1. Accountability

The CEO of the FULL CIRCLE TOTAL DEBT SOLUTIONS INC. is accountable for compliance with these policies and procedures regarding the manner in which FULL CIRCLE TOTAL DEBT SOLUTIONS INC. collects, uses, discloses and otherwise manages personal information. The CEO is appointed as the Privacy Officer for FULL CIRCLE TOTAL DEBT SOLUTIONS INC.. FULL CIRCLE TOTAL DEBT SOLUTIONS INC. is responsible for personal information in its custody and control.

  1. Purposes for Collecting and Using Personal Information

FULL CIRCLE TOTAL DEBT SOLUTIONS INC. collects and uses personal information to provide advice and information on personal money management issues and to provide advice, information and options for debt repayment to FULL CIRCLE TOTAL DEBT SOLUTIONS INC. clients by dealing with their various creditors. The personal information collected by FULL CIRCLE TOTAL DEBT SOLUTIONS INC. includes information on clients’ debts, income, assets, living expenses, employment situation, general financial status and their relationships with various creditors.

The FULL CIRCLE TOTAL DEBT SOLUTIONS INC. also uses the aggregate demographic information from the personal information collected to identify services and programs that may benefit the communities we serve; to target our marketing and awareness programs; and to maintain the ongoing financial support and cooperation of our stakeholders. No individual can be identified through this information.

The FULL CIRCLE TOTAL DEBT SOLUTIONS INC. personnel are trained to explain the purposes of collecting the information to any client who asks for an explanation. The purpose for which personal information is collected and used by FULL CIRCLE TOTAL DEBT SOLUTIONS INC. personnel is communicated to each client at or prior to the time of collection.

  1. Getting the Client’s Consent

FULL CIRCLE TOTAL DEBT SOLUTIONS INC. will not collect, use or disclose a client’s personal information without the express consent of the client.

  1. Limits for Collecting Personal Information

The FULL CIRCLE TOTAL DEBT SOLUTIONS INC. personnel collect personal information about individuals only where such individual is a client or potential client of the FULL CIRCLE TOTAL DEBT SOLUTIONS INC.. Our clients’ personal information is not used or disclosed for purposes other than those for which it was collected, except with the consent of the client or as required by law.

  1. Limits for Disclosing and Retaining Personal Information

FULL CIRCLE TOTAL DEBT SOLUTIONS INC. discloses personal information only for the purposes for which it was collected. It keeps information for as long as it is required for the stated purposes.

The FULL CIRCLE TOTAL DEBT SOLUTIONS INC. retains the hardcopy client assessment files for 24 months and then proceeds to have such files shredded by a licensed and bonded third party. Debt management program file documentation is retained for a period of seven years from the date the debt management program is successfully completed and or closed, after which the files are shredded in the same manner as the client assessment files.

FULL CIRCLE TOTAL DEBT SOLUTIONS INC. electronic file retention policy provides that electronic files regarding debt management programs are kept active until the debts under administration have been paid in full or, alternatively until there is a default in payment or a request by our client to self-administer the repayment of their debts. After this time, the electronic files remain active for a further seven years. After this time the files are permanently deleted from FULL CIRCLE TOTAL DEBT SOLUTIONS INC.’s system.

Electronic files regarding financial counselling only sessions are kept active in our system for a maximum of two years from the date of the last counselling session. The electronic files are permanently deleted on the first day of the month following the two-year period from the date of the last financial counselling session.

Personal information that is no longer required to fulfill the identified purposes or that is not required to be retained pursuant to any applicable law is destroyed, erased or made anonymous. FULL CIRCLE TOTAL DEBT SOLUTIONS INC. reviews the personal information in its custody and control on a periodic basis in order to ensure that personal information no longer required to be retained has been destroyed, erased or made anonymous.

  1. Keeping Personal Information Accurate

FULL CIRCLE TOTAL DEBT SOLUTIONS INC. ensures, to the best of its ability, that the information it holds is accurate, complete, current and relevant to the identified purposes.

FULL CIRCLE TOTAL DEBT SOLUTIONS INC. maintain strict confidentiality agreement with those who have access to the personal information being held by FULL CIRCLE TOTAL DEBT SOLUTIONS INC.. Any corrections to the information can be given to those parties. The FULL CIRCLE TOTAL DEBT SOLUTIONS INC. recognizes that it is crucial that creditors of its clients have current and accurate information in order to make important decisions regarding the acceptance of our client debt management programs as well as other credit decisions.

  1. Safeguarding Personal Information

The FULL CIRCLE TOTAL DEBT SOLUTIONS INC. ensures that personal information is stored in electronic and physical files that are physically secure. Security measures include storage of files in locked filing facilities when not in use; secure locks on the offices of the FULL CIRCLE TOTAL DEBT SOLUTIONS INC. and its satellite offices. Electronic files are protected by encryption software. Staff passwords to access such electronic files are controlled and employ high level encryption practices. Distribution of personal information regarding clients is restricted to the employees of FULL CIRCLE TOTAL DEBT SOLUTIONS INC. and any creditors for whom a debt management program is entered into in respect of FULL CIRCLE TOTAL DEBT SOLUTIONS INC. clients.

The employees of FULL CIRCLE TOTAL DEBT SOLUTIONS INC. sign a Confidentiality Agreement and will abide by these privacy policies and procedures.

Physical FULL CIRCLE TOTAL DEBT SOLUTIONS INC. files containing personal information are shredded under the supervision of FULL CIRCLE TOTAL DEBT SOLUTIONS INC. employees. Deleted electronic files will be permanently removed from the system, as discussed in section five (5).

  1. Individual Access to Personal Information

Upon written request, FULL CIRCLE TOTAL DEBT SOLUTIONS INC. will provide an individual with confirmation as to whether FULL CIRCLE TOTAL DEBT SOLUTIONS INC. has personal information about them, what the information is, what it is being used for and to whom the information has been disclosed.

Individuals should send their written request for access, with contact information and enough information about themselves to identify them to the CEO of FULL CIRCLE TOTAL DEBT SOLUTIONS INC..

The FULL CIRCLE TOTAL DEBT SOLUTIONS INC. will respond within thirty (30) days of receiving any access request at no cost to the individual.

If the individual can provide proof of an error in the personal information held by FULL CIRCLE TOTAL DEBT SOLUTIONS INC., then FULL CIRCLE TOTAL DEBT SOLUTIONS INC. will amend the information and where appropriate, send the corrected information to others who have used the incorrect information.

If the FULL CIRCLE TOTAL DEBT SOLUTIONS INC. denies the individual’s request for access, it will state the reasons for denial.

  1. Handling Individual Complaints and Questions

Individuals may send any complaints regarding the FULL CIRCLE TOTAL DEBT SOLUTIONS I NC.’s compliance with its own privacy policies and procedures to the CEO of the FULL CIRCLE TOTAL DEBT SOLUTIONS INC.. The CEO or designate will investigate the complaint and respond to the individual.

If the individual’s complaint is justified, the FULL CIRCLE TOTAL DEBT SOLUTIONS INC. will change its policies and procedures related to the matter so that other individuals will not experience the same problem.

For more information call us now, toll free 1-877-220-3328.