• Why do we collect it?
• How do we collect it?
• What do we use it for?
• Where do we keep it
• How is it secured?
• Who has access to or uses it?
• To whom is it disclosed?
• When is it disposed of?
BestLifeRewarded Innovations Data Retention Policy:
BLRi will record and retain member information for a minimum of two (2) years after the expiration or termination of the member account, the notice provided to, and the written, electronic or verbal consent obtained from, members regarding the collection, use, disclosure and retention of member's Personal Information;
• 24/7 uniformed security, CCTV, door entry-card access, front door “mantrap” for controlled entry.
• 25 diverse points of entry for Fibre
• 2 incoming 13.8kV feeds (one active and one is fully redundant).
• 25 diesel generators for backup power
• Enwave” for cooling using Toronto’s deep-water cooling system.
• 4 diesel fuel storage units holding 44 thousand gallons of fuel.
Implementation of an Offsite Data Backup Solution with Encryption and ‘Versioning’
• Offsite data backup solution is imperative for organizations that handle critical data. With the implementation of a data backup solution that includes ‘versioning’, data ‘snapshots’ (i.e. the set of files at defined points in time, e.g. the end of each day). The technologies utilized for backup consist of Rsync and SSH. Rsync allows for fast bit-level backups that allow for identical copies of data to be created quickly and efficiently.
• BLRi does not store Member Personal Information on any portable computer devices or media including, without limitation, laptop computers, removable hard disks, USB, mobile phones, and the like unless the Member Personal Information is encrypted; BLRi agrees to assist the Member in fulfilling Individuals’ rights of access, amendment, accounting and deletion of their Personal Information;
BLRi will not disclose Personal Information to third parties, other than disclosures made on a need to know basis as required to perform the Services to BLRi authorized employees, agents and subcontractors, unless: (a) BLRi has received prior written authorization from the Member (or client); or (b) such disclosure is required by law, in which case BLRi shall immediately notify the client in writing of any subpoena or other court or administrative order or proceeding or other request seeking access to or disclosure of Personal Information; provided, further,
• BLRi shall use its best efforts to limit the nature and scope of the required disclosure and will only disclose the minimum amount of Personal Information necessary to comply with law;
BLRi will not disclose Member Personal Information to the client unless BLRi has received prior written authorization from the Member (or through the client consent process, respecting PIPEDIA);
• BLRi will grant clients the right to audit BLRi’s business processes and practices that involve the collection, use, disclosure or retention of Personal Information in relation to the Services rendered under this Agreement. BLRi shall fully cooperate with any such audit. In the event that any such audit reveals material gaps or weaknesses in BLRi’s security program, BLRi will work to resolve the issues in accordance with PIPEDA;
• BLRi will provide to the client or Member, and as otherwise required by law, oral notice within 24 hours of discovery followed by prompt written notice of all real or suspected security incidents that involve, or which BLRi reasonably believes involve, the unauthorized access, use or disclosure of Personal Information; provided, further, such notice shall summarize in reasonable detail the impact on the client or Member of the breach or unauthorized use or disclosure of, or access to, Personal Information and the corrective action taken or to be taken by BLRi.
Upon Member termination or revoking access, BLRi will de-identify Member Personal Information. Specifically, within 24 hrs of a Member revoking access and requesting termination to the BestLifeRewarded portal, the following process will occur:
Data is wiped from the hard-drive and back up systems using a Permanent Erase Program.
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