Policy and Procedures: Privacy Policy

Date:

June 17, 2004

Control:

Administration 002

Title:

Members Rights to Privacy

Purpose:

To protect and respect members right to privacy

Reference:

nil

Introduction

To outline your rights as a Member in this connection, and also your obligations to respect the privacy of personal information of your fellow Members. In carrying out your duties as an officer, you are to assure and to demonstrate to your fellow members that you, and this corporation, respect their privacy rights.

These policies and practices will comply with the letter, spirit, and intent of the federal Personal Information Protection Documents Act (PIPEDA) and any applicable provincial privacy act (referred to below collectively as ‘the Act”).

The purpose of the Act is to establish rules to govern the collection, use, and disclosure of personal information, to recognize the right of privacy, and to recognize the need of organizations to collect, use, or disclose personal information.

This policy has been developed and is consistent with policies adopted by other Corporations. The policy applies to the H.K.V.C.A. only, and responsibility for compliance with the policy lies with this corporation.

This corporation respects the privacy of our members, indeed that of all individuals. It is committed to maintaining accurate, confidential, secure, and private personal information in our files.

What is Personal Information?

Personal information includes any factual or subjective information, recorded or not, about an individual. This includes such information as:

Personal information does not include the name, title, business address, or business telephone number of a member.

Privacy Principles

The following privacy elements form the ground rules for the collection, use and disclosure of personal information:

  • Be accountable
  • Identify the purpose
  • Obtain consent
  • Limit collection
  • Limit use, disclosure and retention
  • Be accurate
  • Use appropriate safeguards
  • Be open
  • Give individuals access
  • Provide recourse
  • 1. The HKVCA is accountable to its members.

    It will:

    2. Identifying Purposes:

    It will:

    - Identify why your personal information is needed and how it will be used.

    a) Application Information - Reason:

    i} Ontario Corporations Act requires that an accurate list of shareholders (members) be maintained

    ii} Mailing purposes

    b) Computer and e-mail Access

    HKVCA will ensure that neither internet nor access of any kind will be granted for purposes other than HKVCA internal needs.

    3. This Corporation will obtain consent to use personal information.

    It will obtain member’s consent before, or at the time of collection, as and when a new use is identified for information already collected. This consent will be obtained in written form.

    Personal information collected about you during the course of your membership is subject to the Act. Members may withdraw consent to use information for specific purposes by making a request in writing to any member of your Board of Directors or Region Council.

    4.  This corporation limits collection of personal Information

    Information shall be collected by fair and lawful means. The corporation

    Each member is obligated to honour these policies in dealing with such information from your fellow members.

    5. This corporation limits use, disclosure, and retention of personal information

    This corporation will:

    Where personal information is disclosed or transferred to third party organizations performing services on behalf of this corporation (e.g. special mailings), the privacy and confidentiality of your personal information will be maintained through contractual agreement with these organizations. These arrangements strictly prohibit sale or disclosure of your personal information to any other party, except where it is providing sub-contracted services covered under the main agreement.

    To the extent required by law, information will be retained after membership expires. For example, some data must be retained for up to seven years.

    Information whose retention is not required by law will be regularly reviewed and destroyed, when no longer required for business purposes.

    6.  This Corporation keeps personal Information up to date and accurate.

    This corporation will:

    7. Safeguards - The security of your personal information is our priority.

    This corporation safeguards personal information under its control in a manner appropriate to the sensitivity of the information including:

    Personal information in documentary form is and will continue to be maintained in a secure, locked area. Computerized personal information is and will continue to be maintained in secure files with limited, password protected access.

    As a Member, you are responsible to observe all such privacy policies and practices respecting the personal information of your fellow members. Officers are permitted only as authorized to collect, use, or disclose the personal information of others. If you discover or uncover personal information that is not properly safeguarded, you should immediately notify a Director. Members entrusted with confidential personal information of others must be sure to observe appropriate procedures. You should not disclose or release such information casually to the subject of that information, but only after proper process that may even include written request and identification proof, and personal delivery in sealed envelopes marked "Confidential". In responding to personal information access. Requests by any agency, you cannot contravene another person's privacy and confidentiality, (e.g. you cannot give out information which also includes, that of other members (in those, cases, you may be able, and obligated, to issue that with the sections involving another person either blocked out or deleted, and that it must be done with great care, so as not to directly or indirectly reveal the identity of that other person or any personal information about them).

    8.  This corporation is open about its privacy and security policy.

    This corporation will:

    *** membership forms should contain an “acknowledgment statement” that the applicant agrees to the use of the personal information enclosed in accordance with Corporate Policy, and a address where he/she can apply for a record of what we have on file.***

    9. This corporation provides access to a member on his or her personal information.

    This corporation will:

    10. Challenging Compliance

    If they wish, an individual may challenge this corporation’s compliance with the above principles through the Secretary or their designated representative.

    Members should direct any requests and complaints relating to this corporation’s privacy policy or practices to the President or their designated representative.

    If an individual’s privacy requests and concerns have not been addressed through this process, at their option, they may pursue that through contact with the governing Privacy Commissioner’s Office of their province (currently in Quebec, British Columbia, or British Columbia) or for Canada.

    Approval:

    President: ___________________
    Carol Hadley
    Date: ____________________

    Secretary: ___________________
    Jim Trick
    Date:_____________________

    Record of Revisions

    Rev # Date Change Description Approval Method Reference Remarks
    1 Jan '13 Converted to HTML. No content change BOD Meeting 23 Jan Minutes