Personal Information Protection Policy
At Languages Canada, we are committed to providing our members, their teachers and their students with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our members, protecting their personal information is one of our highest priorities.
While we have always respected our members’, their teachers’ and their students’ privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of the Personal Information Protection and Electronic Documents Act (PIPEDA) which came into effect on January 1, 2001, and with which we must comply as of January 1, 2004. This act sets out the ground rules for how Canadian businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our members, their teachers and their students 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.
This policy outlines the principles and practices we will follow in protecting members’, their teacher’ and their students’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of their personal information and allowing them to request access to, and correction of, their personal information.
Personal Information – means information about an identifiable individual such as name, home address and phone number, credit history, education, employment information. 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, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPEDA.
Privacy Officer – means the individual designated responsibility for ensuring that Languages Canada complies with this policy and PIPEDA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the member, teacher or student 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 member, teacher or student information that is necessary to fulfill the following purposes:
- To verify identity;
- To verify financial status for new membership applicants;
- To identify member preferences;
- To deliver requested products and services;
- To enrol a member in the association or for event registration;
- To send out association membership information;
- To ensure a high standard of service to our members;
- To meet regulatory requirements;
- To collect and process membership payments;
- To conduct industry specific surveys
Policy 2 – Consent
2.1 We will obtain member, teacher or student consent to collect, use or disclose personal information except where we are authorized under PIPEDA to do so without consent.
2.2 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 the member, teacher or student voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a member, teacher or student 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 member does not opt-out.
2.4 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), members, teachers and students can withhold or withdraw their consent for Languages Canada to use their personal information in certain ways. A member’s, teacher’s or student’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the member, teacher or student in making the decision.
2.5 We may collect, use or disclose personal information without the member’s, teacher’s or student’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);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose a member’s, teacher’s or student’s personal information where necessary to fulfill the purposes identified at the time of collection.
3.2 We will not use or disclose a member’s, teacher’s or student’s personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell member, teacher or student lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use member, teacher or student personal information to make a decision that directly affects the member, teacher or student, we will retain that personal information for at least one year so that the person has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain member, teacher or student 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 member, teacher or student personal information is accurate and complete where it may be used to make a decision about the member, teacher or student or disclosed to another organization.
5.2 Members, teachers or students 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 Officer.
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 in the previous year. If the correction is not made, we will note the member’s, teacher’s or student’s correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of member, teacher and student 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 member, teacher and student personal information is appropriately protected:
- Securing all information in lockable file cabinets
- Securing offices in which the information is held
- Using passwords, firewalls and other computer safety systems to ensure information is secured
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 Members, Teachers and Students Access to Personal Information
7.1 Members, teachers and students have a right to access their personal information, subject to limited exceptions as covered in PIPEDA.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer.
7.3 Upon request, we will also tell members, teachers and students 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 minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the member, teacher or student of the cost and request further direction from the member, teacher or student 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 member, teacher or student in writing, providing the reasons for refusal and the recourse available to the member or student.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer is responsible for ensuring Languages Canada compliance with this policy and the Personal Information Protection Act.
8.2 Members, teachers or students should direct any complaints, concerns or questions regarding Languages Canada’ compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the member, teacher or student may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Languages Canada’s Privacy Officer: