The TELUS Privacy Code
At TELUS, we have a long-standing policy of protecting the privacy of customers and team members in all of our business operations. The TELUS Privacy Code is a formal statement of the principles and guidelines that govern how TELUS protects personal information of its customers (subject to the exclusions noted here and below under scope) and team members. It is based on and incorporates the ten principles that form the basis of all applicable privacy legislation in Canada, including Part 1 of the Personal Information Protection and Electronic Documents Act (Statutes of Canada 2000).
The TELUS Privacy Code was originally published in 1998: we regularly review it to ensure that it reflects legislative and technological changes and that it continues to reflect our practices and commitments.
Last updated January, 2018
The ten principles, which form the basis of the TELUS Privacy Code, are interrelated and TELUS shall adhere to the ten principles as a whole. Each principle must be read in conjunction with the accompanying commentary. The commentary in the TELUS Privacy Code has been tailored to reflect personal information matters specific to TELUS.
The scope and application of the TELUS Privacy Code are as follows:
- The Code applies to personal information collected, used, or disclosed by TELUS, including personal information of TELUS' customers and team members.
- The Code applies to the management of personal information in any form whether oral, electronic or written.
- The Code does not apply to personal information created by, or collected from or on behalf of TELUS’ (including TELUS Health’s) business customers and their employees or contractors receiving TELUS services under corporate customer agreements; however, such information is protected by other TELUS policies and practices and through contractual arrangements.
- The application of the TELUS Privacy Code is subject to the requirements and provisions of Part 1 of the Personal Information Protection and Electronic Documents Act and the regulations thereunder, provincial privacy legislation (where applicable), and any applicable regulations of the Canadian Radio-television and Telecommunications Commission.
Customer - An individual who uses, or applies to use, TELUS' products or services.
Team member - An employee of TELUS.
Personal information - Any information about an identifiable individual, other than the name, title or business address (including business email address) or business telephone or fax numbers of an employee of an organization.
Personal information does not include de-identified or aggregated information that cannot reasonably be associated with a specific individual.
Information about customers who are sole proprietors or partners is considered to be "personal information" if it is information about the individuals themselves, as distinct from information about their businesses. The latter is protected by other TELUS policies and practices and through contractual business arrangements.
TELUS - TELUS Communications Inc. and its subsidiary companies, as they may exist from time to time. These include, without limitation, the subsidiaries or divisions which carry on business under the following names: TELUS, TELUS Communications, TELUS Mobility, TELUS Québec, TELUS Retail Ltd., Koodo, Public Mobile, PC Mobile, TELUS Health, TELUS Health and Payment Solutions, and TELUS Sourcing Solutions Inc. "TELUS" does not include independent dealers and distributors of TELUS products and services.
Principle 1 – Accountability
TELUS is responsible for personal information under its control and shall designate one or more persons who are accountable for TELUS' compliance with the following principles.
1.1 Responsibility for ensuring compliance with the provisions of the TELUS Privacy Code rests with the senior management of TELUS, which shall designate one or more persons to be accountable for compliance with the Code. Other individuals within TELUS may be delegated to act on behalf of the designated person(s) or to take responsibility for the day-to-day collection and processing of personal information.
1.2 TELUS shall make known, upon request, the identity of the person or persons designated to oversee TELUS' compliance with the TELUS Privacy Code.
1.3 TELUS is responsible for personal information in its possession or control. TELUS shall use appropriate means to provide a comparable level of protection while information is being processed by a third party (see Principle 7).
1.4 TELUS shall implement policies and procedures to give effect to the TELUS Privacy Code, including:
- Implementing procedures to protect personal information and to oversee TELUS' compliance with the TELUS Privacy Code;
- Establishing procedures to receive and respond to inquiries or complaints;
- Training and communicating to team members about TELUS' policies and practices;
- Developing public information to explain TELUS' policies and practices.
Principle 2 – Identifying purposes for collection of personal information
TELUS shall identify the purposes for which personal information is collected at or before the time the information is collected.
2.1 TELUS collects personal information of customers and team members only for the following purposes:
- To establish and maintain a responsible commercial relationship with our customers and to provide ongoing service;
- To understand customer needs and preferences;
- To develop, enhance, market or provide products and services to our customers;
- To manage and develop TELUS' business and operations, including personnel and employment matters;
- To meet legal and regulatory requirements.
Further references to "identified purposes" mean the purposes identified in this Principle.
2.2 TELUS shall outline the purposes for which it collects personal information of team members in the Team Member Privacy Commitment.
2.3 TELUS shall specify the identified purpose or purposes to the customer or team member at or before the time personal information is collected. Upon request, persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within TELUS who shall explain the purposes.
2.4 Unless required by law or for exceptions set out in applicable legislation, TELUS shall not use or disclose for any new (not previously-identified) purpose personal information that has been collected without first identifying the new purpose and obtaining appropriate consent of the customer or team member.
2.5 We may record interactions, such as telephone calls or chats, to or from TELUS service representatives for quality assurance and training purposes; our systems may also conduct real-time analytics on such interactions to identify trends and patterns to help us serve you better.
Principle 3 – Obtaining consent for collection, use or disclosure of personal information
The knowledge and consent of a customer or team member are required for the collection, use, or disclosure of personal information, except where not required by applicable privacy legislation. In certain circumstances personal information can be collected, used, or disclosed without the knowledge and consent of the individual.
For example, TELUS may collect personal information without knowledge or consent if it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is seriously ill or mentally incapacitated.
TELUS may also collect, use or disclose personal information without knowledge or consent if, for example, seeking consent would compromise the availability or accuracy of the information in the context of an investigation, collection and use of the information is reasonable and useful in the investigation of a contravention of a federal or provincial law, or disclosure is required for investigating a breach of an agreement or for the purposes of detecting, suppressing or preventing fraud.
TELUS may also use or disclose personal information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened.
TELUS may also disclose personal information without knowledge or consent to a lawyer representing TELUS, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required or permitted by law.
The Code does not require consent for the collection, use or disclosure of information about a customer or team member that is publicly available and is specified by regulation pursuant to the Personal Information Protection and Electronic Documents Act or provincial privacy legislation, where applicable.
3.1 In obtaining consent, TELUS shall use reasonable efforts to ensure that a customer or team member is advised of the identified purposes for which personal information will be used or disclosed. Purposes shall be stated so that it is reasonable to expect that the customer or team member would understand the nature, purpose and consequences of granting consent.
3.2 Generally, TELUS shall seek consent to use and disclose personal information at the same time it collects the information. However, TELUS may seek consent to use and disclose personal information after it has been collected, but before it is used or disclosed for a new purpose.
3.3 TELUS will require customers to consent to the collection, use or disclosure of personal information as a condition of the supply of a product or service if such collection, use or disclosure is required to fulfill the identified purposes.
3.4 In determining the appropriate form of consent, TELUS shall take into account the sensitivity of the personal information and the reasonable expectations of its customers and team members.
3.5 In general, the use of products and services by a customer, or the acceptance of employment or benefits by a team member, constitutes implied consent for TELUS to collect, use and disclose personal information for all identified purposes.
3.6 A customer or team member may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Customers and team members may contact TELUS for more information regarding the implications of withdrawing consent.
Principle 4 – Limiting collection of personal information
TELUS shall limit the collection of personal information to that which is necessary for the purposes identified by TELUS. TELUS shall collect personal information by fair and lawful means.
4.1 TELUS collects personal information primarily from its customers or team members.
4.2 TELUS may also collect personal information from other sources including credit bureaus, employers or personal references, publicly available sources or other third parties who properly represent that they have the right to disclose the information.
Principle 5 – Limiting use, disclosure, and retention of personal information
TELUS shall not use or disclose personal information for purposes other than for identified purposes, except with the consent of the individual, for exceptions set out in legislation, or as required by law. TELUS shall retain personal information only as long as reasonably necessary for the fulfillment of those purposes.
5.1 Subject to applicable CRTC regulations, TELUS may share a customer's personal information, with the information to be used only for the purpose for which it was shared, to:
- a person seeking information as an agent of a customer, such as a customer's legal representative or as an authorized user under his or her account, if TELUS is satisfied that the person is authorized to receive the information;
- other TELUS business units to help TELUS serve its customers better and to provide them with services from different parts of the company;
- another telecommunications company for the efficient and cost-effective provision of telecommunications services;
- a company involved in supplying a customer with telecommunications or directory-related services;
- our suppliers, agents or other organizations or individuals contracted to TELUS to perform services or functions on our behalf where they require the information to assist us in serving you;
- a credit bureau to evaluate a customer's creditworthiness for monthly reporting purposes on the status of your payment history with TELUS;
- with collection agencies to collect an account if your account has been referred for collection;
- a public authority or agent of a public authority if, in the reasonable judgment of TELUS, it appears that there is imminent danger to life, health or security of an individual which could be avoided or minimized by disclosure of the information;
- TELUS' partners or third-party agents responsible for administering TELUS offers or programs;
- third parties in connection with the sale or outsourcing of parts of TELUS' business, the sale or securitization of assets, or the merger or amalgamation of part or all of TELUS' business with other entities. Since customer and account information and team member information will normally be a part of such transactions, TELUS may use or disclose such information to other parties included in the transaction, as part of due diligence and/or on completion of the transaction; or
- a government agency or other third party, if required to meet legal and regulatory requirements. If a customer dials 911, for example, TELUS will provide the customer's name, telephone number and location information to the emergency agency.
5.2 TELUS may disclose personal information about its team members:
- For standard personnel and benefits administration;
- In the context of providing references regarding current or former team members in response to requests from prospective employers;
- Where the team member consents to such disclosure or disclosure is required by law or for exceptions specified under the applicable legislation.
5.3 Only TELUS' team members with a business need to know, or whose duties reasonably so require, are granted access to personal information about customers and team members.
5.4 TELUS shall keep personal information for as long as it remains reasonably necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where personal information has been used to make a decision about a customer or team member, TELUS shall retain, for a period of time that is reasonably sufficient to allow for access by the customer or team member, either the actual information or the rationale for making the decision.
5.5 TELUS shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer reasonably necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.
Principle 6 – Accuracy of personal information
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
6.1 Personal information used by TELUS shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a customer or team member.
6.2 TELUS shall update personal information about customers and team members as and when reasonably necessary to fulfill the identified purposes or upon notification by the individual.
Principle 7 – Security safeguards
TELUS shall protect personal information by security safeguards appropriate to the sensitivity of the information.
7.1 TELUS shall employ appropriate security measures to protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction.
7.2 TELUS shall protect personal information shared with third parties by a variety of means, including by contractual agreements stipulating the confidentiality and security of the information and the purposes for which it is to be used.
7.3 All of TELUS' team members with access to personal information shall be required to appropriately respect the confidentiality of that information.
7.4 TELUS may store and process personal information in Canada or another country. In either case, the personal information is protected with appropriate security safeguards, but may be available to foreign government agencies under applicable law.
Principle 8 – Openness concerning policies and practices
TELUS shall make readily available to customers and team members specific information about its policies and practices relating to the management of personal information.
8.1 TELUS shall make information about its policies and practices easy to understand, including:
- The title and address of the person or persons accountable for TELUS' compliance with the TELUS Privacy Code and to whom inquiries or complaints can be forwarded;
- The means of gaining access to one's own personal information held by TELUS;
- A description of the type of personal information held by TELUS, including a general account of its use.
8.2 TELUS shall make available information to help customers and team members exercise choices regarding the use of their personal information and the privacy-enhancing services available from TELUS.
Principle 9 – Customer and team member access to personal information
TELUS shall inform a customer or team member of the existence, use, and disclosure of his or her personal information upon request and shall give the individual access to that information. A customer or team member shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
9.1 Upon request, TELUS shall afford customers and team members a reasonable opportunity to review the personal information TELUS holds about them. Personal information shall be made accessible to the individual in understandable form, within a reasonable time, and at minimal or no cost to the individual.
9.2 In certain situations, TELUS may not be able to provide access to all the personal information that it holds about a customer or team member. For example, TELUS may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, TELUS may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor – client privilege, or, in civil law, by the professional secrecy of lawyers and notaries, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law. If access to personal information cannot be provided, TELUS shall provide the reasons for denying access upon request. In general, the exceptions above do not apply if the individual needs the information because an individual's life, health or security is threatened.
9.3 Upon request, TELUS shall provide an account of the use and disclosure of personal information and, where reasonably possible, shall state the source of the information. In providing an account of disclosure, TELUS shall provide a list of organizations to which it may have disclosed personal information about the individual when it is not possible to provide an actual list.
9.4 In order to safeguard personal information, a customer or team member may be required to provide sufficient identification information to permit TELUS to account for the existence, use and disclosure of personal information and to authorize access to the individual's personal information.
9.5 TELUS shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual's file. Where appropriate, TELUS shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.
9.6 Customers can seek access to their personal information by contacting a designated representative at TELUS.
9.7 Team members can seek access to their personal information by contacting their manager within TELUS.
Principle 10 – Challenging compliance
A customer or team member shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for TELUS' compliance with the TELUS Privacy Code.
10.1 TELUS shall maintain procedures for addressing and responding to all inquiries or complaints from its customers and team members about TELUS' handling of personal information.
10.2 TELUS shall inform its customers and team members about the existence of these procedures as well as the availability of complaint procedures.
10.3 TELUS shall investigate all complaints concerning compliance with the TELUS Privacy Code. If a complaint is found to be justified, TELUS shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. A customer or team member shall be informed of the outcome of the investigation regarding his or her complaint.
10.4 A customer or team member may seek advice from the Office of the Privacy Commissioner of Canada or the provincial Privacy Commissioner having jurisdiction, and, if appropriate, file a written complaint with the Commissioner's office. However, the customer or team member is encouraged to use TELUS' complaint procedures first.