Covenant House Vancouver (CHV) is committed to protecting personal information through compliance with British Columbia’s Personal Information Protection Act (PIPA). We are committed to providing youth, employees, directors, donors, and other stakeholders with exceptional service. Since providing this service can involve the collection, use and disclosure of some personal information, privacy protection is one of our highest priorities.
This Personal Information Protection Policy outlines the principles and practices to be followed in protecting personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, security, access to, and correction of the personal information we collect, use and disclose.
We will inform people of why and how we collect, use and disclose their personal information, obtain their consent where required, and handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances. All information is retained only for the time periods needed to fulfill the purposes for which it was collected.
We do not use or disclose personal information for any purpose other than those for which it was collected, except as required by law, or with consent.
CHV’s Controller acts as the leading privacy officer for the CHV’s Privacy Committee, and the manager of Quality Assurance acts as the back up privacy officer.
“Personal information” Personal information means information about an identifiable individual. Some examples of personal information defined by Privacy laws PIPEDA or PIPA include:
• Name, sex, age, weight, height
• Home address and phone number
• Race, ethnic origin, sexual orientation
• Medical information
• Income, purchases and spending habits
• Blood type, DNA code, fingerprints
• Marital or family status
• Employment information
“Youth” is a person who is currently accessing CHV services or has done so in the past.
“Employee” is any individual employed to work at any location with CHV and includes persons working in a volunteer capacity.
“Director” is a person elected or appointed as a Director of CHV.
“Donor” is a person or organization that has made a donation to CHV.
“Stakeholder” is an individual or an organization other than a Youth, Employee, Director, or Donor where CHV has, under reasonable circumstances, collected personal information.
“Privacy Officer” is the first point of contact in CHV when privacy issues arise. A Privacy Officer has the authority to intervene on privacy issues relating to any of CHV’s operations. A Privacy Officer is responsible for:
• Conducting a privacy audit and self-assessment
• Ensuring appropriate privacy training is provided
• Responding to requests for access to and correction of personal information
• Working with the Information and Privacy Commissioner in the event of an investigation
A Privacy Officer must also be familiar with the Personal Information Protection Act and the ten principles of privacy protection.
The application for access to CHV’s sites and services by Youth is viewed as consent for CHV to collect, use, and disclose personal information for the purposes identified above.
The acceptance of employment by an Employee is viewed as consent for CHV to collect, use, and disclose personal information about an employee for the purposes identified above. CHV views the purposes identified in this policy as reasonable and necessary to manage the organization and the employment relationship.
The acceptance of an appointment as a Director is viewed as consent for CHV to collect, use, and disclose personal information for the purposes identified above.
The authorization of donation by a Donor is viewed as consent for CHV to collect, use, and disclose personal/business information for the purposes identified above.
The interaction by a Stakeholder with CHV, whereby a reasonable person would consider the collection, use and disclosure of personal information appropriate in the circumstances, is viewed as consent for CHV to collect, use, and disclose personal information for the purposes identified above.
A Youth, Employee, Director, Donor, or other Stakeholder may choose, however, to withhold or withdraw consent for the collection, use, and disclosure of personal information, subject to legal and contractual restrictions and reasonable notice, where the provision of this information is optional, such as in the case of consent for the use of a photograph for newsletters, other publications or CHV website.
CHV will make all reasonable efforts to ensure that personal information is accurate, complete, and current as required for the purposes for which it was collected. In some cases, CHV relies on Youth, Employees, Directors, Donors and other Stakeholders to ensure that certain information about them, such as their home address and phone number, or emergency contact information, is current, complete, and accurate.
CHV will make all reasonable efforts to ensure that personal information is protected against such risks as loss, theft, or unauthorized access, disclosure, copying, use, modification, or destruction. Safeguards include physical, administrative, and electronic security measures. If personal information is disclosed to a third party, CHV will make all reasonable efforts to ensure that the third party has appropriate security procedures in place for the protection of the personal information transferred to it.
All Youth, Employees, Directors, Donors and other Stakeholders have the right to access their personal information under the control of CHV. The Privacy Officer will assist with access requests. Access requests should be submitted in writing to the Privacy Officer. In certain exceptional situations, subject to privacy legislation, CHV may not be able to provide access to certain personal information in its possession. Examples of where the CHV may not provide access include, but are not limited to, the following:
• Where provision may reveal personal information about another individual;
• Where the information is subject to solicitor-client privilege; or
• Where the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law. If access cannot be provided, CHV will notify the individual making the request, in writing, of the reasons for the refusal.
Where access has been provided and where the information is demonstrated to be inaccurate or incomplete, CHV will amend the information as required. Where appropriate, CHV will transmit the amended information to third parties having access to the information in question.
CHV will make available specific information about its policies and practices regarding the management of personal information.
Questions regarding privacy at CHV, as well as any questions or concerns regarding CHV’s compliance with this policy, may be directed to the Privacy Officer at firstname.lastname@example.org
CHV will investigate all complaints received in writing. If a complaint is found to be justified, CHV will take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. An individual will be informed, in writing, of the outcomes of the investigation regarding the complaint.
For general questions regarding privacy regulations or for a copy of the Personal Information Protection Act contact the Office of the Information and Privacy Commissioner of British Columbia at PO Box 9038, Stn. Prov. Govt., Victoria, B.C. V8W 9A4, or online at: www.oipc.bc.ca