Cowichan-Mahalat-Langord NDP Electorial District Association (CML NDP EDA)

Personal Information Protection Policy

 

At CML NDP EDA, we are committed to providing our users with exceptional service.  As providing this service involves the collection, use and disclosure of some personal information about our users, protecting their personal information is one of our highest priorities.

While we have always respected our users’ privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA).  PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our users 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 Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting users’ personal information.  Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our users’ personal information and allowing our users to request access to, and correction of, their personal information.

Scope of this Policy

This Personal Information Protection Policy applies to CML NDP EDA.

This policy also applies to any service providers collecting, using or disclosing personal information on behalf of CML NDP EDA.

Definitions

Personal Information –means information about an identifiable individual (Personal information CML NDP EDA: name and personal email address, social media profile photo, IP address, age, ethnicity, membership in protected groups under human rights legislation, socio-economic status, personal opinions, and sometimes phone number and address. 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 PIPA.

Privacy Officer – means the individual designated responsibility for ensuring that CML NDP EDA with this policy and PIPA.

Policy 1 – Collecting Personal Information

1.1  Unless the purposes for collecting personal information are obvious and the user voluntarily provides their 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 user information that is necessary to fulfill the following purposes:

  • Event RVSP;
  • Event communications;
  • Event payments;
  • Event management;
  • Polls and surveys;
  • Security;
  • Tax receipts;
  • User account management;
  • Volunteer Recruitment and Management

Policy 2 – Consent

2.1  We will obtain user consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2  Consent can be provided orally and electronically, or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the user voluntarily provides personal information for that purpose.

2.3  Consent may also be implied where a user is given notice and a reasonable opportunity to opt-out of their personal information being used for the marketing of new services or products and the user 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), users can withhold or withdraw their consent for CML NDP EDA to use their personal information in certain ways.  A user’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service.  If so, we will explain the situation to assist the user in making the decision.

2.5  We may collect, use or disclose personal information without the user’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 user personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:

  • To conduct user surveys in order to enhance the provision of our services;
  • To contact our users directly about products and services that may be of interest;
  • To contact our users directly about changes to services.

3.2  We will not use or disclose user personal information for any additional purpose unless we obtain consent to do so.

3.3  We will not sell user lists or personal information to other parties unless we have consent to do so.

Policy 4 – Retaining Personal Information

4.1  If we use user personal information to make a decision that directly affects the user, we will retain that personal information for at least one year so that the user has a reasonable opportunity to request access to it.

4.2  Subject to policy 4.1, we will retain user 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 user personal information is accurate and complete where it may be used to make a decision about the user or disclosed to another organization.

5.2  Users 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.

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 users’ correction request in the file.

Policy 6 – Securing Personal Information

6.1  We are committed to ensuring the security of user 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 user personal information is appropriately protected:

  • The use of user IDs and passwords;
  • Encryption;
  • Firewalls;
  • Restricting employee access to personal information as appropriates;
  • Password-protected files on computer;
  • Data storage in Canada, keeping it free from the US Patriot Act;

6.3  We will use appropriate security measures when destroying user’s personal information such as deleting electronically stored information.

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 Users Access to Personal Information

7.1  Users have a right to access their personal information, subject to limited exceptions.

7.2  A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.

7.3  Upon request, we will also tell users 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 user of the cost and request further direction from the user 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 user in writing, providing the reasons for refusal and the recourse available to the user.

Policy 8 – Questions and Complaints:  The Role of the Privacy Officer or designated individual

8.1  The Privacy Officer is responsible for ensuring CML NDP EDA compliance with this policy and the Personal Information Protection Act.

8.2  Users should direct any complaints, concerns or questions regarding CML NDP EDA’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the user may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for CML NDP EDA’s Privacy Officer:

privacy@cmlndp.ca

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