Pearson Assessment's Privacy Policy

The Canadian Federal government has fully implemented the Personal Information Protection and Electronic Documents Act (PIPEDA), which provides guidelines on how personal information is collected, used, and disclosed. In addition, British Columbia, Alberta and Quebec have passed legislation governing the collection, use or disclosure of personal information in those provinces. As a leading test developer, Pearson Assessment is dedicated to preserving the standards of the profession, while adhering to the principles set forth in the Canadian privacy legislation.

This policy outlines Pearson Assessment's steps to safeguard the privacy of personal information that is collected as part of our business of developing assessment products as well as ensuring the security of our products throughout the selling process. Also provided in this document is our position on how PIPEDA impacts private practitioners' requirements in terms of releasing test components to clients.

Collection of Personal Information

"Personal information" means any information about an "identifiable" individual (whether the individual is expressly identified, or the identity of the individual can be inferred or determined from the information in question).

Personal information is collected by Pearson Assessment through various business forms, including those used during the standardization of assessment products and when customers place orders for products via fax, phone, mail or website. The information required varies by form and is customized for each project. No matter the form, project, or product, information collected is for the sole purpose of developing or adapting products or to ensure customers have the appropriate training and expertise to administer and interpret the products.

Please note that there is no completely secure method of transmitting information or storing data. While the characteristics of each method may vary, facsimile transmission, telephone calls, mail, and transmissions over the Internet, are all vulnerable, some more than others, to potential loss, interception, or misuse. Pearson Assessment cannot be held responsible for any such loss, interception or misuse prior to taking custody of personal information.

New Customers

To ensure that our tests are administered in an appropriate manner so as to provide valid results, Pearson Assessment requires all potential customers to complete the Customer Registration and Profile Forms. These forms are available online at www.PsychCorp.ca, printed in our catalogues, and through our Customer Service Department at 1-866-335-8418. The information collected on these forms pertains to the person's educational and training background, association membership, employment, and contact information, all of which is suggested by the Canadian Psychological Association (CPA) and the American Psychological Association (APA) for determining the appropriate customer qualification level.

Web Customers

Qualification information is also required when purchasing products via our website. The qualification information requested on our website is the same information requested on the paper version, and the information is provided through a secure site, which means that the information you provide is encrypted during the transmission to our database.

Information collected through our website is analyzed with the purpose of better understanding our customers' needs and targeting our marketing strategies to satisfy those needs. Through the use of "cookies", we are able to measure site traffic, including the number of repeat versus new visitors, the time users spend online, and their navigation behaviour. Collecting this information allows us to make changes that improve the overall functionality of the site.

The tracking of website behaviour can be inactivated by either having your computer set to refuse the "cookies" or by deleting existing "cookies".

Consultants

To assist with business strategies, Pearson Assessment may seek assistance from professional consultants for projects including, but not limited to, translations, standardization data collection and product review. For each project, consultants are required to sign an agreement, which stipulates the responsibilities and expectations of the role. As with all third parties to which access is provided to personal information collected by Pearson Assessment, consultants must adhere to Pearson Assessment's Privacy Policy by signing a confidentiality and non-disclosure agreement to protect the private nature of the personal information while it is in their custody.

Examiners

To expedite the standardization process, Pearson Assessment relies on examiners throughout the country to assist in data collection. To become an examiner, Pearson Assessment requires the candidate to complete a background questionnaire which requests information pertaining to the candidate's demographics, work experience and education; accessibility to disabled, clinical, and non-clinical populations; and the potential examinees' ages, ethnicity, and parents' education level. The information collected pertaining to the potential examinees is critical as Pearson Assessment is responsible for ensuring the sampled population is representative of the nation's population.

Based on the information provided, Pearson Assessment will identify potential examiners. The selected individuals are then required to complete a Project Enrollment Form. This form, like the Consultant Agreement, outlines the expected role of the examiner. Upon signing the form, the examiner agrees to follow Pearson Assessment's guidelines throughout the data collection process. Depending on the project, the examiner may also be required to complete a criminal background process through his/her local police. As with all third parties to which access is provided to personal information collected by Pearson Assessment, examiners must adhere to Pearson Assessment's Privacy Policy by signing a confidentiality and non-disclosure agreement to protect the private nature of the personal information while it is in their custody.

All information collected on candidates and examiners are retained in a secured area by Pearson Assessment for the life of the test edition for which the information was collected. Information relating to individuals electing not to participate in future research studies is destroyed in a secure manner. If any data is transferred to business units outside of Canada for reasons such as analyzing, the content of the file is stored in a manor in which it is anonymous and unidentifiable.

Examinees

If the examinee is under the age of 18 years, a completed Parent Consent Form from the child's parent or guardian is required before the child is permitted to be tested. The form, requested by the examiner, is customized by project and explains the role the child plays in the research study. The form includes information regarding the examinee's birth date, grade, ethnicity, parents' education level, primary language spoken at home, and medical history. The purpose for collecting this information is explained on the form. If the parent/guardian signs the form, he/she expresses his/her understanding of the information collected on the child, the expectation of the child, and the rights of the parent/guardian. For examinees 18 years and older, they will be asked to sign a form, which explains their rights and project expectations.

These forms are reviewed by internal staff to determine which of the potential examinees would be appropriate to include in the standardization sample. For those examinees not selected for the project, their information will be properly destroyed. All examinee information collected for use in our research programs is stored in secure files. Electronic files are stored on secure networks accessible only by Pearson Assessment staff. Each Pearson Assessment employee signs confidentiality agreements upon employment with the company, and is trained to carry out and implement Pearson Assessment's privacy policy. The information pertaining to a product is kept for the life of the test edition for which the information was collected.

Usage of Information

Marketing to potential and current customers

Through use of information gathering tools such as surveys, focus groups, discussions and customer registration, Pearson Assessment uses information gathered to better serve our customers through such areas as warranty service, product support, new release and upgrade notices, as well as fulfilling orders placed by you, to contact you in the event follow-up communications are necessary, and to notify you of related offers and services. These communications include, but are not limited to, electronic or paper copies of flyers, letters, brochures, catalogues, postcards, newsletters, etc. These communications are targeted to customers identified from our database, which follow a specific purchasing behaviour.

In some instances, we hire companies to help us analyze survey results and to mail interested parties offers and information on products and services, or for other legitimate business purposes such as product fulfillment or database maintenance. These companies will be authorized to use the information in the same manner in which we have been authorized. In rare instances, we will disclose personally identifiable website information to necessary parties to protect the site or visitors to our site, or to enforce compliance with our Terms and Conditions of Use. The personal information collected will be used to effectively process your order and/or respond to your product/service inquiries. In addition, Pearson Assessment may use your personal information to send you marketing materials deemed relevant to your practice.

Pearson Assessment abides by its privacy policy across various media; however, Pearson Assessment is not responsible for the privacy policies on websites that may be linked to our website. It is Pearson Assessment's recommendation that you view third-party privacy policies to understand their process of collecting and managing customer information.

We may share personally identifiable information within the Pearson family of companies. Information concerning individuals' usage of the www.PsychCorp.ca will not be disclosed to third parties except in an aggregate form (e.g., "45% of the visitors to the www.PsychCorp.ca are repeat visitors"). The purpose for sharing personal information with the Pearson family of companies is for recognizing customer qualifications and for serving the needs of our market. Such information is never sold or transferred to third parties other than as stipulated previously and under normal business practice and with the appropriate confidentiality agreements in place.

Customers visiting our website may also receive email notifications on specific products, or promotions based on their identified online behaviour. These communication pieces will be targeted and will always include an Opt-Out option.

Opting-Out or Withdrawing Consent

The communications sent by Pearson Assessment are related to the products and services offered by the company. Pearson Assessment, in accordance with the new requirements outlined in PIPEDA, has updated our Customer Registration Form and communication pieces to include an Opt-Out statement. This statement provides the targeted recipients direction on how to remove their name from our mailing list. In situations where Pearson Assessment rents lists from professional organizations, it is the organization/association's responsibility to only provide Pearson Assessment a list of names of individuals who are interested in receiving marketing material.

At any time, a web customer can elect to no longer receive these email communications by responding to the Opt-Out function at the bottom of the communication piece. The customer will be removed from Pearson Assessment's email list and will only receive notices pertaining to updates of products that they have purchased in the past. If a customer elects to Opt-Out, he/she will not receive any marketing related information. However, the customer will continue to receive mailings that affect the administration of products he/she purchased from Pearson Assessment, including Canadian Manuals (discusses the results of Canadian normative studies) and content change notices.

Changing Customer Profile

At any time, customers can contact our Customer Service at 1-866-335-8418 or cs.canada@pearson.com and request changes to their profile, including address updates and opt-out requests.

Collection of Normative Data for Standardization

The publishing of Canadian adaptations requires Pearson Assessment to collect data on a sampling of the Canadian population. Throughout the entire standardization process, Pearson Assessment follows procedures that ensure information is collected, analyzed, and stored in a secure manner. Pearson Assessment also takes security measures regarding each completed test received. The data collected is de-identified as each case is assigned a number and that number is used throughout the standardization process.

The findings from the data analysis are stated in a generic manner in manuals, marketing pieces, journal articles, etc. This process is also followed with our clinical sampling process. The cases are collected with permission from the facility/institution responsible for obtaining consent from the guardian or the individual being assessed. The clinical cases collected are provided to Pearson Assessment without the examinee's name to ensure anonymity. In published materials, clinical cases are assigned fictitious names to further ensure privacy.

For additional information regarding the protection of information collected during the standardization process, please contact Marie-Josée Gendron at 1-800-387-7278, ext. 2130.

Disclosure

Pearson Assessment may disclose personally identifiable information collected through normal business activities such as website tracking, interacting with potential customers at conferences, and marketing mailings in the following ways:

• In the event of an asset sale, merger, restructuring, reorganization, liquidation, or similar transaction Pearson Assessment may transfer information to the successor company.
• When Pearson Assessment believes such disclosure is required by law or for the protection of persons or property.
• With your consent.

Security

Customer information collected through various marketing means is housed in our customer database. Customer Registration Forms are filed in a secure area, once the information collected on the form is entered into our database. The same procedure is followed for information collected during research studies. The database and secure areas are limited to access by selected individuals with either a password or a key. Pearson Assessment will retain this information for the duration of the customer's involvement with Pearson Assessment. If a customer communicates to Pearson Assessment that he/she is no longer a customer, Pearson Assessment will destroy the customer's information 5 years from the notification. At anytime, a customer can contact Pearson Assessment and inquire about his/her profile and ask that information be removed from their profile. Each Pearson Assessment employee signs confidentiality agreements upon employment with the company, and is trained to carry out and implement Pearson Assessment's privacy policy

The information collected on our website is electronically stored in our web customer database and our main customer database. Access to electronically stored information is limited and password protected. The online Customer Registration Form is printed and once entered into our customer database, the hard copy is stored under the customer account in the secure area. Pearson Assessment will retain this information for the duration of the customer's involvement with Pearson Assessment. If a customer communicates to Pearson Assessment that he/she is no longer a customer, Pearson Assessment will destroy the customer's information 5 years from the notification. At anytime, a customer can contact Pearson Assessment and inquire about his/her profile and ask that information be updated or removed from their profile. Each Pearson Assessment employee signs confidentiality agreements upon employment with the company, and is trained to carry out and implement Pearson Assessment's privacy policy.

PIPEDA

The Canadian Psychological Association (CPA) and leading Canadian test developers, including Pearson Assessment believe that Test Record Forms or Protocols may not be disseminated to persons who claim that they are entitled to copies under the Personal Information Protection and Electronic Documents Act (PIPEDA). It is Pearson Assessment's position along with CPA and other leading test developers that test items are trade secrets and that such information is not required to be disclosed under PIPEDA. Pearson Assessment has claimed trade secret status for its test record forms and protocols for many years in order to preserve the validity of these tools used by the professional community for the benefit of the general public. For additional information on CPA's position, please visit its website, www.cpa.ca.

Additional Information on Pearson Assessment's Business Policies

For more information pertaining to our policies, please see our Terms and Conditions of Purchase and Qualifications for Test Purchase, accessible through our website at www.PsychCorp.ca. Terms and Conditions of Purchase and Qualification for Test Purchase policies are also printed in our catalogue. If you require a hard copy of this Privacy Policy, please contact our Customer Service department at 1-866-335-8418.

Any changes to our policies will be written and printed in our catalogues or posted on our website for your convenience.

Privacy Contacts

For additional information pertaining to Canada's federal privacy legislation, please visit the Government of Canada Privacy Commissioner's website at www.privcom.gc.ca.

If you have any questions regarding Pearson Assessment's Privacy Policy, please contact:

Scott Pawson, General Manager
scott.pawson@pearson.com
Phone: 1-800-387-7278, ext. 2133
Fax: 416-255-1621

Last modified on July 11, 2007