Kumon Canada Inc. is a corporation incorporated under the laws of Ontario, with its head office at 6240 Highway 7, Suite 300, Woodbridge, Ontario, L4H 4G3. When the term “Kumon” or “we” is used in this policy, it means Kumon Canada Inc.
Kumon Canada Inc. is part of a worldwide group of companies, the largest supplemental education provider in the world, with headquarters in Osaka Japan. Kumon is a wholly owned subsidiary of Kumon North America, Inc., located in the United States. Kumon North America Inc. and Kumon Institute of Education Co., Ltd., located in Japan, will from time to time have access to your personal information in order to monitor and develop programs to improve instruction and maximize learning.
Protection of your personal information is essential to Kumon. Kumon complies with the federal Personal Information Protection and Electronic Documents Act, as well as with applicable provincial privacy legislation (the “Applicable Privacy Laws”).
- “Collection” – means the act of gathering, acquiring or obtaining personal information from any source, including from third parties, by any means.
- “Consent” – means a voluntary agreement with what is being done or proposed. Consent can be either express or implied. Express consent is given explicitly, either orally or in writing. Express consent is unequivocal and does not require any inference on the part of the persons seeking the consent. Implied consent arises where consent may reasonably be inferred from the action or inaction of the individual.
- “Customer” - means an individual who is a client at a Kumon Math and Reading Centre.
- “Disclosure” – making personal information available to other persons outside of Kumon.
- “personal information” – means information about an identifiable individual.
- “Use” – means the handling and processing of personal information.
PRINCIPLE 1: ACCOUNTABILITY
Accountability for Kumon’s compliance with the privacy principles shall rest with Kumon’s Privacy Officer. This individual may delegate other individuals to act in his or her behalf. The individual will be known as the “Privacy Officer”.
Kumon is responsible for all personal information in its possession or custody, including information that has been transferred to it by a third party, including personal information collected by a third party assisting us with marketing.
Kumon will only disclose your personal information to a third party if it is satisfied that such party will grant a comparable level of protection to your personal information. Kumon selects contractors or third parties who can guarantee that technical, organizational, and security measures will adequately protection your personal information at all times.
- (a) implementing procedures to protect personal information;
- (b) establishing procedures to receive and respond to complaints and inquiries;
- (c) training staff and communicating to staff information about Kumon’s policies and practices;
- (d) developing information to explain Kumon’s policies and procedures; and
- (e) monitoring developments in privacy and security on a continuing basis.
PRINCIPLE 2: IDENTIFYING PURPOSES
The purposes for which personal information is collected shall be identified by Kumon before or at the time the information is collected.
Kumon shall collect personal information only for the purposes of operating its business including:
- improvement of our Math and Reading programs
- security of the child
- franchise recruitment
- centre management
- identifying and communicating with individuals interested in receiving information about the Kumon Method, Materials, services and other marketing purposes (often referred to as secondary marketing)
- complying with governmental rules and regulations;
- hiring and employment purposes;
- training its staff;
- operating its websites.
Kumon generally uses such personal information to carry on its business and serve its customers as described above. If the business is transferred to a new owner, the personal information will also be transferred subject to the limitations of Principle 5.
The purposes for which information is being collected shall be identified by the member at or before the time the information is collected. Only information that is necessary for the purposes that have been identified may be collected. The purposes for the collection, use and disclosure shall be communicated to the subject individual.
PRINCIPLE 3: CONSENT
The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except as provided by law.
Consent is required for the collection of personal information and the subsequent use or disclosure of such information. Exceptions to such requirement are specified in Applicable Privacy Laws.
When acting as a service provider to a franchisee or another organization such as a private school with respect to the collection, use or disclosure of personal information, a member of Kumon shall obtain and adhere to any form of consent previously obtained by such organization, subject to the exceptions provided for in Applicable Privacy Laws.
Kumon may not, as a condition for the supply of a product or a service require an individual to consent to the collection, use or disclosure of personal information beyond what is necessary for such purposes.
The adequacy of the form of consent depends upon the circumstances and the type of information that is being collected.
In principle the collection, use or disclosure of personal data concerning racial and ethnic origin, political opinions, religious or philosophical beliefs, or details about the health or sexual orientation of the individual concerned is not permitted, except when such is required or allowed by law, as these are particuarly sensitive categories of personal information. Should Kumon collect sensitive information about you or your child, we will require your explicit consent.
You may withdraw his/her consent at any time, subject to legal or contractual restrictions and reasonable notice. Kumon will inform you of the implications of such withdrawal.
PRINCIPLE 4: LIMITING COLLECTION
The collection of personal information shall be limited to that which is necessary for the purposes identified by Kumon. The information shall be collected by fair and lawful means.
Personal information shall not be collected indiscriminately. Both the amount and the type of information collected shall be limited to that which is necessary to fulfill the purposes identified.
PRINCIPLE 5: LIMITING USE, DISCLOSURE AND RETENTION
Personal information shall not be used or disclosed for purposes other than those for which the information was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
Kumon is a wholly owned subsidiary of Kumon North America, Inc. and Kumon North America, Inc. is a wholly owned subsidiary of the Kumon Institute of Education Co., Ltd.
Kumon may disclose your personal information to third parties who assist us in the conduct of our business. Prior to disclosing your personal information, we will ensure that such third parties will protect your personal information adequately.
Employees and contractors who have access to personal information shall only be those whose function and responsibility specifically include the handling of such personal information. The right of access is restricted according to the nature and scope of the individual function and responsibility.
Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or made anonymous.
PRINCIPLE 6: ACCURACY
Personal information shall be accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.
This is particularly important where the information is being used to make some evaluation or judgement about the individual. The extent to which the personal information shall be accurate, complete and up-to-date will depend upon the use of the information taking into account the interests of the individual.
Kumon has measures in place to ensure that your personal information that is used on an ongoing basis, including information that is disclosed to third parties, is generally accurate and up-to-date.
When appropriate, Kumon communicates modifications to your personal information to contractors having access to your personal information.
PRINCIPLE 7: SAFEGUARDS
Personal information shall be protected by security safeguards which are commensurate to the sensitivity of the information.
The security safeguards shall protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification. The nature of the safeguards will vary according to the sensitivity of the information. Kumon will monitor security developments and re-assess the risks at regular intervals.
The methods of protection will include physical measures, organizational measures and technological measures. All personal information shall be handled on a “need-to-know” basis and each member of Kumon shall be responsible for the protection of the personal information used in his or her job function.
Kumon shall regularly make all of its employees and contractors aware of the importance of maintaining the security of personal information.
Care shall be used in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to such information.
PRINCIPLE 8: OPENNESS
Kumon shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.
Kumon shall be open about its policies and practices with respect to the management of personal information. Individuals shall be able to acquire information about Kumon’s policies and practices without unreasonable effort. This information shall be made available in a form that is generally understandable.
The information made available must include:
- (a) the correct legal name of Kumon;
- (b) how the individual may contact the Privacy Officer with respect to complaints or inquiries;
- (c) advice that the individual can gain access to the personal information held by Kumon by writing to the Privacy Officer, confirming and verifying their identity, and requesting the specified information;
- (d) a description of the type of personal information held by Kumon including a general account of its use;
- (e) a copy of any brochures or other information that explain Kumon’s policies, standards or codes; and
- (f) what personal information is generally made available to related organizations.
- (g) advice that the individual may refuse to allow the use of his or her data for purposes of direct marketing, which must be given no later than the time of the first inclusion in a mailing.
This information is also available on the Kumon’s website www.kumon.ca.
PRINCIPLE 9: INDIVIDUAL ACCESS
Upon request, an individual shall be informed of the existence, use and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Before granting an individual access to the personal information, a member of Kumon must consult the Privacy Officer or that person’s delegate. There are restrictions on the grant of access in Applicable Privacy Laws, for instance where such disclosure would reveal personal information about a third party that cannot be severed from the information about the individual making the request.
Upon receiving your access request, Kumon will inform your whether or not it holds personal information about you or your child. When Kumon provides you with information regarding the personal information in its possession or control, it will provide an account of the use that has been made or is being made and an account of the third parties to which the information has been disclosed. Before providing you with any information, Kumon will verify and satisfy itself as to your identity.
Kumon shall respond to your request within 30 days at minimal or no cost to you. Kumon may require a reasonable payment for the information provided only if it has informed you in advance of the approximate cost and you have advised Kumon that the request is not being withdrawn.
If you demonstrate the inaccuracy or incompleteness of your personal information, Kumon must amend the information as required. Depending upon the nature of the information challenged, amendment could involve the correction, deletion or addition of information. Where appropriate, the amended information shall be transmitted to third parties having access to the information in question.
When a challenge is not resolved to your satisfaction, the substance of the unresolved challenge shall be recorded by Kumon. When appropriate, the existence of the unresolved challenge should be transmitted to third parties having access to the information in question.
PRINCIPLE 10: CHALLENGING COMPLIANCE
An individual shall be able to address a challenge concerning compliance with the above privacy principles to the Privacy Officer.
The individual accountable for Kumon’s compliance is the Privacy Officer. All inquiries and complaints shall be made to Kumon’s Privacy Officer by mail or be email at:
Kumon Canada Inc.
6240 Highway 7, Suite 300
Woodbridge, Ontario, L4H 4G3
(416) 490 1434 EXT. 2303
The Privacy Officer shall investigate all complaints. If a complaint is found to be justified, the Privacy Officer will take appropriate measures, including amending its policies and practices if necessary.
Where the complaint arises out of a customer matter, the customer shall be informed immediately of such measures.
From time to time the Privacy Officer may make changes to this policy to adapt to changing business conditions and for other reasons. In the event that in the opinion of the Privacy Officer acting reasonably such changes will allow Kumon to make materially greater use and/or disclosure of any personal information, the individuals affected by the changes will be clearly and concisely notified of the changes and their proposed effect, and provided with an opportunity to withdraw their consent to the collection, use and/or disclosure of their personal information.
Date Adopted: September 1, 2017