Our Privacy Policy

Context

At Deep Bay Consulting Ltd (DBC), we are committed to providing our clients with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about them, protecting their personal information is one of our highest priorities. While we have always respected our client’s privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information. We will inform our clients of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Privacy Policy, in compliance with PIPA, the UK General Data Protection Regulation (UK-GDPR) and the Australian Privacy Principles (APPs), outlines the principles and practices we will follow in protecting clients’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of their personal information and allowing them to request access to, and correction of, their personal information.

Scope

This Privacy Policy applies to DBC and any service providers collecting, using or disclosing personal information on behalf of our company. This policy also applies to the processing of personal data of individuals located in the United Kingdom regardless of where the processing takes place, and to any act or practice relating to the personal information of an individual in Australia.

Definitions

Personal Data – For the purposes of this policy, Personal Data includes both Personal Information and Contact Information as defined below, when it relates to individuals in the UK or Australia.

Personal Information – means information about an identifiable individual (i.e. name, age, home address and phone number, social insurance number, marital status, religion, income, credit history, medical information, education, employment information). Personal information does not include contact information (described below).

Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by PIPA.

Privacy Officer – means the individual designated responsibility for ensuring that we comply with this policy, PIPA, UK-GDPR, and APPs.

Collecting Personal Information

Unless the purposes for collecting personal information are obvious and the client voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

• We will only collect client information that is necessary to fulfill the following purposes:
• To verify identity;
• To maintain contact information (name, company name, address, email address, phone number, etc);
• To identify or retain client preferences (i.e. cookies);
• To deliver requested products and services;
• To bill for products or services delivered;
• To meet regulatory requirements.

Consent

We will obtain client consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

For personal data collected from individuals in the UK and Australia, we will obtain explicit, freely given, specific, and informed consent. This means we will use clear, specific language and require a positive action from the individual to show their agreement. Pre-checked boxes or similar implied methods will not be used for UK or Australian data subjects.

For all other clients, consent can be provided in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting, using, or disclosing the personal information would be considered obvious and the client voluntarily provides personal information for that purpose. Consent may also be implied where a client is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products and the client does not opt-out.

Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients can withhold or withdraw their consent for DBC to use their personal information in certain ways. A client’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the client in making the decision.

We may collect, use or disclose personal information without the client’s knowledge or consent in the following limited circumstances:

• When the collection, use or disclosure of personal information is permitted or required by law;
• In an emergency that threatens an individual’s life, health, or personal security;
• When the personal information is available from a public source (e.g., a telephone directory);
• When we require legal advice from a lawyer;
• For the purposes of collecting a debt;
• To protect ourselves from fraud;
• To investigate an anticipated breach of an agreement or a contravention of law.

Using and Disclosing Personal Information

We will only use or disclose client personal information where necessary to fulfill the purposes identified at the time of collection. We will not use or disclose client personal information for any additional purpose unless we obtain consent to do so. We will not sell client lists or personal information to other parties.

We will not use or disclose personal information for direct marketing purposes unless consent is obtained, or an individual would reasonably expect their information to be used for this purpose. An easy-to-use opt-out mechanism will always be provided with every direct marketing communication.

Retaining Personal Information

If we use client personal information to make a decision that directly affects them, we will retain that personal information for at least one year so that they have a reasonable opportunity to request access to it. We will retain this client personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Ensuring Accuracy of Personal Information

We will make reasonable efforts to ensure that client personal information is accurate and complete where it may be used to make a decision about them or disclosed to another organization. Clients may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’ correction request in the file.

Securing Personal Information

We are committed to ensuring the security of client personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks. The following security measures will be followed to ensure that client personal information is appropriately protected:

• The use of user IDs, passwords, encryption;
• Restricting employee access to personal information as appropriate (need-to-know);
• Contractually requiring any service providers to provide comparable security measures.

We will use appropriate security measures when destroying client’s personal information such as shredding documents, or deleting electronically stored information. We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Providing Clients Access to Personal Information and Expanded Rights

Clients have a right to access their personal information, subject to limited exceptions. A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer. Upon request, we will also tell clients how we use their personal information and to whom it has been disclosed if applicable.

We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request. A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client of the cost and request further direction from the client on whether or not we should proceed with the request. If a request is refused in full or in part, we will notify the client in writing, providing the reasons for refusal and the recourse available to them.

For individuals in the UK and Australia, we also recognize the following rights:

• The right to be forgotten (erasure): The right to request the deletion or removal of personal data where there is no compelling reason for its continued processing.
• The right to data portability: The right to obtain and reuse your personal data for your own purposes across different services.
• The right to object: The right to object to the processing of your personal data in certain circumstances.
• The right to restrict processing: The right to block or suppress the processing of your personal data.
• The right to rectification: The right to have inaccurate personal data corrected.

For individuals in Australia, where it is lawful and practicable, you have the option of dealing with us anonymously or using a pseudonym.

Data Breach Notification

In the event of a personal data breach affecting individuals in the UK, we will notify the Information Commissioner’s Office (ICO) within 72 hours of becoming aware of the breach, unless the breach is unlikely to result in a risk to the rights and freedoms of natural persons.

For a data breach affecting individuals in Australia, we will notify the Australian Information Commissioner (OAIC) and affected individuals of all eligible data breaches. An eligible data breach occurs where there is unauthorized access, use, or disclosure of personal information that is likely to result in serious harm to an individual.

International Data Transfers

When we transfer personal information to an overseas recipient, we will take reasonable steps to ensure that:

• the transfer is a “restricted transfer” as defined by the UK-GDPR and that it is protected by appropriate safeguards, or
• the recipient handles the information in a way that is consistent with the Australian Privacy Principles. We remain accountable for any acts or practices of the overseas recipient that would breach the APPs.

Questions and Compliants

This policy was last reviewed and updated on September 20, 2025.