Change Makers’ Education Society Privacy & Confidentiality Policy
Change Makers’ Education Society Privacy & Confidentiality Policy
Originally Adopted by Board January 25, 2017
Revised and Approved by BOD January 30, 2018
Change Makers’ Education Society respects the right of individuals to the protection of their personal information. Accordingly, Change Makers’ Education Society complies with the British Columbia Personal Information Protection Act (PIPA) and the federal Personal Information Protection and Electronic Documents Act (PIPEDA).
Definition of Personal Information
Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. Personal information does not include the name, title, business address or telephone number of an employee of an organization.
Principle 1 – Accountability
Change Makers’ Education Society is responsible for personal information under its control and shall designate an individual or individuals who are accountable for Change Makers’ Education Society ’s compliance with established privacy principles.
1.1 The name and contact information of the Privacy Officer will be made available to interested individuals through Change Makers’ Education Society’s website, its Privacy Statement or upon inquiry to Change Makers’ Education Society staff.
1.2 Staff and relevant volunteers shall be made aware of the importance of maintaining the confidentiality of personal information and other confidential business information. Board, staff and volunteers will read, sign and follow the privacy protection practices established by Change Makers’ Education Society when collecting, using, disclosing and safeguarding personal information.
1.3 In cases where information has been transferred to a third party for processing or analysis, Change Makers’ Education Society will ensure that the third party has comparable privacy safeguards in place.
Principle 2 – Identifying Purposes
Change Makers’ Education Society will identify the purposes for collecting personal information orally, electronically or in writing when or before the information is collected.
2.1 The purposes will be limited to those that are related to our business and which a reasonable person would consider to be appropriate in the circumstances.
2.2 Change Makers’ Education Society collects personal information for the following reasons:
To understand the needs of literacy learners, practitioners, and volunteers
To ensure a high standard of service
To build and maintain relationships
To provide information about services, professional development, research, and resources
To deliver requested products and services
To conduct research and collect statistical information
To support literacy practitioners with reporting requirements
Principle 3 – Consent
The manner in which Change Makers’ Education Society obtains consent for the collection of personal information varies with the sensitivity of the information being collected. PIPA makes provision for express, implied or deemed consent, depending on the situation.
3.1 In general, the following actions by an individual constitute implied consent for Change Makers’ Education Society to collect, use and disclose personal information for purposes identified to the individual:
• Registration for programs and services, participation in literacy activities
• Acceptance of employment and benefits enrollment by an employee
• Acceptance of a volunteer position or student placement
3.2 Change Makers’ Education Society will make a reasonable effort to ensure that individuals are aware of the purposes for which information is collected at the time of collection. Individuals can give consent:
• In writing, such as when completing a form
• Through an opt-out process, either by checking off a box on a response form or by contacting Change Makers’ Education Society
3.3 Individuals may withdraw consent to Change Makers’ Education Society’s use or disclosure of their personal information at any time with reasonable notice to Change Makers’ Education Society.
3.4 Change Makers’ Education Society may collect, use and disclose personal information without consent if that information is considered by law to be in the public domain. Sources of public information include telephone and professional directories, newspapers, periodicals and public registries.
Principle 4 – Limiting Collection
Change Makers’ Education Society will limit the collection of personal information to that which is necessary and reasonable for the purposes identified under Principle 2.
4.1 Information will be collected by fair and lawful means.
4.2 When collecting personal information, staff and volunteers will usually collect it directly from the individuals (or legal guardians) about whom the personal information pertains.
4.3 Personal information may be collected from other sources with prior consent from the individual, for example, from prior employers, personal references or from other third parties having the right to disclose the information.
Principle 5 – Limiting Use, Disclosure and Retention
Change Makers’ Education Society will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required by law.
5.1 Change Makers’ Education Society does not sell, rent or trade mailing lists.
5.2 Personal information will be retained as long as the purpose for which the information was originally collected remains valid.
Principle 6 – Accuracy
Change Makers’ Education Society will use its best efforts to ensure that information that is used on an ongoing basis, including information that is disclosed to third parties, and information that is used to make a decision about an individual (such as giving recognition) is accurate, complete, and up-to-date.
Principle 7 – Safeguards
Change Makers’ Education Society will protect personal information by making reasonable security arrangements, appropriate to the sensitivity of the information, against such risks as unauthorized access, collection, use, disclosure and disposal.
7.1 All staff and volunteers with access to information will be required, as a condition of employment or volunteer role, to respect the confidentiality of personal information.
7.2 Third parties are expected to safeguard personal information entrusted to them in a manner consistent with the policies of Change Makers’ Education Society. Examples of third parties include mailing services and data collection/analysis providers.
7.3 Retention and destruction – records will be retained in accordance with all legal and regulatory requirements. Personal information that is no longer needed will be destroyed, erased or made anonymous.
Principle 8 – Openness
Change Makers’ Education Society will make readily available to individuals information about its procedures and practices relating to the collection and management of personal information.
8.1 The information made available will include any or all of the following:
• The name or title and contact information of the Privacy Officer who is accountable for compliance with Change Makers’ Education Society’s policies and procedures, and to whom complaints or inquiries can be forwarded;
• The means of gaining access to personal information held by Change Makers’ Education Society;
• A description of the types of personal information held by Change Makers’ Education Society;
• A copy of any document that explains Change Makers’ Education Society’s policies, procedures, standards or codes; and
• The types of information made available to third parties.
Principle 9 – Individual Access
Upon request, Change Makers’ Education Society will inform an individual of the existence, use and disclosure of his or her personal information and will give the individual access to that information.
9.1 Change Makers’ Education Society will respond to such a request within a reasonable length of time that is no longer than one month.
9.2 While the response will typically be provided at no cost to the individual, depending on the nature and amount of information involved, a cost may be imposed.
9.3 The requested information will be made available in a form that is generally understandable. For example, where Change Makers’ Education Society uses abbreviations or codes to record information, an explanation of those codes will be provided.
9.4 For Change Makers’ Education Society to provide an account of the existence, use and disclosure of personal information, an individual may be asked to provide additional information to aid in the search. The additional information provided will only be used for this purpose.
9.5 Upon request, Change Makers’ Education Society will provide specific information about third parties to whom personal information has been disclosed.
9.6 When an individual demonstrates the inaccuracy or incompleteness of personal information, Change Makers’ Education Society will amend the information as required. Where appropriate, the amended information will be transmitted to third parties having access to the information in question.
9.7 Change Makers’ Education Society may not be able to provide an individual with access to some or all of his or her personal information in certain circumstances permitted by law. Some exceptions include, if doing so would likely reveal personal information about a third party or disclosure could reasonably be expected to threaten the life or security of another individual.
Principle 10 – Challenging Compliance
An individual will be able to challenge Change Makers’ Education Society’s compliance with the above principles to the designated person/s accountable for Change Maker’ Education Society’s compliance.
10.1 The name of the Privacy Officer will be known to staff and information about how to contact that person/s will be made available.
10.2 Change Makers’ Education Society will maintain procedures to receive and respond to complaints or inquiries about its policies and practices relating to the handling of personal information. The complaint procedures will be easily accessible and simple to use.
10.3 Individuals who make inquiries or lodge complaints will be given information by Change Makers’ Education Society of the existence of relevant complaint procedures.
10.4 If a complaint is found to be justified, Change Makers’ Education Society will take appropriate measures, including revision of the personal information, and, if necessary, amendment of Change Makers’ Education Society’s policies and procedures.
This policy will be reviewed every 3 years, or as required.
How to Contact the Privacy Officer
Inquiries, complaints, or access requests should be addressed to:
Change Makers’ Education Society
661 McKay Street
Prince Rupert BC V8J 3X6