The Canadian Seed Growers’ Association (CSGA) is committed to protecting personal information and meeting or exceeding the requirements in Canada’s privacy laws, including the Personal Information Protection and Electronic Documents Act.
This Privacy Policy sets out the principles and procedures that CSGA follows in meeting its privacy commitments. It also describes how your personal information is collected, used, and shared by CSGA to fulfill its regulatory and related responsibilities and to operate its pedigreed seed crop certification service.
Who we are
The Canadian Seed Growers’ Association (CSGA) is authorized by the federal Seeds Act and the Seeds Regulations as the Canadian agency responsible for prescribing varietal purity standards and certifying seed crops of all agricultural crops, with the exception of potatoes.
Many CSGA activities involve close cooperation and require the sharing of information with the Canadian Food Inspection Agency (CFIA), CSGA Branches, and CSGA provincial associations across Canada.
How to contact us
If you have any questions about the CSGA Privacy Policy and practices, the CSGA Privacy Officer can be reached by:
- Phone: 613-236-0497
- Letter: 21 Florence Street, Ottawa, Ontario K2P 0W6
What is Personal Information?
Reference to “Personal Information” in this Privacy Policy means any information about an identifiable individual or that allows an individual to be identified. The personal information that CSGA collects includes the following:
- Home addresses
- Home telephone and facsimile numbers
- Email addresses
- Personal identification numbers (e.g., account number)
- Field information (e.g., varieties, crop kinds, acreage, previous land use, quantity of seed harvested per crop certificate)
- Personal information (e.g., seed production history, crop certificate assignments)
Information that is aggregated and/or de-identified and cannot be associated with an identifiable individual is not considered to be Personal Information.
Collection of personal information by CSGA
CSGA collects personal information from applicants, and uses and discloses such information, only to provide the services that applicants have requested and to comply with regulatory requirements.
By providing CSGA with your personal information, you consent to the collection, use, disclosure, and retention of that information by CSGA in accordance with this Privacy Policy and as otherwise permitted by applicable law. By signing a CSGA application form such as the Application for CSGA Seed Crop Certification, CSGA Membership Application/Renewal, or Application for Variety Certification Eligibility, you are formally acknowledging this consent.
CSGA collects personal information in the following circumstances:
- When you complete the Application for CSGA Seed Crop Certification, CSGA Membership Application/Renewal, Third Party Account Information and Consent, the Application for Variety Certification Eligibility or other service forms;
- When you subscribe to receive news and information from CSGA;
- When you contact us by any means;
- When you visit our website;
We may also use financial details, such as payment card details, via our third-party payment services provider when you make an online purchase from us, but neither we nor our payment services provider store this information.
We also collect, use, and share aggregated data such as statistical data on the proportion of website visitors using the various parts and features of the site. These are collected through the use of automated technologies including our use of cookies, server logs, and similar technologies as described in the Automated Collection section below.
Automated collection
CSGA may automatically collect certain information regarding your use of the website (seedgrowers.ca and seedcert.ca) and sub-pages (the “Website”). For example, we may collect:
- the dates and times that you use the Website;
- the browsers, operating systems, software and devices that you use to access the Website;
- the address of the website you came from;
- a general geolocation and your IP address; and
- details of your use of the Website, including the pages you visit, the duration of your visit and the number of times that you visit the Website.
In particular, CSGA uses Google Analytics to collect information regarding your use of the website. For more information, please see the privacy policy of Google Analytics.
The Websites may use technologies (e.g., cookies, web beacons, tokens, pixels, tags) to collect information that enables CSGA to improve its products, services, client communications, and advertising and to prevent fraud. CSGA may use information collected through technological means to recognize you as a user of the website, to facilitate and improve your use of the website, and to confirm that messages have been delivered to and opened by you.
The use of cookies is required to validate return users, maintain user preferences, and record your progress while logged into the Website.
You may choose to decline or disable cookies if your web browser or device permits but doing so may affect your ability to access or use certain features of the Website.
Some of the information automatically collected by technological means is non-personal information (because the information does not identify you), and CSGA handles that non-personal information as explained below in this Privacy Policy unless applicable law requires otherwise.
Withdrawing your consent
You may withdraw your consent to the collection, use, and disclosure of Personal Information in accordance with this policy at any time upon reasonable notice to CSGA in writing, subject to legal or contractual restrictions. We will advise you about any consequences of doing so. In some circumstances, legal requirements may prevent you from withdrawing consent. To withdraw your consent, please contact us as set out in the How to contact us section.
How we use and disclose personal information
CSGA uses or discloses personal information only for purposes for which it has consent or as required by law. This includes:
- In accordance with your consent (either express or implied) to the disclosure of personal information.
- As required by pedigreed seed crop certification standards, CSGA documents the work it performs in records. Such records include personal information obtained from an applicant or the CFIA-authorized inspection service and CFIA-authorized inspector.
- The personal information collected from an applicant during the course of a crop production year may be disclosed to full time and contracted CSGA employees (e.g., programmers, IT technicians) to the extent required to assess compliance with applicable standards and CSGA policies, including providing quality control reviews of work performed and maintenance and development of database operating systems.
- CSGA collects fees associated with CSGA Branch and CSGA provincial association membership and acreage fees and passes those fees to those organizations. Information necessary for the CSGA Branches and CSGA provincial associations to conduct their business of communicating with, and providing services to, members in their region is disclosed to the relevant CSGA Branch or CSGA provincial association.
- Variety-specific production and personal information may be disclosed to the Canadian Representative(s) and Breeder responsible for a specific variety.
Suppliers and Service Providers
CSGA may share your personal information to its suppliers and service providers working on our behalf to collect, store, process, and safeguard your personal information (including service providers that provide information technology, payment processing, email delivery, marketing, and customer support services).
Personal information is shared with suppliers and service providers for the following purposes:
- to assist CSGA in the provision of information and services to you;
- to provide services to CSGA;
- to assist CSGA to use your personal information as set out in this Privacy Policy and as otherwise permitted by applicable law.
When we use suppliers or service providers, we only share with them the information they need to perform their specific services. They may only use your personal information for the exact purposes we specify in our contract with them, and we work closely with them to obtain assurances that your privacy is respected and protected at all times.
We may also share your personal information with third parties in other limited circumstances where we are required, authorised, or permitted by law.
Legal Disclosures
CSGA may disclose your personal information as required or authorized by applicable law, including to comply with a subpoena, warrant, or court or arbitral order, or litigation disclosure obligation.
Use and disclosure of non-personal information
CSGA may use your personal information to create and collect personal information that has been aggregated or otherwise de-identified so that the information no longer relates to an identifiable individual.
CSGA may use, disclose, transfer, and retain non-personal information for any purpose and in any manner whatsoever.
How we protect personal information
CSGA protects the privacy of personal information in its possession or control by using security safeguards appropriate to the sensitivity of the information.
- Physical security (e.g., restricted access, locked storage areas and filing cabinets) is maintained over personal information stored in hard copy form. Employees are authorized to access personal information based on applicant assignment and quality control responsibilities.
- Authentication is used to prevent unauthorized access to personal information stored electronically. Encryption is used to prevent unauthorized access to personal information received or sent over the Internet.
- For files and other materials containing personal information entrusted to a third party service provider (e.g., programmers, IT technicians), CSGA Branches or regulator (e.g., CFIA), CSGA obtains appropriate assurance to affirm that the level of protection of personal information by the third party is equivalent to that of CSGA.
How long we keep personal information
CSGA retains personal information only as long as necessary to fulfill those purposes for which it was collected, and to meet any applicable legal requirements, and otherwise for as long as is necessary for any purpose for which it can be lawfully used or disclosed by us.
At the end of that period, personal information is either securely deleted, or is anonymized and/or aggregated so that it can be used in a non-identifiable way for statistical analysis and business planning.
We may continue to keep personal information beyond this if we are legally required to, for example, to prevent abuse, fraud, or to resolve disputes.
Where we store and process personal information
CSGA stores and processes personal information in Canada.
Any transfer of your personal information will follow applicable laws including, where required, implementing contractual safeguards to ensure the level of protection equivalent to applicable laws, and we will treat such personal information under this Privacy Policy.
Changes to this Privacy Policy
We may make changes to this Privacy Policy from time to time at our sole discretion. Any changes we make will be effective when we post the revised policy on our websites. If we make any significant changes to the Privacy Policy, we will post a notice on our websites or contact you to inform you when required by law.
By continuing to interact with us after the modified version of the Privacy Policy has been posted, you are accepting the changes to the Privacy Policy, subject to any additional requirements that may apply.
Right of access, correction, or updates to your personal information
CSGA responds on a timely basis to requests from applicants about their personal information which CSGA possesses or controls.
Individual CSGA applicants have the right to contact CSGA and obtain access to their personal information. Similarly, authorized employees of organizations that are applicants to CSGA have the right to contact CSGA and obtain access to personal information provided by that applicant. In certain situations, however, CSGA may not be able to give applicants access to all their personal information. CSGA will explain the reasons why access must be denied and any recourse the applicant may have, except where prohibited by law. Exceptions may include, for example, information that contains references to other individuals, information that we cannot disclose for legal, security, or commercial proprietary reasons, information that is subject to solicitor-client or litigation privilege, and information that is prohibitively costly to provide.
You may request access to your information using the contact information set out at the outset of this Privacy Policy. Please include sufficient details to enable us to identify you and to retrieve your information. Any personal information that you provide to us to facilitate access or correction will be used only for this purpose.
Challenge to compliance
Applicants may challenge CSGA compliance with its Privacy Policy.
CSGA has policies and procedures to receive, investigate, and respond to applicants’ complaints and questions relating to privacy.
To challenge CSGA compliance with its Privacy Policy, applicants are asked to provide an email message or letter to the Privacy Officer (see contact information under the How to contact us section above). The Privacy Officer will ensure that a complete investigation of a complaint is undertaken and will report the results of this investigation to the complainant, in most cases, within thirty (30) days.
