PRIVACY POLICY
PRIVACY POLICY
McCluskey Transportation is a leading transportation services provider operating in the private and public sectors across multiple Canadian jurisdictions. To facilitate the best service possible for its clients and customers, McCluskey Transportation must at times collect and maintain personal information.
The purpose of this Privacy Policy is to provide a transparent guide to McCluskey Transportation’s collection, use, protection, and disclosure of personal information.
Personal information refers to information about an identifiable individual, but does not include contact information related to that individual’s employment.
Unless otherwise noted, McCluskey Transportation refers to McCluskey Transportation and all its affiliated companies.
McCluskey Transportation is committed to protecting personal information. That commitment starts by complying with federal and provincial privacy laws, but goes farther, as McCluskey Transportation aims to apply leading privacy practices to its operations.
Accountability
McCluskey Transportation is accountable for the personal information it collects.
McCluskey Transportation has a Privacy Officer to manage its privacy obligations, whose responsibilities include:
- overseeing the development, review and revision of this Privacy Policy, and any supplemental policies and practices related to the protection of personal information;
- ensuring that employees and service providers comply with this Privacy Policy, and any supplemental policies and practices related to the protection of personal information; and
- responding to concerns or complaints relating to this Privacy Policy, any supplemental policies and practices related to the protection of personal information.
The Privacy Officer may be reached at:
Bea Nguyen
1857 Centre Avenue SE
Calgary, AB T2E 6L3
Collection of Personal Information: Purpose & Consent
McCluskey Transportation only collects personal information it requires to provide transportation services.
Accordingly McCluskey Transportation relies on customers’ implied consent for the collection and use of that information as permitted by law.
McCluskey Transportation collects information at the time of sale, including name, email address, physical address and telephone number, because it needs to know the identity of its customers, addresses for the provision of services, and contact information in case any change in the provision of services needs to be communicated.
McCluskey Transportation does not collect any personal information in providing transportation services on behalf of municipal or regional governments, except for certain information needed to provide health-related transportation assistance. That additional information is necessary in case of emergency and to ensure that any assistance-related requirements are known in advance.
McCluskey Transportation’s website uses Cookies, which track information given by a user or about a user’s activity on the website, to personalize the online experience and to save visitors time by recalling specific information on subsequent visits. Visitors to McCluskey Transportation’s website are able to accept or decline Cookies and are prompted to make that selection on accessing the website. For more information on McCluskey Transportation’s use of Cookies, please see our [Cookie Notice].
Customers may seek to withdraw their consent to the collection, use, or disclosure of personal information by contacting the appropriate McCluskey Transportation affiliate or the Privacy Officer. Subject to receiving such requests in a timely manner, and any overriding legal obligations, McCluskey Transportation will take steps to accommodate such requests. Withdrawal of consent prior to the provision of transportation services will negatively affect McCluskey Transportation’s ability to provide those services and may result in services not being provided.
When McCluskey Transportation provides student transportation services on behalf of school boards, it is similarly provided with information necessary to deliver those services, including: student names, addresses, phone numbers and (when needed) dietary and medical information, and photographs in the case of nonverbal students.
McCluskey Transportation does not collect information, including personal information, from any social media platform on which it is active.
Limiting Use, Disclosure, and Retention
In addition to limiting the personal information that is collected, McCluskey Transportation limits the use of that information, its disclosure and its retention.
Use
McCluskey Transportation limits the use of customers’ personal information to what is required to provide transportation services.
McCluskey Transportation does not use personal information for statistics or research, and does not sell, rent or lease that information to third parties.
Cookies used on McCluskey Transportation’s website simplify the process of recording and recalling information, such as contact information, billing and shipping addresses. For more information on McCluskey Transportation‘s use of Cookies, please see our [Cookie Notice].
Disclosure
McCluskey Transportation does not disclose personal information to third parties for any statistical or research use.
McCluskey Transportation and its affiliates do not share personal information with each other.
McCluskey Transportation will not disclose an individual’s personal information without notice to that individual or his or her consent, except in very limited circumstances and only as permitted or required by law, including when disclosure is in the individual’s interest and consent cannot be obtained in a timely way.
When McCluskey Transportation collects personal information in the course of acting as a service provider to federal and provincial governments, that information may be disclosed as required by that government and permitted by law.
Retention
In almost all cases, McCluskey Transportation retains personal information for a minimum of one year, and otherwise for so long as is necessary to facilitate the provision of transportation services.
McCluskey Transportation destroys any student personal information six months after completing the student transportation route to which the personal information relates or as per contractual agreement with our customer.
Safeguards
McCluskey Transportation has reasonable security arrangements in place commensurate with the sensitivity of the type of personal information collected in order to guard against unauthorized access, collection, use, disclosure and disposal of that information.
Storage
McCluskey Transportation collects customer information online and offline. When collected offline, the information is entered into an online database, and otherwise destroyed unless required for use by drivers.
For information stored electronically, McCluskey Transportation‘s data and data systems are physically situated in a tier 1 data centre in Alberta. Only McCluskey Transportation Information & Technology staff have physical access to the data centre. McCluskey Transportation’s data and data systems are otherwise protected by standard network access controls.
Physically recorded personal information is limited to the information that McCluskey Transportation drivers require during day-to-day operations.
When not in use by drivers, documents containing personal information are stored at local McCluskey Transportation offices, which are subject to standard physical access controls. Any extra copies of such documents are disposed of on a daily basis in secured document containers and destroyed on a monthly basis.
McCluskey Transportation does not retain copies of tickets bearing customers’ personal information.
McCluskey Transportation does not collect or store customer financial information. When information such as a credit card number is transmitted to other websites (third party points of sale), it is protected through the use of encryption, such as the Secure Socket Layer (SSL) protocol.
Training
All McCluskey Transportation employees receive privacy training upon employment, which includes review of:
- this Privacy Policy;
- employee obligations to ensure that personal information is protected; and
- employee obligations to report any access breach or suspected access breach of personal information to the Privacy Officer.
Drivers are specifically trained to ensure proper use, storage and disposal of documents containing customer and passenger personal information.
Incident Response
McCluskey Transportation has established a comprehensive IT Security Incident response plan setting forth processes and protocols for management and communications in the event of a security breach related to its collection, use, storage and disposal or disclosure of personal information. For details regarding McCluskey Transportation’s IT Security Incident response plan please contact the Privacy Officer.
Accuracy & Access
McCluskey Transportation aims to ensure the accuracy of personal information, but it relies on customers to provide accurate information.
Customers seeking to correct or update personal information are encouraged to contact the appropriate McCluskey Transportation affiliate by phone to correct any error or omission.
All contact information for various McCluskey Transportation affiliates is available at https://www.mccluskeytransportation.ca/contact-us/
Customers may also request access to their personal information in McCluskey Transportation’s control at any time through the access to information processes provided for under provincial and federal legislation.
Such inquiries may be made to the Privacy Officer.
In responding to any such request, McCluskey Transportation may seek to confirm the identity of the person requesting information, and any additional personal information collected in that process will be destroyed as soon as reasonably possible once that identity is confirmed.
Subject to any overriding legal obligations, McCluskey Transportation will provide customers with a description of what, if any, personal information it retains, the use it makes of that information and what, if any, disclosure has been made of it.
Updates
McCluskey Transportation will occasionally update this policy to reflect company and customer feedback, as well as developments in legislation and best practices.