Privacy Code



At Pewter Graphics we understand that privacy is a critical issue for our clients.

Our privacy code outlines our principles and procedures regarding the confidentiality and security of client personal information. This code is based on the requirements of the Federal Personal Information Protection and Electronic Documents Act (PIPAEDA), and provincial privacy legislation in the provinces in which PEWTER GRAPHICS does business. PEWTER GRAPHICS will continue to implement new technologies from time to time. As a result, this policy is subject to change without prior notice. We encourage you to review our privacy policy periodically.

This code outlines the principles PEWTER GRAPHICS applies when protecting clients’ privacy. We believe that ensuring the accuracy, confidentiality, and security of the information we hold about clients is more than simply a legal requirement, it is an ethical obligation.

Section 1: PEWTER GRAPHICS ‘s Accountability

Section 2: Identifying the Purposes of Personal Information

Section 3: Client Consent

Section 4: Limits for Collecting Personal Information

Section 5: Limits for Using, Disclosing, and Keeping Personal Information

Section 6: Accuracy

Section 7: Safeguarding Personal Information

Section 8: Availability of Policies and Procedures

Section 9: Providing Client Access to Personal Information

Section 10: Compliance and Complaints


This code applies to PEWTER GRAPHICS. It outlines the principles and commitments we make to our clients, to protect the privacy of personal information.

This code does not apply to the information collected, used, or disclosed with respect to corporate or commercial entities that are clients. However, PEWTER GRAPHICS exercises the same care and diligence in protecting the confidentiality of this information.


“PEWTER GRAPHICS” - means Pewter Graphics Inc.

“Collection” - the act of gathering, acquiring, or obtaining personal information from any source, including third parties, by any means.

“Consent” - involves voluntary agreement with what is being done or proposed. Consent may be expressed or implied. Express consent can be given orally or in writing, it is unequivocal, and does not require any inference on the part of PEWTER GRAPHICS. Implied consent exists when PEWTER GRAPHICS can reasonably infer consent based upon the action or inaction of the client.

“Client” - is any individual who joins, or applies to join PEWTER GRAPHICS.
“Disclosure” - the act of making personal information available to others outside of PEWTER GRAPHICS. “Use” - the treatment and handling of personal information by and within PEWTER GRAPHICS.

 “Personal Information” - information about an identifiable individual that is recorded in any form; excluding the individual’s name, business title, business address and business phone number.

“Non-Personal Information” – information that is not associated with or linked to your personal information, including personal information that has been aggregated or otherwise anonymized so that it no longer relates to an identifiable individual.

“Third-Party” - an individual or organization other than PEWTER GRAPHICS and the client.

Section 1: PEWTER GRAPHICS’s Accountability

1.0 PEWTER GRAPHICS is accountable for the protection of clients’ personal information. While senior management is ultimately accountable for the protection of personal information, the day-to-day monitoring for compliance may be delegated to other staff.

1.1 The overall responsibility for the protection of personal information, and compliance with this code rests with PEWTER GRAPHICS’s Privacy Officer.

1.2 PEWTER GRAPHICS is committed to ensuring that the appropriate security measures are employed in the transfer of sensitive information. However, when using e-mail or wireless communication, PEWTER GRAPHICS advises clients that complete confidentiality and security are not assured. PEWTER GRAPHICS is not accountable for any damages suffered when a client transmits personal information through e-mail or wireless communication or when PEWTER GRAPHICS transmits information at the request of the client.

1.3 PEWTER GRAPHICS has developed policies and procedures to: protect personal information; receive and respond to complaints and inquiries; train staff regarding the policies and procedures; and communicate the policies and procedures to our clients.

Section 2: Identifying the Purposes of Personal Information

2.0 PEWTER GRAPHICS will communicate the purposes for which information is being collected, either orally or in writing.

2.1 PEWTER GRAPHICS does not sell, rent, share, or loan our clients list. PEWTER GRAPHICS collects client personal information for the following reasons:

  • To provide Wholesale services and process client purchases;
  • To understand the product and service needs of our clients;
  • To develop and manage products and services to meet the needs of our clients;
  • To contact our clients directly for products and services that may be of interest;
  • To determine the eligibility of our clients for share ownership;
  • To meet regulatory requirements;
  • To ensure a high standard of service to our clients;
  • To verify a client’s identity.

Client Purchases: When clients purchase an item from us  (or through our website) we only request the information needed to complete the processing of orders and billing.

  • We may share our clients’ personal information with outside shipping companies and credit card processing companies in order to bill and ship orders, but we do not provide any more information than necessary for these purposes.
  • We may also use the information to contact clients regarding orders or to provide clients with future information about our products and services.
  • We use information on purchases to compile statistics and reports for Pewter Graphicserative ‘s use.
  • We analyse aggregated information to understand our clientship and their needs.

Pewter Graphics  Membership: To become a client of PEWTER GRAPHICS, you must provide certain information, which is added to our internal membership database, and which incorporation must maintain by law (such as a valid legal name and address). While according to current law, PEWTER GRAPHICS must allow some access to the membership database to directors and clients, the information contained in the database can only be viewed or used for corporate purposes pertaining to Pewter Graphics.

2.2 PEWTER GRAPHICS may transfer your personal information across provincial or national borders to fulfill any of the above purposes, including to service providers located outside of Canada who may be subject to applicable disclosure laws in those jurisdictions.

Section 3: Client Consent

3.0 PEWTER GRAPHICS will obtain client consent to collect, use or disclose any personal information except where detailed in this code. PEWTER GRAPHICS will make reasonable efforts to ensure that clients understand how their personal information will be used and disclosed.

3.1 A client’s consent can be express or implied, or given through an authorized representative such as a lawyer or agent. A client can withdraw consent at any time, with certain exceptions (see section 3.3). Only under the following exceptional circumstances will PEWTER GRAPHICS collect, use, or disclose personal information without the client’s knowledge or consent:

  • When such collection, use or disclosure is permitted or required by law*
  • When use of information is for acting in an emergency that threatens an individual’s life, health, or personal security
  • When certain information is publicly available
  • When we require legal advice from a lawyer
  • When we need to deal with an anticipated breach of law. *Fraud Prevention

Pewter Graphics reserves the right to co-operate with local, national, or international law enforcement or other authorities in the investigation of improper or unlawful activities and this may require the disclosure of personal information. If such an investigation requires disclosure of personal information kept in our records, we may be required by law to cooperate.

Under two scenarios would we be required to provide law enforcement with personal information:

  1. Warrant: if the law enforcement agency obtains a warrant, PEWTER GRAPHICS is required to disclose personal information in order to comply with the warrant, and
  2. Investigation: if the law enforcement agency’s request for the information identifies its lawful authority to obtain the information and indicates that:
  1. if the law enforcement office suspects the information relates to national security, the defence of Canada or the conduct of international affairs; or
  2. the disclosure is requested for the purpose of enforcing any law in Canada, a province or a foreign jurisdiction, carrying out an investigation relating to the enforcement of any such law or gathering intelligence for the purpose of enforcing any such law, or

iii. the disclosure is requested for the purpose of administering any law of Canada or a province.

When a request is received from law enforcement an PEWTER GRAPHICS Privacy Officer will ensure that PEWTER GRAPHICS receives the request in writing on RCMP (or other law enforcement) letterhead, and we will confirm directly with the RCMP (or law enforcement requestor) that the request is authentic.

We also reserve the right to report improper or unlawful user activities on our website, which may require the disclosure of personal information relating to those individuals conducting such improper or unlawful activities.

3.2 Consent may be given orally, in writing, or electronically. For example, depending on the sensitivity of the information, consent can be expressed over the telephone when information is being collected; electronically when submitting an agreement, application, or other information; in writing when signing an agreement or form; when using a product or service; or when indicating by means of a check-off box whether or not consent is granted.

3.3 Subject to contractual or legal arrangements, clients may withdraw or refuse consent provided that PEWTER GRAPHICS is given reasonable notice. Refusal or withdrawal of consent may prevent PEWTER GRAPHICS from providing a product or service
to the client as in the case where a client is applying for membership and will not provide relevant personal information required by law to process the membership share purchase. PEWTER GRAPHICS will not unreasonably withhold products or services from clients who refuse or withdraw consent, but if information is required by law or required to operate a consumer retail co-operative, PEWTER GRAPHICS may decline to deal with a client or person who will not consent to the use of such information.

Section 4: Limits for Collecting Personal Information

4.0 PEWTER GRAPHICS will only collect personal information for the purposes identified. PEWTER GRAPHICS limits the collection of personal information to what is reasonably required.

4.1 PEWTER GRAPHICS collects personal information in a variety of ways such as during the course of your purchase of our products or services or your participation in one or more of our events or contests.

  1. Directly from you. You may provide personal information to us in person, by mail, over the telephone, through
    our websites or in any direct manner. For example, personal information may be collected through our monitoring and recording of communications, such as telephone calls to our service centre.
  2. Through Technology. We may collect personal information and non-personal information through various technologies directly from you or from third parties.
  1. Point of Sale
    2. Video surveillance
    3. Social Networking and other electronic means

Section 5: Limits for Using, Disclosing, and Keeping Personal


5.0 Personal information will only be used or disclosed for the purpose for which it was collected. PEWTER GRAPHICS will not use personal information for any additional purpose unless PEWTER GRAPHICS seeks client consent to do so.

5.1 PEWTER GRAPHICS will not sell client lists or personal information to Third Parties. PEWTER GRAPHICS will not share its client list with Third Parties (including any of our community partners).

5.2 PEWTER GRAPHICS may periodically use client personal information to conduct client surveys in order to enhance our provision of client services. If an outside body is employed to conduct research on behalf of PEWTER GRAPHICS, or provide other services that require access to client information, PEWTER GRAPHICS will ensure that appropriate security undertakings, such
as confidentiality clauses in contractual arrangements, are employed to protect the transfer and use of personal information.

5.3 PEWTER GRAPHICS will retain client personal information only as long as necessary or expected to be necessary for the identified purposes, or as required by legislation.

Section 6: Accuracy

6.0 PEWTER GRAPHICS will make reasonable efforts to ensure that client personal information is as accurate, complete, and current as required for the purposes for which it was collected. In some cases, PEWTER GRAPHICS relies on its clients to ensure that certain information, such as the client’s address or telephone number, is current, complete, and accurate.

6.2 Clients may request amendments to the records at PEWTER GRAPHICS in order to ensure the accuracy and completeness of their personal information. If the amendment request pertains to information that remains in dispute, PEWTER GRAPHICS will note the client’s opinion in the file.

Section 7: Safeguarding Personal Information

7.0 PEWTER GRAPHICS is committed to the safekeeping of client personal information in order to prevent its loss, theft, unauthorized access, disclosure, duplication, use, or modification.

7.1 Depending on the sensitivity of the information, PEWTER GRAPHICS will employ appropriate security measures to protect the information. The measures may include, for example, the physical security of offices and data centres, and electronic security measures such as passwords, encryption, and personal identification numbers.

7.2 PEWTER GRAPHICS will use appropriate security measures when disposing of client personal information.

7.3 The development of PEWTER GRAPHICS’s policies and procedures for the protection of personal information is an ongoing process. Changes in technology necessitate that PEWTER GRAPHICS continually develops, updates, and reviews information protection guidelines and controls to ensure ongoing information security.

Section 8: Availability of Policies and Procedures

8.0 PEWTER GRAPHICS is open about the policies and procedures it uses to protect client personal information. Information about these policies and procedures will be made available to clients either electronically or in written format in plain language. However, to ensure the integrity of our security procedures and business methods, PEWTER GRAPHICS may refuse to publicly disclose certain information.

8.1 PEWTER GRAPHICS will make the following information available:

  • The name, title and address of the person accountable for the policies and procedures and to whom complaints or inquiries can be forwarded;
  • A description of the type of personal information held by PEWTER GRAPHICS, including a general account of its use;
  • A copy of any brochures or other information that explain the policies and procedures.

Section 9: Providing Client Access to Personal Information

9.0 Clients have a right to access their personal information held by PEWTER GRAPHICS. Upon request, PEWTER GRAPHICS will, within a reasonable time period, tell the client what personal information it has, what it is being used for, and to whom it has been disclosed if applicable and within the time period for which records are available.

9.1 Clients may be asked to be specific about the information they would like to access and if necessary, be asked to submit their request in writing to the PEWTER GRAPHICS Privacy Officer.

9.2 Clients will be required to provide personal information to identify themselves to enable PEWTER GRAPHICS to provide an account of the existence, use, and disclosure of personal information.

9.3 PEWTER GRAPHICS will make the information available within 30 days, or provide written notice of extension where additional time is required to fulfil the request.

When information is not provided within 30 days of the request, PEWTER GRAPHICS will, no later than 30 days after the date of the request, send a notice of extension to the client, advising of the new time limit, the reasons for extending the time limit and of the right of the client to make a complaint to the Commissioner regarding the extension.

9.4 The information will be made available at a cost that will vary with the type and amount of information requested. Where a cost will be incurred by the client, PEWTER GRAPHICS will inform the client of the cost and request further direction from the client on whether or not PEWTER GRAPHICS should proceed with the request.

9.5 When reporting to clients to whom their information has been disclosed, PEWTER GRAPHICS will not document information transfers necessary for the daily provision of products and services to clients. For example, transfers to organizations that process debit card purchases, cheque clearing, credit card transactions, and automated banking transactions will not be documented. Upon request, PEWTER GRAPHICS will provide a list of organizations where client personal information may have been sent.

9.6 If a request is refused, PEWTER GRAPHICS will notify the client in writing, documenting the reasons for refusal and resources for redress available to the client.

9.7 In certain situations, PEWTER GRAPHICS may not be able to provide access to any or all personal information about a client. In such cases, PEWTER GRAPHICS will explain the reasons it will not provide the requested information, and identify resources for recourse available to the client. The reasons for not providing information may include that it is unreasonably costly to provide, information that would threaten the life or security of another individual, information generated in a formal dispute resolution process, information that contains references to other individuals, information that cannot be disclosed for legal, security, or commercial proprietary reasons, and information that is subject to solicitor-client or litigation privilege.

9.8 If the information is demonstrated to be inaccurate or incomplete, PEWTER GRAPHICS will amend the information as required. Where appropriate, PEWTER GRAPHICS will transmit the amended information to Third Parties having access to the information in question.

Section 10: Compliance and Complaints

10.0 Clients are to direct any complaints, concerns or questions regarding this privacy code in writing to the office of the PEWTER GRAPHICS Privacy Officer. If the Privacy Officer is unable to address the client’s concerns, the issue can be referred to the office of the CEO. At any point in this process the client may also write to the Privacy Commissioner.