PAC Privacy Policy

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PAC Privacy Policy

The PAC has undertaken the following personal privacy protection policy:

ECOLE DOROTHY LYNAS SCHOOL PAC
PERSONAL INFORMATION PROTECTION POLICY

01/13/2004

Protecting Client Information
Ecole Dorothy Lynas School Parent Advisory Council has always been committed to protecting the privacy of personal information and has long-standing procedures and security measures to preserve the confidentiality of sensitive financial and personal information.

Scope of this Policy

 Personal Information Protection
This Policy sets out the principles that will be observed by Ecole Dorothy Lynas School Parent Advisory Council (hereinafter “the PAC”) in the collection, use, and disclosure of information about any identifiable individual.

Basis of this Policy
This Policy complies with the principles expressed in the Personal Information Protection Act (hereinafter “PIPA”) and the BC Privacy Act and is consistent with good administrative practice.

Definitions

For the purposes of this Policy:

Collect

To gather, receive, or obtain personal information from any source outside the PAC.

Personal Information

Means any information about an identifiable individual, whether it was collected before or after this Policy was first published. It includes, but is not limited to, the individual’s name, address, age, telephone number(s), email address(es), child’s name, photographs, hot meal selections, accounts receivable status, donation information, schedule of availability for volunteer activities, committee commitments, emergency contact information, and emergency comfort kit information. With respect to any specific individual the PAC may or may not have personal information within these categories.

Third Party

Anyone other than the PAC or its committee members.

Use of Personal Information

To review, access, employ, or apply Personal Information for any purpose by and within the PAC and its committees.


Personal Information Protection Principles

The collection, use, and distribution of Personal Information by the PAC shall be governed by the following principles:

1. Accountability Principle

The PAC is responsible for all personal information under its control and our Privacy Officer is accountable for the PAC’s compliance with the principles described in this Policy.

PSIM’s Privacy Officer may be contacted at:

Privacy Officer
Ecole Dorothy Lynas School Parent Advisory Council
4000 INLET CRESCENT
NORTH VANCOUVER BC V7G 2R2

Under this Principle the PAC is responsible not only for personal information in its physical possession or custody, but also for personal information that is transferred by the PAC to a third party for processing. The PAC will obtain undertakings with such third parties to ensure that they give a comparable level of protection to the personal information while it is being processed.

The PAC has established and implemented:

a. Procedures to protect personal information;
b. Procedures to receive and respond to complaints and enquiries;
c. A volunteer training and information program to explain this Policy and related practices

The Privacy Officer is entitled to delegate day-to-day responsibility for administration of this Policy and related policies and practices to other PAC members, but notwithstanding such delegation, the Privacy Officer remains accountable under this Principle.


2. Identifying Purposes Principle

The purposes for which personal information is collected will be identified by the PAC at or before the time the information is collected. The PAC will also document the purposes for which personal information is collected.

Depending on the specific circumstances, the PAC may collect personal information for one or more of the following purposes:

a) Communication with a PAC member;
b) Issue tax receipts and manage the donation program(s);
c) Management of one or more of the PAC’s programs including “hot dog days”, emergency preparedness, callback, Seycove Auction, Spring Carnival, and others.
d) comply with certain laws and regulations;
e) determine eligibility for certain programs offered by the PAC

When an individual provides the PAC with personal information, the PAC will ensure that the purpose(s) for which the personal information is collected, used, and disclosed is identified by the PAC and communicated to the individual providing the information. The PAC will collect only the personal information that is necessary for the purposes that have been identified to the individual.

Circumstances may arise where the PAC wishes to use or disclose personal information for a new purpose. The PAC will ensure that personal information is not used or disclosed for that new purpose unless the individual is informed of the new purpose and gives his or her consent. The PAC will ensure that any questions about the purpose of collecting, using, or disclosing personal information are candidly and clearly answered.

The methods employed by the PAC to notify individuals of the proposed purposes for which personal information is collected, used, or disclosed may be by telephone, in person, in writing, by email, or by any other means of communication, which is likely to reach the individual. The PAC will provide an explanation that is easily understandable.

3. Consent Principle

The knowledge and consent of an individual, express or implied, are required for the collection, use, or disclosure of personal information by the PAC, except where allowed by law.

Except where the under-noted limited exceptions apply, the PAC will make a reasonable effort to ensure that the individual is advised in advance of the purposes for which his or her personal information will be collected, used, or disclosed. To make the individual’s consent meaningful, the PAC will state the purposes in such a manner that the individual can reasonably understand how the information will be used or disclosed.

The PAC will not, as a condition of membership or the supply of services or products, require an individual to consent to the collection, use, or disclosure of personal information beyond that required to fulfill the PAC’s explicitly specified and legitimate purposes.

An individual may opt out of proposed collection, use, and disclosure purposes, however, in certain circumstances, if the individual elects to opt out, the PAC may not be able to provide certain products, services, or programs to the individual or the individual may be ineligible for or be unable to use certain products, services, or programs the PAC provides.

PAC committee members involved in obtaining the consent of individuals to the collection, use, or disclosure of their personal information will be adequately trained to explain the nature and scope of the consent sought by the PAC.

Information collected in the past

With respect to the personal information collected in the past before this Policy came into effect, the PAC will make reasonable efforts to ensure that each individual who has not already expressly indicated his or her consent by signing a written consent is invited to communicate with the PAC in order to discuss the future collection, use, and disclosure of personal information.

Access to this Policy

A copy of this Policy will be provided to all PAC members at their request. A copy of this Policy will be available from the PAC’s website.

Withdrawal of Consent

An individual may withdraw his or her consent to collection, use or disclosure at any time subject to legal or contractual restrictions and reasonable notice. The PAC shall inform the individual of the implications of such withdrawal of consent for the continued provision of products, services, and programs by the PAC to the individual.

Obtaining Consent

The PAC will never obtain consent by deception or by using misleading practices.

An individual’s consent may be either express or implied and may be communicated by an authorized representative. Express consent may be given to the PAC orally (face to face or over the telephone), by mail, by facsimile or by email. Implied consent may arise through action or inaction on the part of the individual.

In appropriate circumstances, the PAC will seek individual consent to the collection, use and disclosure of personal information by notifying individuals that they will be deemed to consent unless they expressly inform the PAC to the contrary. The PAC will ensure that the individual is entitled to use a convenient method for such notification to the PAC.

Promotion of Products, Services, and Programs

If the PAC wishes to use personal information to promote products, services, or programs, we will obtain the consent of the individual before using personal information for this purpose.

Circumstances Where an Individual’s Consent is Not Required

As permitted by law, the PAC may collect personal information without the knowledge or consent of an individual where:

  1. collection of the information is clearly in the interests of the Individual and consent cannot be obtained in a timely manner;
  2. collection is necessary for the medical treatment of the individual and the individual is unable to give consent.
  3. it is reasonable to expect that the collection of the personal information with the knowledge or consent of the individual would compromise the availability or accuracy of the information and the collection is reasonable for an investigation or proceeding as defined in the PIPA;
  4. the personal information is collected by observation at a performance, a sports meet or a similar event at which the individual voluntarily appears and that is open to the public;
  5. the personal information is already publicly available;
  6. the collection is necessary to determine the individual’s suitability to receive an honour, award, or similar benefit or to be selected for an athletic or artistic purpose;
  7. the collection is required or authorized by law; or
  8. collection is permitted under sections 18 to 22 of the PIPA.

As permitted by law, the PAC may use personal information, without the knowledge or consent of the individual, in circumstances where:

  1. the use is clearly in the interests of the individual and consent could not be obtained in a timely way;
  2. the use is necessary for medical treatment of the individual and the individual doe not have the legal capacity to give consent;
  3. the use with the consent of the individual would compromise an investigation or proceeding (as defined in the PIPA) and the use is reasonable for purposes related to an investigation or a proceeding;
  4. the personal information is collected by observation at a performance, a sports meet or a similar event at which the individual voluntarily appears and that is open to the public;
  5. the personal information is already publicly available;
  6. the use is necessary to determine the individual’s suitability to receive an honour, award, or similar benefit or to be selected for an athletic or artistic purpose
  7. the use is required or authorized by law.
  8. the personal information was disclosed to the PAC under sections 18 to 22 of the PIPA.
  9. the information is needed to facilitate the collection of a debt owed to the PAC or the payment of a debt owed by the PAC;
  10. the information is used for the purpose of acting in respect of an emergency that threatens the life, health, or security of an individual; or

With respect to the disclosure of personal information without express or implied consent, the PAC, as permitted by law, may disclose personal information without the knowledge or consent of the individual if such disclosure:

  1. the disclosure is clearly in the interests of the individual and consent could not be obtained in a timely way;
  2. the disclosure is necessary for medical treatment of the individual and the individual does not have the legal capacity to give consent;
  3. the disclosure with the consent of the individual would compromise an investigation or proceeding (as defined in the PIPA) and the disclosure is reasonable for purposes related to an investigation or a proceeding;
  4. the personal information is collected by observation at a performance, a sports meet or a similar event at which the individual voluntarily appears and that is open to the public;
  5. the personal information is already publicly available;
  6. the disclosure is necessary to determine the individual’s suitability to receive an honour, award, or similar benefit or to be selected for an athletic or artistic purpose;
  7. the information is needed to collect a debt owed to the PAC or the payment of a debt owed by the PAC to an individual;
  8. the personal information is disclosed in accordance with a provision of a treaty that authorizes or requires its disclosure, and is made under an enactment of British Columbia or Canada;
  9. the disclosure is for the purpose of complying with a subpoena, warrant, or order issued or made by a court, person or body with jurisdiction to compel the production of personal information;
  10. the disclosure is to a public body or a law enforcement agency in Canada, concerning an offence under the laws of Canada or a province, to assist in an investigation, or in the making of a decision to undertake an investigation to determine whether the offence has taken place, or to prepare for the laying of a charge or the prosecution of the offence
  11. there are reasonable grounds to believe that compelling circumstances exist that affect the health or safety of any individual and if notice of disclosure is mailed to the last known address of the individual to whom the personal information relates;
  12. the disclosure is for the purpose of contacting the next of kin or a friend of an injured, ill, or deceased individual;
  13. is made to a barrister or solicitor who is representing the PAC;
  14. the disclosure is to an archival institution if the collection of the personal information is reasonable for research or archival purposes;
  15. the disclosure is required or authorized by law;
  16. the disclosure is in accordance with sections 19 to 22 of the PIPA.

In circumstances where the PAC discloses information to a government institution that has identified its lawful authority to obtain the information, the PAC will first verify that the government institution is entitled to compel such disclosure and in any event will take reasonable care to ensure that only the personal information that is legally required is provided to the institution. To the extent permitted by law, the PAC may notify the individual of such disclosure. The PAC will not disclose personal information to government institutions in response to casual requests for information.


4. Limiting Collection Principle

The PAC will limit the amount and type of personal information collected to that which is necessary for the purposes identified by the PAC.

Although the PAC will collect personal information primarily from the individual concerned, with the individual’s consent, the PAC may also collect information from external sources such as Ecole Dorothy Lynas School or the school district. If personal information is collected from a third party, the PAC will note their identity unless there is a lawful reason for not doing so.

5. Limiting Use, Disclosure, and Retention Principle

The PAC 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 or permitted by law. Personal information will be retained only as long as necessary for fulfillment of those purposes.

The PAC maintains guidelines to govern the destruction of personal information.

The PAC maintains guidelines for the retention of a Client’s personal information and will retain it only as long as necessary for the identified purposes, as required by law, or as required for member service.

The PAC will destroy, or make anonymous, any personal information no longer needed.

The PAC’s policies and procedures dictate how the PAC will destroy personal information so that unauthorized persons or organizations do not gain access to it.

6. Accuracy Principle

The PAC will keep personal information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

The PAC will minimize the possibility that inappropriate information is used to make a decision about the individual.

The PAC will not routinely update personal information, unless such updating is necessary to fulfill the purposes for which the information was collected.

The PAC will make reasonable efforts to keep the personal information that is used on an ongoing basis, including information that is disclosed to third parties, generally accurate and up-to-date, unless limits to the requirement for accuracy are clearly set out.

The PAC will rely on individual members to provide up-dated information, such as changes to member addresses and other contact information.

If an individual demonstrates to the PAC that personal information is inaccurate, incomplete, out-of-date, or irrelevant, the PAC will revise the personal information. If necessary, the PAC will disclose the revised personal information to third parties that were provided with the wrong information to permit them to revise their records as well.

7. Safeguards

The PAC will protect personal information with security safeguards appropriate to the sensitivity of the information.

Security safeguards are employed to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The PAC will protect personal information regardless of the format in which it is held.

The nature of the PAC’s safeguards will vary depending on the sensitivity of the personal information that has been collected, the amount, distribution, and format of the information, and the method of storage. The more sensitive personal information will be safeguarded at a higher level of protection.

The methods of protection will include physical measures, technological measures, and organizational measures.

The PAC will inform committee members about the PAC’s policies and procedures for protecting personal information and will emphasize the importance of complying with them. As a condition of continued membership on a committee, committee members will be required to conform to the PAC’s policies and procedures concerning the security of personal information.

When the PAC discloses personal information to third parties, the PAC will require these third parties to safeguard all personal information in a way that is consistent with the PAC’s measures and which complies with these principles.

The PAC will use care in the disposal or destruction of personal information, to prevent unauthorized parties from gaining access to the information.

8. Openness Principle

The PAC will be open about its policies and procedures with respect to the management of personal information. The PAC will ensure that individuals are able to acquire information about the PAC’s policies and procedures without unreasonable effort. The PAC will make this information available in a form that is generally understandable.

Copies of this Policy will be made available to all PAC members.

The information made available by the PAC will include:

  • The name of the Privacy Officer and contact information;
  • The means of gaining access to personal information held by the PAC;
  • A copy of the PAC’s Privacy Policy

9. Individual Access Principle

Upon an individual’s request in writing, the PAC will inform an individual of the existence, use, and disclosure of his or her personal information and the individual shall be given access to that information, except where the law requires or permits the PAC to deny access.

The PAC will assist any individual who informs the PAC that they need assistance in preparing such a request to the PAC.

The PAC may require the individual to provide sufficient information to permit the PAC to provide an account of the existence, use, and disclosure of personal information. The information provided by the individual in response to the PAC’s request will be used only for this purpose.

The PAC will respond to a request with due diligence and in any case not later than 30 days after receipt of the request. The PAC may extend the time limit for a maximum of 30 days if meeting the time limit would unreasonably interfere with the activities of the PAC, or the time required to undertake any consultations necessary to respond to the request would make the time limit impracticable to meet. In either of these cases, the PAC will, not later than 30 days after the date of the request, send a notice of extension to the individual, advising them of the new time limit and the reasons for extending the time limit.

The PAC may respond to an individual’s request at a cost to the individual if:

  • The PAC informs the individual of the approximate cost; and
  • the individual has advised the PAC that the request is not being withdrawn

When the PAC responds by refusing a request, the PAC will inform the individual in writing of the refusal and the reasons(s) for the refusal.

An individual will be permitted to challenge the accuracy and completeness of the personal information collected, used or disclosed by the PAC and have it amended as appropriate.

As permitted by law, the PAC may deny access by an individual to his or her personal information where:

  1. the information is protected by solicitor-client privilege;
  2. it would reveal confidential commercial information;
  3. to do so could reasonably be expected to threaten the life or security of another individual;
  4. the information was collected in circumstances where it was reasonable to expect that the collection with the knowledge or consent of the individual would compromise the availability or the accuracy of the information and the collection is reasonable for the purposes related to an investigation (as defined in the PIPA) and the investigation and associated proceedings and appeals have not been completed;

As required by law, the PAC must deny access by an individual to his or her personal information where:

5. the disclosure could reasonably be expected to threaten the safety or the physical or mental health of an individual other than the individual who made the request
6. the disclosure can reasonably be expected to cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request;
7. the disclosure would reveal personal information about another individual;
8. the disclosure would reveal the identity of an individual who has provided personal information about another individual and the individual providing the personal information does not consent to disclosure of his or her identity.

Where the PAC is entitled or required to withhold access to personal information as above, and that information is severable from other information for which access is requested, the PAC will provide access to an edited copy of the personal information after severing such information.

The PAC will not give an individual access to personal information if doing so would reveal personal information about a third party, unless the information is severable, in which case edited information will be provided.

If the PAC denies an individual’s request for access to personal information, the PAC will tell the individual why. The individual may then challenge the PAC’s decision.

An individual may challenge the reasonableness of the PAC’s estimated cost of providing access to his or her personal information.

When an individual successfully demonstrates the inaccuracy or incompleteness of personal information, the PAC will amend the information as required. Depending upon the nature of the information challenged, an individual may be required to provide satisfactory proof. The amendment may involve the correction, deletion, or addition of information. Where appropriate, the PAC will transmit the amended information to third parties that have been given the original information in question.

The law may prevent the PAC from informing the individual about disclosure of his or her personal information to a government institution or part of a government institution.

10. Challenging Compliance Principle

An individual will be able to direct a challenge concerning compliance with the above principles to the Privacy Officer.

The person accountable for the PAC’s compliance is the Privacy Officer.

Complaints or inquiries about the PAC’s policies and practices may be provided to the Privacy Officer by telephone, by mail, by facsimile, or by email.

The PAC will investigate all complaints. If the PAC finds that a complaint is justified, the PAC will take appropriate measures, including, if necessary, amending its policies and practices.

In the event that an individual is dissatisfied with the decision (or lack of a decision) of the Privacy Officer, he or she may appeal the Privacy Officer’s decision (or lack of a decision) to the PAC Executive.