Privacy Policy

Last modified: March 9, 2021 

1.1 INTRODUCTION

First Peoples Development Inc. (“FPDI“, “us” or “we“) respects your privacy and is committed to protecting it by  complying with this Privacy Policy (the “Policy“). 

FPDI supports the development of capacity within First Nations, and assists in addressing training and employment  barriers to increase First Nation members’ (each, a “Sub-Agreement Holder“) participation in the labour market by  developing and delivering programs and services designed to assist Sub-Agreement Holders at the community  level. These, and such other training activities and other products and services as may be provided by FPDI, from  time to time, including the FPDI website www.fdpinc.ca (our “Site“), are collectively referred to as the “FPDI  Services“.  

This Policy describes how we collect, use, disclose, and protect the personal information we receive from users of  the FPDI Services (collectively referred to herein as “you“), including general public users of our Site. 

Privacy laws in Canada generally define “personal information” as any information about an identifiable individual,  which includes information that can be used on its own or with other information to identify, contact, or locate a  single person. Personal information does not include business contact information, including your name, title, or  business contact information. 

We will collect, use and disclose personal information in accordance with this Policy, unless otherwise required by  applicable law. We take reasonable steps to ensure that any personal information we collect about you is  adequate, relevant, not excessive, and used for limited purposes. 

This Policy does not apply to personal information collected outside the FPDI Services or by any third party,  including information collected through an application or content that may link to or be accessible from or on our  Site. 

Please read this Policy carefully to understand our policies and practices for collecting, processing, and storing  personal information. By accessing or using the FPDI Services, you indicate that you understand, accept, and  consent to the practices described in this Policy.  

1.2 INFORMATION WE COLLECT ABOUT YOU 

We collect and use several types of information from and about you, including: 

  • Personal information, that we can reasonably use to directly or indirectly identify you, which may include  your: Social insurance number; name; date of birth; gender; Indigenous group; marital status; number of  dependents; language(s) spoken; disability; address; Indigenous Skills and Employment Training  agreement – First Nations Distinct Funding Agreement number; highest level of education; employment  information; social assistance or employment insurance information; client status; action plan start date,  end date and result; intervention start date, end date, outcome, code, and related National Occupational  Classification; employment results; return to school results; Internet protocol (IP) address used to connect  your computer to the Internet, user name or other similar identifier, account and log-in information, and  any other identifier we may use to contact you; and information collected from FPDI’s employees and  independent contractors for the purposes of administering our relationship with them (“personal  information“). 
  • Non-personal information, that does not directly or indirectly reveal your identity or directly relate to an  identifiable individual, such as demographic information, or statistical or aggregated information.  Statistical or aggregated data does not directly identify a specific person, but we may derive non-personal  statistical or aggregated data from personal information. For example, we may aggregate personal information to calculate the percentage of users participating in a certain program or accessing a specific  feature on our Site.  
  • Technical information, including your login information, browser type and version, time zone setting,  browser plug-in types and versions, operating system and platform, or information about your internet  connection, the equipment you use to access our Site, and usage details. 
  • Non-personal details about your interactions with our Site, including the full Uniform Resource Locators  (URLs), clickstream to, through and from our Site (including date and time), information you viewed or  searched for, page response times, download errors, length of visits to certain pages, page interaction  information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, or  any phone number used to contact us. 

1.3 HOW WE COLLECT INFORMATION ABOUT YOU 

We use different methods to collect your information, including through: 

  • INFORMATION YOU PROVIDE TO US, for example, by: 
    • Filling in forms, online polls, or questionnaires. 
    • Registering for an account, program, or services. 
      Corresponding with us by phone, email, or otherwise. Records of correspondence, including copies of  emails, may be kept by FPDI to assist us in delivering our programs and services to you. 
    • Providing information for us to publish or display on public Site areas (hereinafter, “posted” or  “posting”) or to transmit to other Site users or third parties (collectively, “User Contributions“), as and when such features are made available from time to time. Any User Contributions are posted and  transmitted to others at your own risk. FPDI cannot control the actions of other users of the Site with  whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee  that unauthorized persons will not view your User Contributions. 
  • AUTOMATED TECHNOLOGIES OR INTERACTIONS. As you navigate through and interact with our Site, we  may use cookies or other automatic data collection technologies to collect certain information about your  equipment, browsing actions, and patterns, including: 
    • Details of your visits to our Site, including traffic data, and other communication data and the  resources that you access and use on the Site. 
    • Information about your computer and internet connection, including your IP address, operating  system, and browser type. 

The information we collect automatically is statistical data. It helps us to improve our Site and to deliver a  better and more personalized service, including by enabling us to estimate our audience size and usage  patterns, store information about your preferences, and recognize you when you return to our Site. 

The technologies we use for this automatic data collection may include: 

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer or  stored temporarily in your computer’s memory. You may refuse to accept browser cookies by  activating the appropriate setting on your browser. However, if you select this setting you may be  unable to access certain parts of our Site. Unless you have adjusted your browser setting so that it  will refuse cookies, our system will issue cookies when you direct your browser to our Site.  
  • Web Beacons. Web beacons (also known as pixel tags, Internet tags, clear GIFs, or single-pixel GIFs)  are electronic images embedded into a Web page. Web Beacons permit an organization to count  users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server  integrity). 
  • THIRD PARTIES, including: 
    • Service providers who deliver training programs or are engaged for specific projects or services as  part of FPDI’s programs. Where FPDI engages a service provider to collect or manage personal  information on our behalf (either directly or indirectly) for a specific project, we will explain to you (in  this Policy or otherwise) what personal information we are collecting, for what purposes it is being  collected, and with whom that information will be shared (if anyone). Service providers who collect or  manage personal information on FPDI’s behalf are contractually obligated to keep personal  information confidential, collect it only for the purposes for which we have engaged them, and to  process the personal information with the same standards set out in this Policy. FPDI remains responsible for any personal information collected for us by service providers, as set out in this Policy. 
    • Sub-Agreement Holders who collect information about individuals through surveys, forms or other  means, with the individual’s consent. This may include, for example, information collected for general  statistics and reporting as part of the Accountability and Resource Management System (“ARMS“),  information about individuals collected as part of a special project, such as a labour market or other  surveys, or other programs, as may be implemented from time to time. 
    • the Government of Canada (“Canada”), via Canada’s EIBIS/ LMDA web-based access portal, in order  to determine entitlements to benefits an individual may have under various programs. 

A NOTE ABOUT THIRD PARTY TRACKING TECHNOLOGIES  

At times we may provide links or content through the FPDI Services that is hosted or served by third parties. These  may include, for instance, instructional videos such as the ARMS or Annual Operational Planning training videos  hosted by YouTube, or the FPDI facebook page, which we use to communicate information about our organization  and activities. These third-party websites may include advertisements or other content produced or distributed by  third parties. These third parties may use cookies or other tracking technologies to collect information about you  when you use their services. They may collect information, including personal information, about your online  activities over time and across different websites and other online services and may use this information to  provide you with interest-based (behavioural) advertising or other targeted content, on other platforms.  

We do not control these third parties’ tracking technologies or how they are used. If you have any questions about  an advertisement or other targeted content, you should contact the responsible provider directly. 

To learn more about online behavioural advertising and how to stop websites from placing cookies on your device,  you can access materials and information provided by the Digital Advertising Alliance of Canada or the Network  Advertising Initiative.  

1.4 USE OF YOUR INFORMATION 

We may use information that we collect about you or that you provide to us, including any personal information:

  • To present our Site and its contents to you. 
  • To provide the FPDI Services, including providing you with information or services that you request from  us. 
  • To fulfill the purposes for which you provided the information or that were described when it was  collected, or any other purpose for which you provide it. 
  • To carry out our obligations and enforce our rights arising from any contracts with you. • To notify you about changes to the FPDI Services, including changes to our Site. 
  • To improve the FPDI Services, including our Site, communications, client relationships and experiences.
  • To allow you to participate in interactive or similar features on our Site, such as a member or Sub Agreement Holder portal, as such features may be made available from time to time. 
  • In any other way we may describe when you provide the information. 
  • For any other purpose with your consent. 

If you are a Sub-Agreement Holder, we may also use your information to provide you with information related to  the FPDI Services, including programming, educational and employment opportunities available in a particular  geographic location that may be of interest to you, as permitted by law. If you do not want us to use your  information in this way, please use the unsubscribe mechanism at the bottom of our e-mails or e-mail us at  enquire@fpdinc.ca for more information, see Choices About How We Use and Disclose Your Information. 

1.5 DISCLOSURE OF YOUR INFORMATION 

We may disclose personal information that we collect or you provide as described in this Policy:

  • To provide the FPDI Services.
  • In accordance with applicable law, to a buyer or other successor in the event of a merger, divestiture,  restructuring, reorganization, dissolution, or other sale or transfer of some or all of FPDI’s assets, whether  as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal  information held by FPDI about our Sub-Agreement Holders, clients, individual program participants, and  users is among the assets transferred. 
  • To Canada, in order for Canada to: 
  • Measure the results of the Indigenous Skills and Employment Training Program First Nations  Distinction Funding Agreement (the “ISET Agreement“) and evaluate the ISET Agreement’s success; 
  • Evaluate the success of any program in achieving its objectives; and 
  • Meet FPDI’s obligation of accountability by reporting on the results of the program and its success in  achieving its objectives. 

    Information, when provided to Canada, is administered in accordance with the Privacy Act (RSC, 1985, c P 21), the Department of Employment and Social Development Canada Act (SC 2005, c 34) and the Access to  Information Act (RSC, 1985, c A-1)] 
  • To Sub-Agreement Holders, to provide the activities set out in our agreements with those Sub-Agreement  Holders, or to otherwise meet our obligations to Sub-Agreement Holders and their participants, as part of  our provision of FPDI Services. 
  • To fulfill the purpose for which you provide it.  
  • For any other purpose disclosed by us when you provide the information. 
  • With your consent. 

We may also disclose your personal information: 

  • To comply with any court order, law, or legal process, including to respond to any government or  regulatory request, in accordance with applicable law. 
  • To enforce or apply the FPDI Terms of Use and other agreements. 
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of FPDI, our  clients, or others. 

1.6 TRANSFERRING YOUR PERSONAL INFORMATION 

We may transfer limited personal information that we collect or that you provide as described in this Policy to  contractors, service providers, and other third parties we use to support the FPDI Services (such as analytics and  search engine providers that assist us with Site improvement and optimization) and who are contractually  obligated to keep personal information confidential, use it only for the purposes for which we disclose it to them,  and to process the personal information with the same standards set out in this Policy. 

We may process, store, and transfer your personal information in and to a foreign country, with different privacy  laws that may or may not be as comprehensive as Canadian law. In these circumstances, the governments, courts,  law enforcement, or regulatory agencies of that country may be able to obtain access to your personal information  through the laws of the foreign country. Whenever we engage a service provider, we require that its privacy and  security standards adhere to this Policy and applicable Canadian privacy legislation. 

You are welcome to contact us to obtain further information about FPDI policies regarding service providers  outside of Canada. See Contact Information. 

By submitting your personal information to us or engaging with the FPDI Services, you consent to this transfer,  storage, or processing. 

1.7 CHOICES ABOUT HOW WE USE AND DISCLOSE YOUR INFORMATION 

We strive to provide you with choices regarding the personal information you provide to us. We have created  mechanisms to provide you with the following control over your information:  

  • Tracking Technologies. You can set your browser to refuse all or some browser cookies, or to alert you  when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash  player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of  this Site may not be accessible or may not function properly. For more information about tracking  technologies, see Information We Collect About You. 
  • Programming Information from FPDI. If you have opted in to receive certain emails from us but no longer  wish to have your contact information used by FPDI to provide information about educational,  employment, or other programming opportunities we think may be of interest to you, you can opt-out by  sending us an email stating your request to enquire@fpdinc.ca. If we have sent you a general informational email, you may unsubscribe by clicking the unsubscribe link we have included in the email.  This opt-out does not apply to information provided by FPDI as part of its requirements under an  agreement with you.  
  • Information Used and Disclosed as part of the FPDI Services, generally. When it comes to the FPDI  Services, generally, FPDI may have certain contractual obligations relating to the use and disclosure of  personal information you have provided to us, as described in this Policy. If you wish to have more  information about FPDI’s privacy practices and your choices related to how we use and disclose your  information as part of the FPDI Services, please contact us at the information provided below in the  Contact Information section. 

1.8 DATA SECURITY 

The security of your personal information is very important to us. We use physical, electronic, and administrative  measures designed to secure your personal information from accidental loss and from unauthorized access, use,  alteration, and disclosure. We store all information you provide to us in compliance with policies, procedures and  guidelines described in this Policy and our other contractual obligations. 

The safety and security of your information also depends on you. Where we have given you (or where you have  chosen) a password for access to certain parts of our Site, as such functionality is offered from time to time, you  are responsible for keeping this password confidential. We ask you not to share your password with anyone. 

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best  to protect your personal information, we cannot guarantee the security of your personal information transmitted  to our Site. Any transmission of personal information is at your own risk. We are not responsible for circumvention  of any privacy settings or security measures contained on the Site.  

1.9 DATA RETENTION 

Except as otherwise permitted or required by applicable law or regulation, we will retain your personal  information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of  satisfying any legal, accounting, or reporting requirements. This includes personal information collected under an  ISET Agreement, which will be maintained in accordance with the terms of that agreement. 

Under some circumstances we may anonymize your personal information so that it can no longer be associated  with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose  under FPDI’s mandate without further notice to you or your consent.  

1.10 CHILDREN UNDER THE AGE OF 13 

We do not knowingly collect personal information from children under 13. If you are under 13, do not use or  provide any information on this Site or on or through any of its features. If we learn we have collected or received  personal information from a child under 13 without verification of parental consent, we will delete that  information. If you believe we might have any personal information from or about a child under 13, please contact  us at enquire@fpdinc.ca 

1.11 ACCESSING AND CORRECTING YOUR PERSONAL INFORMATION 

It is important that the personal information we hold about you is accurate and current. Please keep us informed if  your personal information changes. By law you have the right to request access to and to correct the personal  information that we hold about you. We will provide access to your personal information, subject to exceptions set  out in applicable privacy legislation. 

If you want to review, verify, correct, or withdraw consent to the use of your personal information you may also  send us an email at enquire@fpdinc.ca to request access to, correct, or delete any personal information that you  have provided to us. We may not accommodate a request to change information if we believe the change would  violate any law or legal requirement or cause the information to be incorrect. 

We may request specific information from you to help us confirm your identity and your right to access, and to  provide you with the personal information that we hold about you or make your requested changes. Applicable  law may allow or require us to refuse to provide you with access to some or all of the personal information that we  hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance  with our record retention obligations and practices. If we cannot provide you with access to your personal  information, we will inform you of the reasons why, subject to any legal or regulatory restrictions. 

If you are concerned about our response or would like to correct the information provided, you may contact our  Privacy Officer at enquire@fpdinc.ca.  

1.12 WITHDRAWING YOUR CONSENT 

Where you have provided your consent to the collection, use, and transfer of your personal information, you may  have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if  applicable, contact us at enquire@fpdinc.ca. Please note that if you withdraw your consent we may not be able to  provide you with particular services. We will explain the impact to you at the time to help you with your decision. 

1.13 CHANGES TO OUR PRIVACY POLICY 

This Policy may change from time to time. Changes we make to this Policy will be posted on this page. If we make  material changes to how we treat our users’ personal information, we may notify you by email or through a notice  on the Site home page. We include the date the Policy was last revised at the top of this Policy. You are responsible  for periodically visiting our Site and this Policy to check for any changes. Your continued use of the FPDI Services  after such notice constitutes your acceptance of such changes. 

1.14 CONTACT INFORMATION 

If you have any questions about this Policy and FPDI’s privacy practices, please email us enquire@fpdinc.ca. 

We have procedures in place to receive and respond to complaints or inquiries about our handling of personal  information, our compliance with this Policy, and with applicable privacy laws. To discuss our compliance with this  Policy please contact our Privacy Officer using the contact information listed above.