1. Statement and Purpose:
The Justice Education Society of B.C. (the “Society”) is committed to respecting individuals’ right to privacy. We recognize the need for appropriate protection and management of any personally identifiable information provided to us, whether from our employees, volunteers, donors, customers, participants or the public.
2.2 Written Consent – for the purposes of this policy, written consent includes email.
2.3 Personal Information means information about an identifiable individual including name, age, home address and phone number, social insurance number, marital status, education, employment information and photographs. Personal information does not include contact information (described below).
2.4 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 the Act.
2.5 Privacy Officer – means the individual designated responsibility for ensuring that the Society complies with this policy and the Act.
The Society is accountable for personal information in its custody and control from employees, volunteers, donors, customers, participants or the public.
The Society is responsible for the protection of personal information under its custody or control when dealing with third parties. Care in collecting, using and disclosing personal information is essential to continued public trust in the privacy practices of the Society.
The Society has appointed Linda Windibank, Finance Manager, and Dave Nolette, Communications and Web Manager, as Privacy Officers (see section 3.12).
3.2 Purposes for Collection, Use, and Disclosure
The Society collects and uses personal information for the following purposes:
· to provide requested resources and programs
· employment and benefits
· annual reporting and marketing
· to maintain communication with the public (email updates)
· to verify identity
· to collect and process payments
· to understand the needs of the people we serve
· to meet contractual obligations, legal and regulatory requirements
· to recruit potential staff and volunteers
· to contact previous or potential donors
· funding applications and reports to funders
The Society will obtain consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
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 a person voluntarily provides information for that purpose.
Consent may also be implied where an individual is given notice that personal information will be collected, used or disclosed, and a reasonable opportunity to opt-out.
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), individuals can withhold or withdraw their consent for the Society to use their personal information. A decision to withhold or withdraw consent may restrict the Society’s ability to provide a particular service or product.
3.4 Disclosure of Information to Third Parties
The Society will disclose personal information to third parties in the following situations:
· the fulfillment of purposes identified in Section 3.2;
· when the collection, use or disclosure of personal information is permitted or required by law;
· when the personal information is available from a public source (e.g., a telephone directory);
· when the society requires legal advice from a lawyer;
· to investigate an anticipated breach of an agreement or a contravention of law.
If personal information is disclosed to third parties for the fulfillment of any purposes identified above, the Society will ensure that appropriate undertakings, such as confidentiality clauses in contractual agreements, are employed to protect the transfer and use of personal information. The Society does not and will not sell, trade, or rent personal information to third parties without the individual’s consent.
3.5 Limiting Collection
The Society will collect personal information from employees, volunteers, donors, customers, participants and the public only for the purposes identified in Section 3.2
Unsolicited correspondence that includes personal information from individuals or resumes will be disposed of by the Privacy Officer or designate or protected as per section 3.8.
3.6 Limiting Use, Disclosure, and Retention
The Society does not use or disclose personal information for any purpose other than that for which it was collected, except with the individual’s consent or as required by law.
If information is no longer necessary to fulfill the purpose for which it was collected, the Society’s Privacy Officer or designate will dispose of it after one year, unless further retention is required by law.
The Society will make all reasonable efforts to ensure that personal information is as accurate, complete, and current as required for the purposes for which it was collected.
This includes allowing employees and the people we serve to have the opportunity to review and correct their personal data upon written request.
A request to correct personal information should be forwarded to the Privacy Officer.
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 clients’ correction request in the file.
The Society will protect personal information by making reasonable security arrangements to prevent the risk of unauthorized collection, access, use, disclosure or disposal of personal information.
Safeguards include appropriate physical, administrative, and electronic security measures.
The Society will provide employees with information related to the intended use of personal data and the need to safeguard the privacy of personal information and limit disclosure.
3.9 Access for public, volunteers, staff and Board Members
The Society supports the public’s right of access to information and the right of individuals to access and request correction of personal information about themselves. The Privacy Officer will assist individuals with their access requests to the Society. In certain situations, the Society may not be able to provide access to personal information. If access cannot be provided, the Society will notify the individual making the request in writing of the reasons for the refusal.
3.10 Access to third party personal information about employees
The Society’s Privacy Officer will consider requests regarding personal information about employees. Third party access to confidential personal information such as payroll or employment history will be granted only if the Privacy Officer has deemed it necessary and the employee has provided written consent to the disclosure of that information.
The Society’s Privacy Officer is responsible for ensuring that this policy is consistent with the Act.
3.12 Concerns or Questions regarding Society’s Compliance
You may direct your questions or concerns regarding the Society’s compliance with this policy to the Privacy Officers, Linda Windibank or Dave Nolette, at (604) 660-9870 or email to info@JusticeEducation.ca
or by mail to:
The Justice Education Society of BC
Attn.: Privacy Officer
#260 – 800 Hornby St.
Vancouver, BC V6Z 2C5