Privacy Policy

Compensation Governance Partners (“CGP”) is committed to the privacy and transparency of our information practices. Our policies and practices with respect to the collection, use, disclosure and processing of personal information, as defined under applicable Canadian laws, are contained within this notice, and apply to CGP and anyone providing services on behalf of CGP.

The nature and integrity of our business is fundamental to handling the personal information we collect through our services, and online via our website and other mediums with the utmost confidentiality. We will not sell or give out personal information or e-mail addresses to any third party without your explicit consent.

Collection and Use of Personal Information

CGP collects only the personal information that it requires to provide the services for which it has been retained by a client.  This may include:

  • information about the compensation offered or provided by organizations to particular individuals;

  • information about performance assessments of individuals by organizations; and

  • other related information.

CGP normally collects personal information directly from its clients.  CGP will collect and use this personal information for the purpose of providing services to the client in accordance with the applicable engagement letter and work plan, or as otherwise agreed between CGP and its client (the “Agreement”).

CGP may also retain the personal information and use it in aggregate form for the purposes of improving CGP’s services and advice, generally.  CGP will not disclose this information to any third party in a manner which allows or might reasonably be considered to allow particular individuals to be identified, except as noted below.

Disclosure of Personal Information

CGP may disclose personal information as follows:

  • as expressly provided in the applicable Agreement;

  • to third-party service providers or agents who provide services to or on behalf of CGP, as further detailed below;

  • to law enforcement agencies for the purposes of investigating fraud or other offences, in connection with the prevention or investigation of suspected fraudulent activities or harm to individuals or property, to establish or exercise our legal rights or defend against legal claims, or in connection with an emergency that warrants use or disclosure of the information;

  • to regulatory authorities, as required or permitted by applicable law;

  • to legal, financial, insurance, and other advisors or in connection with the sale, reorganization, or management of all or part of its business or operations; and

  • as consented to by the individual from time to time, including to fulfill any other purposes that are identified when the personal information is collected.

CGP will not use or disclose personal information for purposes other than those for which it was collected, except with the individual’s consent or as required or permitted by law.  Consent may be express or implied, and given in writing, including by using or not using a check-off box, electronically, orally, or by the individual’s conduct, such as use of the services or products.

Storage and Processing of Data

CGP makes use of third-party service providers to store and process data, including personal information, on its behalf.  Neither CGP, its service providers, or its agents use servers or other facilities located in the United States of America for this purpose.  When acting on CGP’s behalf, such service providers and agents are only authorized to collect, use, or disclose personal information as described in this Privacy Policy. 

Security

CGP protects against the loss, misuse, and alteration of personal information with security measures appropriate to the sensitivity of the information, including through the use of physical, organizational, and technological measures and appropriate training of employees.

Data exchanged and stored by CGP is encrypted at rest and in transit, using several strong encryption protocols, and technologies that include Transport Layer Security/Secure Sockets Layer (TLS/SSL), Internet Protocol Security (IPSec), and Advanced Encryption Standard (AES).

Complaints

Any individual may contact the Privacy Officer, using the contact information provided below, to modify or correct any of his or her personal information that is under CGP’s control.  Any individual may also direct a written complaint regarding compliance with this Privacy Policy to the Privacy Officer and, within a reasonable time upon receiving the written complaint, the Privacy Officer will conduct an investigation into the matter. Within a reasonable time of concluding the investigation, the Privacy Officer will respond to the complaint and, if appropriate, CGP will take appropriate measures necessary to rectify the source of the complaint.

CONTACT

For any questions regarding this Privacy Policy or CGP’s policies and practices on the collection, use, disclosure, processes or storage of personal information, please contact us at:

Compensation Governance Partners
Attention: Privacy Officer
Address: 330 Bay St., Suite 1102, Toronto, Ontario, M5H 2S8
Email: privacy@compgovpartners.com
Telephone: 647.484.7222 ext. 110

Last modified: April 2023