please contact us.
We have procedures in place to receive and respond to complaints or inquiries about our handling of personal information, our compliance with this Policy, and with applicable privacy laws. To discuss our compliance with this Policy please contact our Privacy Officer using the contact information listed above.