North Vancouver Community Arts Council Personal Information Protection Policy
At North Vancouver Community Arts Council, we are committed to providing our members and customers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our members and customers, protecting their personal information is one of our highest priorities.
While we have always respected our members and customers 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 our members and customers of why and how we collect, use and disclose their personal information, obtain their consent where required, and 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 members’ and customers’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our members’ and customers’ personal information and allowing our members and customers to request access to, and correction of, their personal information.
Personal Information – means information about an identifiable individual such as name, age, home address and phone number, medical information (allergies), and employment information. 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 responsible for ensuring that North Vancouver Community Arts Council complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the member and customer 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 member and customer information such as is necessary to fulfill the following purposes:
- To verify identity; we may collect name, home address, home telephone number, and other identification such as driver’s licence;
- To identify member and customer preferences;
To open and manage an account; we may collect banking information, including credit card information;
- To deliver requested products and services;
- To enrol the client in a program; we may collect age information if applicable to a specific program;
- To send out association membership information;
- To contact our members and customers for fundraising;
- To ensure a high standard of service to members and customers;
- To collect and process payments;
Policy 2 – Consent
2.1 We will obtain member and customer 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, electronically, through an authorized representative; or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the member and customer voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a member and customer 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, or fundraising, and the member and customer 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), members and customers can withhold or withdraw their consent for North Vancouver Community Arts Council to use their personal information in certain ways. A member’s and customer’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 requirement for personal information in order to assist the member and customer in making the decision whether to consent or not.
2.5 We may collect, use, or disclose personal information without the member’s and customer’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 use or disclose member and customer personal information only 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 customer or member surveys in order to enhance the provision of our services;
- To contact our members and customers directly about products and services that may be of interest.
3.2 We will not use or disclose member and customer personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell member and customer lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use member and customer personal information to make a decision that directly affects the member and customer, we will retain that personal information for at least one year so that the member and customer has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain member and customer 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 member and customer personal information is accurate and complete where it may be used to make a decision about the member and customer or disclosed to another organization.
5.2 Members and customers may request correction of their personal information in order to ensure its accuracy and completeness. A request to correct personal information may be made in writing or by phone (subject to verification of identity and authorization) and must 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 members’ and customers’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of member and customer 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 member and customer personal information is appropriately protected. These security measures include:
- the use of locked filing cabinets;
- physically securing offices where personal information is held;
- the use of user IDs and passwords for access to computer systems;
- restricting employee access to personal information as appropriate (i.e., only those that need to know will have access);
- contractually requiring any service providers to provide comparable security measures.
6.3 We will use appropriate security measures when destroying member’s and customer’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 Members and Customers Access to Personal Information
7.1 Members and customers have a right to access their personal information, subject to limited exceptions. A full listing of the exceptions to access can be found in section 23 of PIPA. Some examples include:
- when disclosure would reveal personal information about another individual;
- when disclosure might lead to health and safety concerns;
- under circumstances governed by solicitor-client privilege.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought and is subject to verification of the requestor’s identity and authorization to make the request. Requests to access personal information should be directed to the North Vancouver Community Arts Council’s Privacy Officer.
7.3 Upon written request, we will also inform members and customers 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 member and customer of the cost and request further direction from the member and customer 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 member and customer in writing, providing the reasons for refusal and the recourse available to the member and customer.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer
8.1 The Privacy Officer is responsible for ensuring North Vancouver Community Arts Council’s compliance with this policy and the Personal Information Protection Act.
8.2 Members and customers should direct any complaints, concerns or questions regarding North Vancouver Community Arts Council’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the member or customer may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for North Vancouver Community Arts Council’s Privacy Officer:
North Vancouver Community Arts Council
335 Lonsdale Avenue, North Vancouver, BC V7M 2G3