If the policies and procedures outlined in this document do not address a specific situation, individuals are expected to contact our Privacy Officer for guidance or clarification.
- Identifying Purpose
- Limiting Collection
- Limiting Use, Disclosure, and Retention
- Accuracy of Personal Information
- Safeguarding Personal Information
- Access to Personal Information
- Challenging Compliance
Brush Education Inc. is responsible for maintaining and protecting the personal information under its control. Accountability for this function within our organization is held by:Privacy Officer
Brush Education Inc.
Edmonton, Alberta, Canada T6H 4R5
Brush Education Inc. will identify to an individual the purposes for which personal information is collected at or before the time the information is collected. Generally, Brush Education Inc. collects personal information for the following purposes:
- to fulfill customer orders for products and services;
- to manage and develop the business and operations of Brush Education Inc., including personnel and employment matters; and
- to meet legal and regulatory requirements.
However, there may be other circumstances that require such information to be collected and used. The type of information collected by Brush Education Inc. includes (but is not restricted to) name, address, phone numbers, credit card information, and transaction history.
Additionally, Brush Education Inc. routinely collects anonymous, non-personal information through our Web servers. This is information that is not associated with or traced back to a specific individual. Gathered electronically, this information includes the type of Web browser used, the level of encryption a browser supports, and the Internet Protocol address. This information may be used for research and analytical purposes, to examine how the Web site is being used, and to determine how it can be improved.
Cookies are used to store your encrypted user ID and password so that you won't have to type it in each time that you access our e-Library. A persistent cookie is only set if you click on "Remember my password."
An individual's knowledge and consent are required before the Brush Education Inc. is allowed to collect, use, or disclose his or her personal information, except where inappropriate. Where possible, Brush Education Inc. will obtain consent directly from the individual concerned at the time of collection. After having provided consent, an individual has the right to withdraw consent at any time by providing reasonable notice to Brush Education Inc.
In limited circumstances, Brush Education Inc. may use or disclose personal information without the knowledge or consent of the individual, for example, for purposes of debt collection, breaches of agreements, as required by governmental bodies acting with authority, or as authorized or required by applicable legislation.
Limiting Use, Disclosure, and Retention
Brush Education Inc. does not use personal information for purposes other than those for which it was collected, except with an individual's consent or as required by law. Once personal information is no longer required to fulfill the identified purposes or other legal requirements, it will be destroyed, deleted, or made anonymous.
Brush Education Inc. sometimes uses the services of external firms to assist us in communicating with individuals (e.g., surveys and mail distribution) or as a means of providing more effective and efficient services to these individuals (e.g., technology support). Our external suppliers are contractually obligated to keep the information confidential, to use the information only for the purpose requested and to destroy the information when it is no longer required.
Customer information is shared with external service providers only to the extent required for the provision of such services. Furthermore, Brush Education Inc. does not sell personal information to a third-party organization.
Personal information is retained only as long as necessary for the fulfillment of the purposes stated in this policy.
Accuracy of Personal Information
Personal information is kept as accurate, complete and up to date as necessary for the purposes for which it is to be used. Individuals are encouraged to provide updates to their personal information as changes occur, to enable us to continue to provide services to them.
The personal information of customers can be reviewed and modified either directly online or by contacting our Web site administrator.Web Site Administrator
Brush Education Inc.
Edmonton, Alberta, Canada T6H 4R5
Safeguarding Personal Information
Personal information, whatever its form, will be protected by security safeguards appropriate to the sensitivity of the information. The safeguards will protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The measures of protection include:
- physical measures, for example, locking filing cabinets and restricted access to offices;
- organizational measures, for example, security passes and limiting access to the personal information on a "need-to-know" basis;
- technological measures, for example, the use of passwords and encryption; and
- procedural measures, for example, the shredding of sensitive personal information.
Access to Personal Information
Individuals may request a copy of their personal information held at Brush Education Inc. by submitting a written request to the Privacy Officer at the address above. Acceptable proof of identification is required before such information is given out. If you feel the information we have about you is inaccurate, you may request that it be reviewed and, if inaccurate, changed, by contacting the Privacy Officer.
An individual can challenge compliance with the above policy by providing written details of the challenge to the Privacy Officer.
Anti-Harassment and Anti-Discrimination Policy
1. Brush Education’s Commitment
Brush Education Inc. is committed to providing an environment free of discrimination and harassment, where all individuals are treated with respect and dignity, can contribute fully, and have equal opportunities.
By law, every person has the right to be free from harassment and discrimination. Harassment and discrimination will not be tolerated, condoned, or ignored at Brush Education. If a claim of harassment or discrimination is proven, disciplinary measures will be applied, up to and including termination of employment or contract of engagement.
Brush Education is committed to a comprehensive strategy to address harassment and discrimination, including:
- Providing training and education to make sure everyone knows their rights and responsibilities
- Regularly monitoring organizational systems for barriers relating to prohibited grounds of discrimination
- Providing an effective and fair complaints procedure
- Promoting appropriate standards of conduct at all time.
2. Policy Objectives
The objectives of this policy are to:
- Make sure that management, staff, editors, and all who are engaged by Brush Education to work, whether for pay or on a voluntary basis (hereinafter, “Brush Education Personnel”), are aware that harassment and discrimination are unacceptable practices and are incompatible with the standards of this organization, as well as being a violation of the law.
- Set out the types of behavior that may be considered offensive and are prohibited by this policy.
3. Applying the Policy
The right to freedom from discrimination and harassment extends to all Brush Education Personnel.
It is also unacceptable for Brush Education Personnel to engage in harassment or discrimination when dealing with authors, potential authors, those with whom they have professional dealings, or the public.
This policy applies at every level of Brush Education and to every aspect of the workplace environment and working relationship, including recruitment, selection, promotion, transfers, training, remuneration, and termination. It also covers manuscript review and author recruitment and editing.
This policy also applies to events that occur outside of the physical workplace, such as during business and editing meetings, trips, parties, or entertaining.
4. Prohibited Grounds of Discrimination
This policy prohibits discrimination or harassment based on the following grounds, and any combination of these grounds:
- Sexual orientation
- Gender identity
- Gender expression
- Family status
- Marital status
- Place of origin
- Ethnic origin
- Association or relationship with a person identified by one of the above grounds
- Perception that one of the above grounds applies
The following behavior is prohibited:
Discrimination: means any form of unequal treatment based on a prohibited ground of discrimination, whether imposing extra burdens or denying benefits. It may be intentional or unintentional. It may involve direct actions that are discriminatory on their face, or it may involve rules, practices, or procedures that appear neutral, but disadvantage certain groups of people. Discrimination may take obvious forms, or it may happen in very subtle ways. Even if there are many factors affecting a decision or action, if discrimination is one factor, that is a violation of this policy.
Harassment: means a course of comments or actions that are known, or ought reasonably to be known, to be unwelcome. It can involve words or actions that are known or should be known to be offensive, embarrassing, humiliating, demeaning, or unwelcome, based on a ground of discrimination identified by this policy. Harassment can occur based on any of the grounds of discrimination.
Reasonable action taken by the employer or supervisor relating to the management and direction of workers or the workplace is not workplace harassment
Examples of harassment include:
- Epithets, remarks, jokes, or innuendos related to a person’s race, gender identity, gender expression, sex, disability, sexual orientation, creed, age, or any other ground
- Posting or circulating offensive pictures, graffiti, or materials, whether in print form or via email or other electronic means
- Singling out a person for humiliating or demeaning “teasing” or jokes because they are a member of a group defined by a ground of discrimination
- Comments ridiculing a person because of characteristics that are related to a ground of discrimination. For example, this could include comments about a person’s dress, speech, or other practices that may be related to their sex, race, gender identity, or creed.
Sexual and gender-based harassment: Workplace sexual harassment means
- engaging in a course of vexatious comment or conduct against a worker in a workplace because of sex, sexual orientation, gender identity or gender expression, where the course of comment or conduct is known or ought reasonably to be known to be unwelcome, or
- making a sexual solicitation or advance where the person making the solicitation or advance is in a position to confer, grant or deny a benefit or advancement to the worker and the person knows or ought reasonably to know that the solicitation or advance is unwelcome
Examples of sexual and gender-based harassment can include, without limitation:
- Gender-related comments about a person’s physical characteristics or mannerisms
- Paternalism based on gender which a person feels undermines his or her self-respect or position of responsibility
- Unwelcome physical contact
- Suggestive or offensive remarks or innuendoes about members of a specific gender
- Propositions of physical intimacy
- Gender-related verbal abuse, threats or taunting
- Leering or inappropriate staring
- Bragging about sexual prowess or questions or discussion about sexual activities
- Offensive jokes or comments of a sexual nature about another individual
- Rough or vulgar humour or language related to gender
- Display of sexually offensive pictures, graffiti, or other materials including through electronic means
- Unwelcome demands for dates or sexual favours.
Sexual Solicitation: This policy prohibits sexual solicitations or advances by any person who is in a position to deny a benefit to the recipient of the solicitation or advance, including to authors or potential authors. This includes all Brush Education Personnel where one person is in a position to grant or deny a benefit to the other, or to any author or potential author.
Poisoned Environment: A poisoned environment is created by comments or conduct (including comments or conduct that are condoned or allowed to continue when brought to the attention of management) that create a discriminatory work or editorial environment. The comments or conduct need not be directed at a specific person, and may be from any person, regardless of position or status. A single comment or action, if sufficiently serious, may create a poisoned environment.
6. Roles and Responsibilities
All Brush Education Personnel are expected to uphold and abide by this policy, by refraining from any form of harassment or discrimination, by cooperating fully in any investigation of a harassment or discrimination complaint, and by bringing any form of harassment or discriminatory behaviour of which they become aware to the immediate attention of management. Personnel are not to be penalized or disciplined for reporting an incident or for participating in an investigation involving workplace harassment.
The Publisher is responsible for creating and maintaining a harassment and discrimination-free environment, and should wherever possible address potential problems before they become serious. The Publisher will investigate and deal with all complaints or incidents of workplace harassment in a fair, respectful and timely manner. Information provided about an incident or about a complaint will not be disclosed except as necessary to protect staff, to investigate the complaint or incident, to take corrective action or as otherwise required by law.
We encourage anyone who has a complaint against a Brush Education staff member, executive, contactor, consultant or editor at any time to please contact the Publisher. If the Publisher has a personal interest in the matter to be discussed, the report should be made to the Co-Owner. If further assistance is required, a party may contact Alberta Labour.
Other available resources are available online at https://www.alberta.ca/workplace-harassment-violence.aspx
Anyone with concerns can also call Occupational Health and Safety at (780)415-8690, or toll-free at