Wolters Kluwer Limited (“Wolters Kluwer”) has a practice of protecting the privacy and security of customer, author and employee records. We are committed to meeting our obligations under Canadian data privacy laws, including the Personal Information Protection and Electronic Documents Act and applicable provincial laws. We adhere to the privacy principles set out below that govern the way we collect, use, store and disclose personal information, which is obtained in the course of development, sales, promotion and distribution of our products or in the course of employment.
“Personal Information” as used in this policy means any information about an identifiable person including employee records and customer and author information, such as name and contact information.
Policy for the Protection of Personal Information
We will collect, use, store and disclose Personal Information in accordance with the following privacy principles:
We are responsible for Personal Information in our possession or custody, including Personal Information that we may transfer to third parties for processing. We will require our service providers to agree to contractual requirements that are consistent with our privacy and security policies. We will require that our service providers are prohibited from using Personal Information except for the specific purpose for which we supply it to them.
2. Identifying Purposes
Either before or at the time of collection, we will identify the purposes for which we plan to use the Personal Information. Depending upon the way in which the Personal Information is collected, this can be done orally or in writing. Wolters Kluwer may use the information we collect for the following purposes:
- To ship products or provide services to our customers
- To provide customers access to Wolters Kluwer Internet products
- To respond to customer inquiries about accounts and other services
- To understand our customers, and prospective customers’ needs and to offer products and services to meet those needs
- To conduct credit checks on customers or prospective customers
- To meet legal requirements
Unless required by law, we will not use Personal Information for a new purpose without the knowledge and consent of the individual to whom the information relates.
Wolters Kluwer websites use “cookies.” A cookie is a small text file that’s stored on your computing device when you visit a website that retains information about your actions or preferences.
- To save our customers from having to re-enter information
- To allow our customers to access their stored information
- To compile anonymous and aggregated statistics to help us improve the structure of our websites
- To help us recognize customers and allow us to tailor content to match their preferred interests
Wolters Kluwer uses Google AdWords
- You may set preferences to control how Google advertises to you using the Google Ad Preferences page, and if you wish, you may opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.
Personal Information will only be collected, used or disclosed with the consent of the individual, except in certain circumstances permitted or required by law. The way in which we seek consent may vary depending upon the sensitivity of the information. We will obtain consent in all cases where the Personal Information involved is considered sensitive, such as income or health information.
Typically, we will seek consent for the use or disclosure of Personal Information at the time of collection. However, additional consent will be sought after the Personal Information has been collected if it is required for a new purpose.
In certain circumstances, obtaining consent would be inappropriate. The federal Personal Information Protection and Electronic Documents Act and provincial privacy laws provide for exceptions where it is impossible or impractical to obtain consent.
5. Limiting Collection
We will collect Personal Information by fair and lawful means and will limit the amount and type of Personal Information we collect to that which is necessary for our identified purposes.
6. Limiting Use, Disclosure and Retention
We 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. Wolters Kluwer does not sell and/or trade customer lists to selected third-party companies and organizations. Wolters Kluwer may provide a customer list to a third party for the purposes of research and development. Subject to any applicable business, legal or regulatory requirements, we will ensure that the data is destroyed in a secure manner, erased or made anonymous.
7. Affiliates With Whom We Share Information
Wolters Kluwer may provide personal information to affiliates. Our affiliates are the family of companies that form Wolters Kluwer nv, including CCH Incorporated, Aspen Publishers Inc., CCH – Legal Information Services and Bankers System Inc. A complete list of our affiliates is available on the Wolters Kluwer website at www.wolterskluwer.com.
We will use our best efforts to ensure that Personal Information that is used on an ongoing basis and information that is used to make a decision about an individual is as accurate, complete and up to date as necessary for the purpose for which it is to be used.
We will protect Personal Information with safeguards appropriate to the level of sensitivity of the information. Our safeguards protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We will exercise care in the disposal or destruction of Personal Information to prevent unauthorized parties from gaining access to the information. Our methods of protection include physical measures (for example, locked file storage and restricted access to offices), organizational measures (for example, security clearances and limiting access on a need-to-know basis) and technological measures (for example, the use of passwords and encryption). We also require our outside service providers to provide a comparable level of protection to Personal Information that we may supply to them.
10. Transfer of Information Outside of Canada
Wolters Kluwer, our affiliates and our third-party partners to whom we disclose information under this policy may perform certain activities outside of Canada. As a result, your personal information may be collected, used, stored and processed in other countries. Your information will be subject to the laws of those countries and may be disclosed in response to valid demands or requests from government authorities, courts or law enforcement. By providing us with your personal information, you consent to the potential transfer of your information outside of Canada.
11. The General Data Protection Regulation
To protect the personal data of individuals and customers in the European Union and to keep up with everchanging technology, as per the May 25, 2018 the General Data Protection Regulation (GDPR) will come into effect. The GDPR impacts every organization which stores or processes personal data of individuals across the European Union. The GDPR aims to strengthen the rights of individuals over their personal data and creates a harmonized personal data protection standard.
As a trusted partner to professionals, we want our customers to be confident that their personal data is protected. Consistent with the Wolters Kluwer company values and business principles, data privacy is at the heart of our approach to the GDPR. We fully understand the importance of data privacy standards to our customers and we recognize the obligations that apply to managing, storing and processing personal data. At Wolters Kluwer, we are committed to protecting our customers’ personal data. We deliver on this promise by striving to keep information secure and respecting the rights of individuals.
With the Wolters Kluwer Corporate Privacy Office, we are fully engaged in a cross-functional GDPR program. We are reviewing data processes (policies, standards and documentation) and practices throughout our company and are implementing changes to further enhance protection of personal data. We are training our employees on their responsibilities and new ways of working related to GDPR; we are partnering with third parties and vendors to ensure their compliance; and we are assessing customer contracts and working with our customers to help to support them.
Upon written request, we will inform an individual of the existence, use and disclosure of his or her Personal Information and give him or her reasonable access to that information. We may deny access for legally permissible reasons such as situations where the information is prohibitively costly to provide, if it contains references to other individuals, or where it cannot be disclosed for legal, security or commercial proprietary reasons. We will advise the individual of any reason for denying an access request.
When an individual successfully demonstrates the inaccuracy or incompleteness of Personal Information held by us, we will correct or update the information as required.
Wolters Kluwer may revise this policy. You agree to be bound by any such revisions and should therefore periodically visit this policy to determine the current terms to which you are bound.
Filing Inquiries and Complaints
We will investigate all written complaints and respond to all written inquiries. If we find a complaint to be justified, we will take appropriate measures to resolve it.
To file an opt-out request, request access to your information, report incorrect information, file a complaint, please write to:
The Privacy Officer
Wolters Kluwer Limited
300 – 90 Sheppard Avenue East
Toronto ON M2N 6X1
Fax: (416) 224-1067
This policy was last updated on May 25th 2018.