At PHC-MPC, we are committed to providing our clients, customers, and members with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our members, clients, customers and partners, protecting their personal information is one of our highest priorities.
While we have always respected our participants’, clients’, customers’, members’ 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 clients, customers, 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.
Personal Information –means information about an identifiable individual. This may include but is not limited to name, address and phone number, e-mail address, 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, occupation, 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 PHC-MPC complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the participant, client, customer, member 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 participant, client, customer and member information that is necessary to fulfill the following purposes:
Examples of purpose statements, which may or may not be applicable to your organization, include:
• To verify identity;
• To verify creditworthiness;
• To enroll the participant in a program;
• To link to project details in the context of this research initiative
• To send out association membership information;
• To ensure a high standard of service;
• To meet reporting and regulatory requirements as outlined by partners, funders, or various levels of government (municipal, provincial, federal);
• To process payments;
Policy 2 – Consent
2.1 We will obtain participant, client, customer, member 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 in writing, electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the participant, client, customer, member voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a participant, client, customer, member 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 and the participant, client, customer, member does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to participate in the research initiative, provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients, customers, members can withhold or withdraw their consent for PHC-MPC to use their personal information in certain ways. A participants’ client’s, customer’s, member’s decision to withhold or withdraw their consent to certain uses of personal information may restrict his or her eligibility to participate in the research initiative, or may restrict PHC-MPC’s ability to provide a particular service or product. If so, we will explain the situation to assist the participant, client, customer, member in making the decision.
2.5 We may collect, use or disclose personal information without the client’s, customer’s, member’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, Internet, social medial sites such a Facebook, Twitter, LinkedIn, business cards, etc.);
• When we require legal advice from a lawyer;
o For the purposes of collecting a debt;
o To protect ourselves from fraud;
o To investigate an anticipated breach of an agreement or a contravention of law.
PHC is not responsible for any information or its’ use by other parties.
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose participant, client, customer, member personal information where necessary to fulfill the purposes identified at the time of collection, such as:
• To report project results, research initiatives and findings to partners, funders, or various levels of government (municipal, provincial, federal).
• To conduct participant, client, customer, member surveys in order to enhance the provision of our services.
• To contact participants, clients, customers, members directly about products and services that may be of interest.
3.2 We will not use or disclose participant, client, customer, member personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell participant, client, customer, member lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use participant, client, customer, member personal information to make a decision that directly affects the participant, client, customer, member, we will retain that personal information for at least one year so that the participant, client, customer, member has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain participant, client, customer, member 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 participant, client, customer, member personal information is accurate and complete where it may be used to make a decision about the participant, client, customer, member or disclosed to another organization.
5.2 Clients, Customers, 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.
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. If the correction is not made, we will note the participants’, clients’, customers’, members’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of participant, client, customer, member 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 participant, client, customer, member personal information is appropriately protected: the use of locked filing cabinets; the use of user IDs, passwords, 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 client’s, customer’s, member’s personal information such as shredding documents and securely 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 Clients, Customers, Members Access to Personal Information
7.1 Participants, clients, customers, members have a right to access their personal information, subject to limited exceptions, as outlined in section 23 of PIPA.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. Requests to access personal information should be forwarded to the Privacy Officer.
7.3 Upon request, we will also tell participants, clients, customers, 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 fee of $25 may be charged for providing access to personal information. Where a fee may apply, we will inform the participant, client, customer, member of the cost and request further direction from the participant, client, customer, member 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 participant, client, customer, member in writing, providing the reasons for refusal and the recourse available to the participant, client, customer, member.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer or designated individual is responsible for ensuring PHC-MPC’s and www.passivehousecanada.com’s compliance with this policy and the Personal Information Protection Act.
8.2 Participants, clients, customers, members should direct any complaints, concerns or questions regarding PHC-MPC’s and www.passivehousecanada.com’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the participant, client, customer, member may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for PHC-MPC’s and www.passivehousecanada.com’s Privacy Officer or designated individual:
Senion Manager, People & Operations
Suite 113 – 1834C Oak Bay Ave
Victoria, BC, V8R 0A4