For purposes of this policy, personal information is factual knowledge or subjective awareness, recorded or not, about an identifiable individual. Personal information includes, but is not limited to, an individual’s name, age, weight, height, home address and telephone number, e-mail address, race, ethnic origin, sexual orientation, medical information, social insurance number, credit card numbers, marital status, religious affiliations, and education.
Our 10 Privacy Principles
Our procedures for the collection, use, security, and disclosure of personal information are based on the 10 privacy principles of the Canadian Standards Association Model Code for the protection of personal information, which in turn form the basis of the Personal Information Protection Act of British Columbia and the Personal Information Protection and Electronic Documents Act of Canada.
We responsible for maintaining and protecting the personal information in its possession or under its control and has designated one or more individuals to oversee these principles. Overall responsibility for the protection of personal information and compliance with this policy rests with our corporate Privacy Officer (see 10. Inquiries and Complaints for contact information).
- Identifying purposes
The purposes for which personal information is being collected shall be identified and communicated to the provider of this information, either verbally or in writing, before or at the time of collection. The purposes for collecting this information shall be reasonable under the circumstances.
Subject to limited exceptions, we will not collect, use, or disclose personal information without the prior knowledge and consent of the individuals concerned. Consent may be given verbally, in writing, or electronically and may be either express or implied.
The use or disclosure of personal information shall be for the purpose(s) for which it was originally collected. Fresh consent shall be obtained if the information is to be used for a different purpose. Consent may be withdrawn at any time by contacting us.
Consent is not required when collection, use or disclosure is permitted or required by law. Another exception is when information is used for acting in an emergency that threatens an individual’s life, health or personal security.
- Limiting collection
The amount and type of information collected shall be limited to what is necessary to fulfill the identified purposes for which consent to collect the information was received. Personal information shall not be collected indiscriminately.
- Limiting use, disclosure and retention
Personal information may be used or disclosed only for the purpose(s) for which it was collected, unless the individual consents to a new purpose, or the use or disclosure is required or permitted by law. Personal information shall be retained only as long as necessary to fulfill the purpose(s) for which it was collected and/or it is no longer necessary for a business or legal purpose.
We do not sell or otherwise transfer personal information to third parties for marketing or promotional purposes. The personal information of employees shall be disclosed to third parties only for payroll, tax, and benefits administration purposes.
Reasonable efforts are made to keep all personal information as accurate, complete and current as necessary to satisfy the purposes for which it was collected.
We protect personal information within our custody or under our control with reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, or similar risks, regardless of the format in which the information is held (e.g. paper, electronic, audio, or video).
We employ a variety of physical safeguard measures as appropriate to the sensitivity of the information collected. In addition, our outside service providers and agents are required to maintain client confidentiality and may not use personal information for any unauthorized purpose.
All employees are held to strict standards requiring the utmost care and respect in their handling of personal information.
On request, we will provide information to individuals about our personal information policies and procedures, including the following items:
documentation explaining our personal information policies and practices;
contact information of the person to whom inquiries or complaints can be directed;
how an individual can access their personal information; and
the process for making a complaint about our personal information practices.
- Individual access
With some exceptions, individuals have a right to access their personal information held by any us. Upon written request to our Privacy Officer, and within a reasonable time period, we will let the individual know what personal information we are holding, why we are holding it, and to whom it has been disclosed. Individuals are entitled to challenge the accuracy and completeness of that personal information and request that it be amended, if appropriate.
If access to certain personal information cannot be provided, we will explain why, which usually would be due to legal or security reasons, such as information that contains personal information about other identifiable persons or information that is subject to solicitor-client or litigation privilege.
- Inquiries and complaints