Privacy Policy

Interior Association of Family Councils

At Interior Association of Family Councils, we are committed to protecting personal information. British Columbia’s Personal Information Protection Act (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 members 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 members’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our members’ personal information and allowing our members to request access to, and correction of, their personal information.

Definitions

Personal Information –means information about an identifiable individual. 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 Interior Associaation of Family Council complies with this policy and PIPA. 

Policy 1 – Collecting Personal Information1.1 Unless the purposes for collecting personal information are obvious and the member 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 information that is necessary to fulfill the following purposes: 

· deliver requested products and services

· enrol a member in our association, meetings and events. 

· send out association membership information

Policy 2 – Consent

2.1 We will obtain member 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, in writing or electronically, or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the member voluntarily provides personal information for that purpose. 

2.3 Consent may also be implied where a member 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 can withhold or withdraw their consent for Interior Association of Family Councils to use their personal information in certain ways. A member’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 in making the decision. 

2.5 We may collect, use or disclose personal information without the members knowledge or consent in the case of circumstances found in sections 12, 15, and 18 of PIPA. Some examples include:
Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose member personal information where necessary to fulfill the purposes identified at the time of collection. Examples, may include:

· To conduct client, customer, member surveys in order to enhance the provision of our services;

· To contact our members directly about products and services that may be of interest;] 

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

3.3 We will not sell member lists or personal information to other parties. 

Policy 4 – Retaining Personal Information

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

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

5.2 Members 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 – see below. 

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 members’ correction request in the file. 

Policy 6 – Securing Personal Information

6.1  We are committed to ensuring the security of our members’ personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks. 

6.2 We will follow procedures to ensure that member personal information is appropriately protected. 

6.3 We will use appropriate security measures when destroying members’ personal information, such as shredding documents, 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 Members Access to Personal Information

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

A full listing of the exceptions to access can be found in section 23 of PIPA. Some examples include: solicitor-client privilege, disclosure would reveal personal information about another individual, health and safety concerns]

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- see below. 

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

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

8.1 The Privacy Officer is responsible for ensuring Interior Association of Family Councils compliance with this policy and the Personal Information Protection Act. 

8.2 Members should direct any complaints, concerns or questions regarding Interior Association of Family Council’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the member may also write to the Information and Privacy Commissioner of British Columbia. 

Contact information for Interior Association of Family Councils’ Privacy Officer

Privacy Officer, Attention: Karen Waldie, c/o interiorfamilycouncils@gmail.com