Last updated: August 3, 2021
At Synergy Inmate Phones d/b/a Synergy Technology Solutions (“Synergy”), your privacy is of great importance to us. Synergy is dedicated to the protection of the personal information of those using our services, such as inmates and their family members/friends who deposit funds into an account.
Accountability for Your Privacy
Personal Information and How We Collect It
Obtaining Your Consent
Purposes for Collecting and Using Your Information
Sharing Your Information
Keeping Your Information Safe
Accessing Your Personal Information
How Long We Keep Your Information
Our Privacy Complaint and Breach Management Process
Cookies and Website Log Data
Social Media, Chat Rooms and Discussion Forums
Changes to this Policy
Getting in Touch
1. Accountability for Your Privacy
Synergy takes full responsibility for the management and confidentiality of personal information in our custody. Personal information is collected, used, shared and stored in accordance with the Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5 and all applicable provincial public and private sector privacy laws that apply to Synergy. Synergy also respects the privacy best practice principles contained in the Canadian Standards Association Model Code for the Protection of Personal Information,CAN/CSA-Q830-96.
Synergy has appointed a Privacy Officer who oversees compliance with privacy laws and best practice. The Privacy Officer’s duties include:
- Developing and, on a regular basis, reviewing Synergy’s policies and practices to ensure consistent implementation and compliance;
- Ensuring all staff and contractors are trained on privacy best practices and are aware of the importance of safeguarding any personal information that they are privy to;
- Ensuring that all inquiries and complaints relating to privacy are appropriately handled; and
- Ensuring all third parties to whom Synergy provides access to personalinformation adhere to appropriate standards of care in managing that information.
2. Personal Information and How We Collect It
‘Personal information’ is any information about an identifiable individual as contained in the Inmate Telephone System. This may include one’s name, mailing address, e-mail address, phone number, date of birth, gender, inmate identifier, who you transact with, and who receives funds from you.
Note that if you are a friend or family member and access Synergy’s serviceswith your location services settings enabled, we may also be able to identify the location of your device.
Aggregate anonymized information such as usage statistics that cannot be associated with a specific individual is not personal information.
Personal information is collected via our website. We collect limited personal information as is reasonable to offer and deliver our services.
When it is practical to do so, we will collect the information we need directly from you. In those instances where information is collected from a third party, your personal information will be respected in exactly the same way as if we collected it from you personally.
3. Obtaining Your Consent
We collect, use and disclose your personal information with your consent, except as required or permitted by law. Your consent may be expressly obtained or may be implied, when we can reasonably conclude that you’ve given consent by some action, such as processing transactions when you have provided your payment details.
Note that there may be instances where the law permits the collection, use or disclosure of your personal information without your consent, for example in the context of a fraud or other investigation by a facility or law enforcement, to respond to an authorized inquiry of a government agency, or where necessary to protect our legal interests or the safety of individuals. In other contexts, if you would like to withdraw consent or have your information destroyed from our systems, you may contact us to determine your legal rights.
Where an individual is not capable of consenting to the collection, use or disclosure of his or her own personal information but you wish to provide us with that information, please ensure you are legally entitled to do so on behalf of that individual. Also, if you are a friend or family member who provides Synergy with an inmate’s information, you represent and warrant that you have all the necessary rights and consent to disclose such information to Synergy in connection with its services.
Personal information about children under the age of thirteen (13) cannot be provided to Synergy on-line. We never knowingly collect information on-line from children under the age of thirteen (13) without verifiable parental consent. If you are under the age of thirteen (13), please do not provide us with information of any kind whatsoever through our website.
4. Purposes for Collecting and Using Your Information
Personal information is collected and used by Synergy for one or more of the following specific purposes:
- To look up an account, as well as to manage or service accounts;
- To process transactions such as adding money to an account or providing a refund;
- To contact you about your usage of our services and to assist you when responding to your Customer Service requests or inquiries;
- To improve our services and programs;
- To market and promote our services that we believe you would benefit from knowing about. We may also tailor our offerings to you based on your demographics or other information, with the objective of meeting your specific needs;
- To assess and manage risk, including detecting and preventing fraud or error;
- To diagnose problems with our servers, services or our website;
- For internal and external audits;
- To carry out our contractual obligations with facilities, meet legal and regulatory processes and requirements, or bring or defend against legal actions; and
- For such other purposes for which you have provided your consent, or as otherwise permitted or required by law.
5. Sharing Your Information
Your personal information is shared only to the extent required to provide you with our services, and to comply with legal requirements. Your personal information may be accessible to Synergy’s clients, partners, agents and third-party service providers who assist us in carrying out our business and providing you with our services, such as the following:
- Correction facilities who can search for activity or process transactions at their facility with their access to Synergy Deposits System;
- Third Parties with whom Synergy might partner who provide the technology and maintenance and support services, as well as other IT contractors and developers as needed to support our servers and Synergy Deposits System;
- For processing financial transactions, your personal information may be collected by our payment partners for the purpose of transacting with you; and
- Customer Service representatives who are contractors acting on Synergy’s behalf.
These trusted entities comply with strict privacy and confidentiality responsibilities due to the laws that apply to them and/or contractual obligations imposed upon them. We take reasonable steps to ensure that any third parties who we entrust with your personal information are reputable, and have safeguards in place to protect your information.
Synergy does not sell personal information about the user of our services to any third parties.
Note that we may disclose your personal information as required to reduce the risk of harm to an individual; or to respond to law enforcement requests or to a court, administrative tribunal, governmental agency or other body authorized to compel the disclosure of your personal information.
6. Keeping Your Information Safe
Synergy acknowledges that a data security breach could result in potential harm to individuals whose personal information is entrusted to Synergy. Thus, we have implemented critical physical, organizational and technical measures to guard against unauthorized or unlawful access to the personal information we manage and store. We have also taken steps to avoid accidental loss or destruction of, or damage to, your personal information. While no system is completely secure, the measures implemented by Synergy significantly reduce the likelihood of a data security breach.
Here are some examples of the security controls we have in place:
- Hosting our databases on Canadian data servers at all times and using sophisticated Canadian data centres with effective physical and logical data security controls;
- Secure office premises and a secure shredding practice for any paper records generated;
- The use of firewalls, anti-virus programs and robust authentication processes, including complex passwords, for access to electronic records and the Inmate Telephone System;
- The use of intrusion detection and prevention software to provide alerts for suspicious activity;
- Encryption of data at rest and Secure Socket Layer (SSL) encryption for data in transit sent over the Internet, such as when you supply information on our website;
- Role-based and limited access to personal information based on the need-to-know principle;
- Initiatives to raise awareness amongst employees and contractors of their data protection responsibilities; and
- Regular reviews of privacy compliance and best practice initiatives.
7. Accessing Your Information
We make every effort to ensure that the personal information contained in records that we have custody over is accurate, complete and up-to-date for the purposes for which we collect it. Inmates must make requests for access to their personal information to their facility who will seek Synergy’s assistance if required.
As a family member or friend, you can make a written request for access to or correction of your personal information at any time, and it will be reviewed. You will need to provide us with information to authenticate you, help us process your request and locate the information you require.
If you need assistance in preparing your access request, please get in touch with our Privacy Officer (see contact information at the end of this policy). Upon your written request, Synergy will also inform you of how your personal information has been or is being used, and who your personal information has been shared with, unless we are legally required to withhold this information.
Synergy responds to access requests within 30 days, unless an extension of time is required. We may charge a fee to cover any expenses related to responding to your access request. Note that there may be contexts where access is refused or only partial information is provided, for example, in the context of an on-going investigation or where another individual’s personal information or identity must be protected.
8. How Long We Keep Your Information
Synergy retains personal information for as long as necessary to fulfill legal or business purposes and in accordance with the retention schedules set by the correction facilities we work with. Personal information that has been used to make a decision about an individual shall be retained long enough to allow the individual access to the information after the decision has been made.
Once your information is no longer required to meet legal or a facility’s contractual requirements, it is securely destroyed, erased or made anonymous by Synergy. Keep in mind however that residual information may remain in back-ups for a period of time after its destruction date.
9. Our Privacy Complaint and Breach Management Process
Synergy takes privacy complaints very seriously and has a process in place for managing any privacy related concerns to ensure that they are responded to in a timely and effective manner. Any suspected privacy breach must be escalated in accordance with our internal Privacy Breach Management Procedure to Synergy’s Privacy Officer who oversees the containment, investigation and corrective actions for the breach situation.
10. Cookies and Website Log Data
Synergy installs first party cookies on devices that access its websites unless the browser used by the device has disabled the installation of cookies. The first party cookies Synergy installs ensure the website functions as intended, and in some circumstances are essential for Synergy to provide services requested by website visitors. For example, enabling first party cookies is required for the inmate account search function. Non-essential cookies are also used by Synergy to analyze and improve the performance of our websites, design and layout, and your overall on-line experience. For example, Synergy uses web analytics services, including Google Analytics, to understand the interests of our visitors and analyze traffic patterns. We make no effort to personally identify you based on your visit to our site. If you wish, you can make use of Google’s free Google Analytics Opt-Out Browser Add-On.
11. Social Media, Chat Rooms and Discussion Forums
Synergy’s use of social media serves as an extension of our presence on the Internet and helps us build a positive brand image as well as offer our users personalized service. Synergy social media accounts are not hosted on Synergy’s servers. Please note that when you publicly post personal information on social media, it can be viewed by anyone who visits our platforms. Users who choose to interact with Synergy via social media, such as Twitter, should read the terms of service and privacy policies of these services/platforms.
12. External Links
We may offer links from our website or pre-approved apps on our tablets to the sites or services of third parties as required for payment processing or that may be of interest to you. Since these sites are not owned or controlled by us, Synergy makes no representations as to such third parties’ privacy practices and we recommend that you review their privacy policies before providing your personal information to any such third parties.
13. Changes to this Policy
14. Getting in Touch
Any inquires, concerns or complaints regarding privacy should be directed to:
Synergy Inmate Phones
12126 El Sendero St.
San Antonio, TX 78233
Email: [email protected]
Your concerns will receive prompt attention. Our Privacy Officer can also provide you with more detailed information about Synergy’s information-handling practices. Keep in mind however that e-mail is not secure forms of communication, so never send confidential personal information to us this way.
Thank you for continued trust in Synergy Inmate Phones.