personal information protection policy
At Volunteer Richmond Information Services, we are committed to providing our staff, volunteers, clients, customers, and members with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about them, 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 our staff, volunteers, clients, customers, and members 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 their personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of their personal information and allowing them to request access to, and correction of, their personal information.
Personal Information –means information about an identifiable individual [E.g., including name, age, home address and phone number, social insurance number, marital status, religion, income, credit history, medical information, education, 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 responsibility for ensuring that Volunteer Richmond Information Services complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the individual 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 information that is necessary to fulfill the following purposes:
- To verify identity;
- To identify staff, volunteer, client, customer, or member preferences;
- To assess qualification of client, customer, member for requested services;
- To deliver requested products and services;
- To provide counselling services;
- To enrol the client in a program;
- To send out membership information;
- To solicit feedback on performance of products and services;
- To contact our volunteers, clients, customers, members and donors for fundraising;
- To ensure a high standard of service to our clients, customers, members;
- To publish recognition awards in newsletters and local newspapers;
- To issue invitations to events;
- To refer parents to registered daycare providers;
- To send regular mail-outs such as newsletters, annual reports and general program updates;
Policy 2 – Consent
2.1 We will obtain 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, or 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 individual voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where staff, a volunteer, client, customer, or member is given notice and a reasonable opportunity to opt-out of his or her personal information being used for the purposes above and they do 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), staff, volunteers, clients, customers, or members can withhold or withdraw their consent for Volunteer Richmond Information Services to use their personal information in certain ways. A 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 them in making the decision.
2.5 We may collect, use or disclose personal information without 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
We will only use or disclose personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes. 3.2
We will not use or disclose personal information for any additional purpose unless we obtain consent to do so. 3.3
We will not sell lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use personal information to make a decision that directly affects the staff, volunteer, client, customer, member, we will retain that personal information for at least one year so that they have a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain 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
We will make reasonable efforts to ensure that personal information is accurate and complete where it may be used to make a decision about the staff, volunteer, client, customer, or member or disclosed to another organization. 5.2
Staff, Volunteers, Clients, Customers, or Members 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. A request to correct personal information should be forwarded to the Privacy Officer. 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 correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of 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 personal information is appropriately protected:
- use of locked filing cabinets;
- use of user IDs, passwords, and firewalls;
- 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 personal information such as
- shredding documents;
- 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 Staff, Volunteers, Clients, Customers, or Members Access to Personal Information
Staff, Volunteers, Clients, Customers, or Members have a right to access their personal information, subject to limited exceptions found in section 23 of Personal Information Protection Act. Some examples include: solicitor-client privilege, disclosure would reveal personal information about another individual, health and safety concerns. 7.2
Requests to access personal information must be made in writing using the Personal Information Request Form and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer. 7.3
Upon request, we will also tell staff, volunteers, clients, customers, or members 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 administration fee of $10 may be charged for providing access to personal information. Where a fee may apply, we will inform the requestor of the cost and request further direction from them 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 requestor in writing, providing the reasons for refusal and the recourse available to the requestor.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer
8.1 The Privacy Officer is responsible for ensuring Volunteer Richmond Information Services’ compliance with this policy and the Personal Information Protection Act.
8.2 Staff, Volunteers, Clients, Customers, or Members should direct any complaints, concerns or questions regarding Volunteer Richmond Information Services’ compliance in writing to the Privacy Officer using the Privacy Complaint Form obtainable from our office. If the Privacy Officer is unable to resolve the concern, the staff, volunteer client, customer, or member may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Volunteer Richmond Information Services’ Privacy Officer:
Elizabeth Specht, Executive Director
Volunteer Richmond Information Services
190 – 7000 Minoru Blvd.,
Richmond, BC V6Y 3Z5