Privacy policy

This policy explains what personal information Polinsys collects, why, and what we do with it. It is written for anyone who writes to us, attends our sessions or becomes a client, wherever you live, and it follows Canada's federal privacy law (PIPEDA and its ten principles) and Canada's anti-spam law (CASL).

Polinsys gives immigration advice through its authorized representative, Joy Stephen, RCIC, CICC licence R419719 (CICC public register). Licensees owe their clients confidentiality, and that duty continues after a file closes.

Who is responsible

Polinsys is accountable for the personal information it holds, including information handled for us by service providers. Write to [email protected] with any question, request or complaint about your information.

What we collect when you first contact us

The enquiry form on our pages asks for six things, and each field shows why:

You may add a message. You tick a box agreeing that Polinsys may contact you about your enquiry. To keep out automated submissions, we also record basic technical details of the form, such as how long it took to complete.

The confirmation step. After you send the form, we send one email from [email protected] with a link to confirm the address is yours. Nothing else is sent until you click it.

What we collect if you become a client

An application needs much more: identity and passport details, education, work history, language results, finances, family members, and sometimes medical or police information. We collect only what your application and the programme require, and we tell you why when we ask. Because much of this is sensitive, we ask for your express consent, which is recorded in your service agreement. If you give us information about family members, please make sure they know.

How we use and share it

We use your information to answer your enquiry, prepare your evaluation, provide the services in your agreement, keep you informed about your file, invoice you, and meet our legal and professional duties.

We share it only as needed for those purposes:

• with Immigration, Refugees and Citizenship Canada or a province, when we file or follow up for you;
• with service providers who work for us, such as translators, email and hosting providers, under contracts that require them to protect it;
• when the law requires it, or with CICC when it regulates our practice.

We never sell your information, and we never share it for anyone else's marketing.

Emails and unsubscribing

Every email we send identifies Polinsys, gives our contact details and includes an unsubscribe link. Unsubscribe requests are honoured within 10 business days. We send marketing email only with your consent: express consent, or the implied consent CASL allows for 6 months after an enquiry or 2 years after a purchase. Messages about a file you have with us continue while the file is open. Replies go to [email protected]. See Making sure our emails reach you.

How long we keep it

• Client files are kept for at least 6 years after the file is closed, as CICC's Client File Management Regulation requires, in a secure place. They are then destroyed in a way that protects confidentiality, and the destruction is recorded.
• Enquiries that do not lead to a file are kept only as long as we need them to answer you and follow up. You can ask us to delete yours at any time.

Where your information is stored and processed

Your information is stored and processed in Canada, and by our team and service providers in India and the United States. Our offices in India work on files under the licensee's supervision.

When information is held or handled outside Canada, the laws of that country apply to it there, and its courts, law enforcement and national security authorities may be able to access it. We remain accountable for it, and we use contracts and other means to give it a comparable level of protection.

How we protect it

Access is limited to the people who need it for your file, and everyone who works for us is bound to confidentiality. Client files are held in a secure client account system with individual sign-in. If a privacy breach creates a real risk of significant harm, we tell the people affected as soon as feasible and report it to the Privacy Commissioner of Canada. We keep a record of every breach.

Cookies

Our website uses only the cookies it needs to work, such as keeping a form secure. We do not use tracking, advertising or profiling cookies unless you have first agreed to them, and any such tools stay off until you turn them on.

Your rights

• Access and correction. Ask us for a copy of the information we hold about you, or to correct it. Clients can see much of it in their client account. We reply within the time the law allows.
• Withdraw consent. You may withdraw consent at any time, subject to legal and contractual limits. We will explain what that means for your file.
• Complain. Write to us first. If you are not satisfied, you may complain to the Office of the Privacy Commissioner of Canada. See also Complaints.

Changes to this policy

When we change this policy, we update this page and its date.

How Polinsys helps

If you are unsure what we hold or why, ask. Write to [email protected] or use the contact form, and we will answer. You can also raise general questions at our free Friday Q&A with Joy Stephen, RCIC (see FREE Webinars: Resource Guides and AR Q&A), but please keep personal details for a private message.