At Friends of Beacon Hill Park, we are
committed to providing our members and donors with exceptional service. As providing this service involves the
collection, use and disclosure of some personal information about our members
and donors, protecting their personal information is one of our highest
priorities.
While we have always respected our members’
and donors’ 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 donors 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 members’ and donors’ personal information. Our privacy commitment includes ensuring
the accuracy, confidentiality, and security of our members’ and donors’
personal information and allowing our members and donors to request access
to, and correction of, their personal information.
Definitions
Personal
Information –means information about an
identifiable individual E.g., including name, home address and
phone number. 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 Friends of Beacon Hill Park 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 or donor 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 donor
information that is necessary to fulfill the following purposes:
To verify identity;
To identify member and
donor preferences;
To send out association
membership information;
To contact our members and
donors for fundraising;
To meet regulatory
requirements;
To assess suitability for membership;
Policy 2 – Consent
2.1 We will obtain member and donor 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: e.g., 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 or donor voluntarily
provides personal information for that purpose.
2.3 Consent may also be implied where a member or
a donor is given notice and a reasonable opportunity to opt-out of personal
information being used for mail-outs, the marketing of new services or
products, fundraising and the member or donor 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 or donors can withhold or withdraw their consent for Friends of Beacon
Hill Park to use their personal information in certain ways. A member’s or a donor’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 member or donor in making the decision.
2.5 We may collect, use or disclose personal
information without the member’s or donor’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;
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 member or
donor 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 member or donor
surveys in order to enhance the provision of our services;
To contact our members or
donors directly about products and services that may be of interest
3.2 We will not use or disclose member or donor
personal information for any additional purpose unless we obtain consent to
do so.
3.3 We will not sell member or donor lists or
personal information to other parties unless we have consent to do so.
Policy 4 – Retaining Personal Information
4.1 If we use member or donor personal
information to make a decision that directly affects the member or donor, we
will retain that personal information for at least one year so that the
member or donor has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retail
member or donor 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 or donor personal information is accurate and complete where it
may be used to make a decision about the member or donor or disclosed to
another organization.
5.2 Members or donors 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 member’s or donor’s correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security
of member or donor 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 or donor personal information is appropriately
protected:
The use of user
IDs, passwords, encryption, firewalls; restricting 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 or donor’s personal information such as deleting electronically stored information
and shredding paper documents.
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 or Donors Access to
Personal Information
7.1
Members or Donors have a right to access their personal information,
subject to limited exceptions.
Where such disclosure would reveal personal
information about another individual, health and safety concerns
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, members or
donors 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 or donor of the cost and request
further direction from the member or donor 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 or donor in writing, providing the reasons for
refusal and the recourse available to member or donor.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or
designated individual
8.1 The Privacy Officer or Treasurer is responsible for ensuring Friends of Beacon Hill
Park compliance with this policy and the Personal
Information Protection Act.
8.2 Members or donors should direct any
complaints, concerns or questions regarding Friends of Beacon Hill Park compliance
in writing to the Privacy Officer. If the Privacy Officer is unable to
resolve the concern, the member or donor may also write to the Information
and Privacy Commissioner of British Columbia.
Contact
information for Friends of Beacon Hill Park’s Privacy Officer or Treasurer:
