91资源

91资源 (ECEBC)

Personal Information Protection Policy

 

At 91资源 (ECEBC), we are committed to providing our members, bursary recipients, professional development attendees, and other clients (all stakeholders) with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about all stakeholders protecting their personal information is one of our highest priorities.

While we have always respected privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform all stakeholders of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting all stakeholders personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of all stakeholders’ personal information and allowing all stakeholders to request access to, and correction of, their personal information.
 

Definitions

Personal Information – means information about an identifiable individual (E.g., name, age, home address and phone number, social insurance number, education, employment information, etc.). Personal information does not include contact information (described below).

Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.  Contact information is not covered by this policy or PIPA.

Privacy Officer – means the individual designated responsibility for ensuring that 91资源 (ECEBC) complies with this policy and PIPA.
 

Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the stakeholder voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2 We will only collect stakeholder information that is necessary to fulfill the following purposes:

• To verify identity;
• To identify stakeholder preferences;
• To understand the educational and/or bursary needs of our stakeholders;
• To deliver requested products and services;
• To guarantee a travel or hotel reservation;
• To process a journal subscription;
• To enrol the stakeholder in a program;
• To send out membership information;
• To contact our stakeholders for fundraising;
• To ensure a high standard of service to our stakeholders;
• To meet regulatory requirements;
   

Policy 2 – Consent

2.1 We will obtain stakeholder consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2 Consent can be provided orally, in writing, and/or electronically, or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the stakeholder voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a stakeholder is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising, research and the stakeholder does not opt-out.

2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), stakeholders can withhold or withdraw their consent for 91资源 (ECEBC) to use their personal information in certain ways. A stakeholder’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the stakeholder in making the decision.

2.5 We may collect, use or disclose personal information without the stakeholder’s knowledge or consent in the following limited circumstances:

• When the collection, use or disclosure of personal information is permitted or required by law;
• In an emergency that threatens an individual's life, health, or personal security;
• When the personal information is available from a public source (e.g., a telephone directory);
• When we require legal advice from a lawyer;
• For the purposes of collecting a debt;
• To protect ourselves from fraud;
• To investigate an anticipated breach of an agreement or a contravention of law
   

Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose stakeholder personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:

• To conduct  surveys in order to enhance the provision of our services;
• To contact our stakeholders directly about research, products and services that may be of interest;

3.2  We will not use or disclose stakeholder personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell stakeholder lists or personal information to other parties.
 

Policy 4 – Retaining Personal Information

4.1 If we use stakeholder personal information to make a decision that directly affects the stakeholder, we will retain that personal information for at least one year so that the stakeholder has a reasonable opportunity to request access to it.

4.2 Subject to policy 4.1, we will retain stakeholder personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
 

Policy 5 – Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that stakeholder personal information is accurate and complete where it may be used to make a decision about the stakeholder or disclosed to another organization.

5.2 Stakeholder s may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.

5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the stakeholders ’ correction request in the file.
 

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of stakeholder personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2 The following security measures will be followed to ensure that stakeholder personal information is appropriately protected:

• the use of locked filing cabinets; 
• physically securing offices where personal information is held; 
• the use of user IDs, passwords, encryption, firewalls; 
• restricting employee access to personal information as appropriate; and
• ensuring all digital information is only stored and backed up on Canadian servers

6.3  We will use appropriate security measures when destroying stakeholder’s personal information such as  shredding documents and deleting electronically stored information.

6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
 

Policy 7 – Providing Stakeholders Access to Personal Information

7.1 Stakeholders have a right to access their personal information, subject to limited exceptions.

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.

7.3 Upon request, we will also tell stakeholders how we use their personal information and to whom it has been disclosed if applicable.

7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the stakeholder of the cost and request further direction from the stakeholder on whether or not we should proceed with the request.

7.6 If a request is refused in full or in part, we will notify the stakeholder in writing, providing the reasons for refusal and the recourse available to the stakeholder.
 

Policy 8 – Website

8.1 This website may use cookies to store your preferences or to maintain your logged in state on the website. These cookies are small text files provided to your browser by the web server and are sent back to the server on subsequent visits to pages on the site. You may choose to disable cookies in your browser however doing so may limit the usage of features or functionality on the website.

8.2 The server this website is hosted on records access to the website including, among other details: the IP address, browser version, and operating system provided by the browser when requesting a page. This information may be used in aggregate form for analytical purposes but is not used to personally identify any visitors to the website.

8.3 Information submitted through forms on the website, including personal information, will be recorded and saved to a database on the server. This information may also be forwarded to an email address to notify us of the submission. If you have an account and are signed in when submitting a form, or performing other actions this information may be associated with your account.

8.4 This site also uses Google Analytics. To find out more about how Google uses data when you visit a partner's site or app please visit:
 

Policy 9 – Questions and Complaints:  The Role of the Privacy Officer or designated individual

9.1 The Privacy Officer or designated individual is responsible for ensuring 91资源 (ECEBC)’s compliance with this policy and the Personal Information Protection Act.

9.2 Stakeholders should direct any complaints, concerns or questions regarding 91资源 (ECEBC)’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the stakeholder may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for 91资源 (ECEBC)’s Privacy Officer or designated individual:

Emily Gawlick
Executive Director
executive.director@ecebc.ca