Privacy Policy

1. Introduction

SnapShotHR Consulting ("we," "us," or "our") is a fractional HR consulting firm based in British Columbia, Canada. We are committed to protecting the privacy and personal information of the individuals and businesses we work with.

This Privacy Policy explains how we collect, use, disclose, and protect personal information in accordance with British Columbia's Personal Information Protection Act (PIPA), SBC 2003, c. 63. Where personal information is transferred across provincial or national borders, the federal Personal Information Protection and Electronic Documents Act (PIPEDA) may also apply.

2. Definitions

"Personal information" means information about an identifiable individual, as defined under PIPA section 1. It does not include business contact information (name, title, business address, business phone number, or business email) when used solely for business-to-business communications, as excluded under PIPA s. 1.

"Services" means the fractional HR consulting services provided by SnapShotHR, including HR compliance auditing, employee handbook development, hiring and onboarding support, employee relations, workplace investigations, termination support, and general HR advisory.

3. Information We Collect

3.1 Information You Provide Directly

When you contact us through our website, email, or phone, or when you use our HR Snapshot assessment tool, we may collect:

• Your name, email address, and phone number
• Your job title, company name, company size, and industry
• Details you submit through contact forms, the HR Snapshot assessment, or email correspondence
• Information related to HR matters you share during consultations

3.2 Information Collected Automatically

When you visit our website, we may automatically collect:

• IP address, browser type and version, and device type
• Pages visited, time spent on pages, and referring URLs

We do not currently use cookies or third-party tracking technologies on our website. If this changes, we will update this policy and implement appropriate consent mechanisms.

3.3 Information from Third Parties

We may receive your information through LinkedIn or referral partners if you engage with us through those channels, or if a mutual contact introduces us with your knowledge.

4. Purposes for Collection

In accordance with PIPA sections 11 through 14, we collect and use personal information only for the following purposes:

1. To respond to your inquiries and provide our HR consulting services
2. To deliver your HR Snapshot assessment results and recommendations
3. To communicate about our services, including scheduling and follow-up
4. To comply with applicable legislation including the BC Employment Standards Act, Workers Compensation Act, and other regulatory requirements relevant to our consulting engagements
5. To send periodic updates about our services, with your consent and in compliance with Canada's Anti-Spam Legislation (CASL)
6. To improve our website and service delivery
7. To fulfil legal obligations

We limit collection to what is reasonable and necessary for these identified purposes (PIPA s. 11).

5. Consent

Express consent is obtained when you submit a contact form, complete the HR Snapshot assessment, email us directly, or opt in to receive communications from us.

Implied consent may apply when you voluntarily provide personal information for an obvious purpose, such as providing your phone number for us to return your call, or when continued use of our website reasonably indicates your agreement (PIPA s. 7(1)).

You may withdraw your consent at any time by contacting us at keith@snapshothr.com, subject to legal or contractual restrictions. Withdrawal of consent may limit our ability to provide certain services.

CASL compliance: Commercial electronic messages (such as service updates or newsletters) require your express opt-in consent. Every commercial message we send includes clear sender identification, our contact information, and a functioning unsubscribe mechanism. Unsubscribe requests are processed within 10 business days.

6. Use and Disclosure

We do not sell, rent, or trade your personal information to any third party.

We may disclose personal information only when:

• You have provided consent for a specific purpose
• It is required by law, including a court order, subpoena, or regulatory investigation
• It is necessary to provide the services you have engaged us for
• It is shared with our professional advisors (lawyers, accountants) who are bound by confidentiality obligations

If we engage third-party service providers (such as email or cloud storage providers), they are contractually required to protect your information to standards consistent with PIPA.

7. Data Security

In accordance with PIPA section 34, we implement reasonable security measures to protect personal information against unauthorized access, collection, use, disclosure, or disposal. These measures include:

• Encryption of data in transit (TLS/SSL)
• Secure email practices and access controls
• Password-protected devices and cloud storage
• Confidentiality agreements for any contractors or service providers

Client employee data handled during consulting engagements is subject to specific confidentiality protocols outlined in our service agreements.

No method of electronic transmission or storage is completely secure. While we take all reasonable precautions, we cannot guarantee absolute security.

8. Data Retention and Destruction

In accordance with PIPA section 35, personal information is retained only as long as necessary to fulfil the purposes for which it was collected, or as required by law.

• Website inquiries: Retained for up to 2 years from last contact, then securely destroyed
• Client engagement data: Retained per the terms of the applicable service agreement and statutory retention periods (the BC Limitation Act, SBC 2012, c. 13, provides a basic 2-year limitation period for most claims)
• HR Snapshot assessment data: Retained for up to 1 year, then anonymized or securely destroyed

9. Cross-Border Data Transfers

In accordance with PIPA section 33.1, we notify you that your personal information may be stored or accessed in jurisdictions outside of British Columbia or Canada. Our website hosting and email services may use infrastructure located in the United States or other countries.

When personal information is stored outside of Canada, it may be subject to the laws of that jurisdiction, including lawful access by government authorities. We take reasonable steps to ensure that any third-party providers maintain privacy protections comparable to those required under PIPA.

10. Your Rights Under PIPA

Under British Columbia's Personal Information Protection Act, you have the right to:

• Access your information (PIPA s. 23): You may request access to the personal information we hold about you. We will respond within 30 business days of receiving your request.
• Request corrections (PIPA s. 24): If your personal information is inaccurate or incomplete, you may request that we correct it.
• Withdraw consent: You may withdraw your consent to the collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions.

To exercise any of these rights, please contact our Privacy Officer using the information below.

If you believe your personal information has been handled improperly, you have the right to file a complaint with the Office of the Information and Privacy Commissioner for British Columbia (OIPC):

11. Privacy Officer Contact

Our Privacy Officer is responsible for ensuring compliance with this policy and with PIPA. For any privacy-related questions, requests, or concerns, please contact:

12. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices or applicable legislation. Material changes will be posted on this page with an updated effective date. We encourage you to review this policy periodically.

Your continued use of our website or services after changes are posted constitutes your acceptance of the updated policy.