PWC is committed with the Personal Information Protection Act

PREAMBLE

​

Privacy of Personal Information

 

​

Peachland Wellness Centre (PWC) respects privacy, safeguards everyone’s personal information and is committed to complying with the requirements as specified in British Columbia’s Personal Information Protection Act (PIPA). This legislation sets out the ground rules for how BC businesses and not-for-profit organizations may collect, use and disclose personal information.

 

PWC is committed to providing staff, members, volunteers, and participants with exceptional service. Providing this service may involve collecting, using, and disclosing some personal information. Protecting personal information of staff, volunteers, and participants is one of PWC’s highest priorities.

 

This policy, in compliance with PIPA, outlines the principles and practices PWC follows to protect staff, volunteer, and participant personal information.

 

1          Definition of Personal Information

 

1.1     PIPA defines, “personal information” as any information that may identify an individual.  PWC interprets this as including (but not limited to):

• Home address, home phone number, and personal cell number;

• Personal e-mail address;

• Information about the individual's medical or health care status or history, including a physical or mental disability;

• The individual's age, sex, marital status, or family status;

• Race, national or ethnic origin, sexual orientation, colour, or religious or political beliefs or associations;

• Information about interaction history with PWC (e.g., number and type of activities taken, etc);

• Financial information, including type and amount of donations;

• Information about the individual's educational, financial, criminal, or employment status or history; and

• Opinions of a person about the individual, and the individual's personal views or opinions.

 

2          General

 

2.1     PWC limits the collection, use, disclosure, and retention of personal information in that it collects only the minimal information necessary for the stated purpose. 

 

2.2     PWC informs staff, volunteers, and participants:

• Of why and how it collects, uses, and discloses their personal information,

• Obtains their consent where required, and

• Handles their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

 

2.3     Anyone may decline to have personal information collected, used or disclosed by PWC, although doing so may restrict PWC’s ability to represent that person’s interest, in which case the individual making such a request would be notified of any restriction.

 

2.4     PWC identifies to the individual the authority and purposes for the collection and use of personal information at the time of collection, and the contact information of an employee who can answer questions about the collection. PWC will also obtain consent if information already collected would be used for any purpose other than that purpose for which it was originally collected. 

 

2.5     Personal information may be disclosed internally within PWC to staff and volunteers so that PWC may provide its programs and services.

 

2.6     PWC's Privacy Policy and related procedures are available from the Privacy Officer, who responds to any related questions.

 

 

3          Accountability

 

3.1     The Board has ultimate accountability for compliance with privacy legislation.

 

3.2     The Board delegates the role of Privacy Officer to the Executive Coordinator. The Coordinator may assign related duties to other staff as necessary to fulfill delegated responsibilities.

 

3.3     The Privacy Officer bears the primary responsibility to safeguard personal information, implement applicable procedures, and respond to enquiries and complaints. 

 

3.4     All staff and volunteers are responsible for protecting the privacy of staff, volunteers, participants, and others whose personal information is in the custody and/or under the control of PWC.

 

3.5     All staff and volunteers are expected to undertake privacy awareness training provided by PWC.

         

3.6     The Privacy Officer and the President are the only designated persons who may contact external sources and agencies on PIPA matters on behalf of PWC.

 

3.7     All personal information that PWC collects will be used solely for the purposes of providing programs and services.  PWC does not sell, lease, trade, or donate personal information.

 

4          Collection, Use, Disclosure, and Destruction of Personal Information 

 

4.1     Personal Information is collected, used or disclosed by PWC in order to:

• Maintain its record of participants and members;

• Communicate with staff, volunteers, members and participants;

• Administer the business of PWC (e.g., correspondence, program delivery, service delivery, and surveys); and

• Develop and maintain electronic information (e.g., address changes, email notifications and correspondence).

 

4.2     PWC makes every reasonable effort to ensure that the personal information it collects, uses, and discloses is accurate and complete. Each individual is responsible for ensuring his/her information is correct and current.

        

4.3     PWC provides a privacy notice to the individual at the time of information collection.

 

4.4   PWC collects personal information directly from the subject of the information whenever it is feasible and appropriate to do so. When direct collection is not feasible or appropriate, PWC makes every reasonable effort to ensure the accuracy of personal information collected from third parties.

​

4.5     PWC uses security measures, incorporated into records management and security processes, which protect personal information from unauthorized access, use or disclosure.

​

4.6     PWC does not disclose personal information to any individual other than the subject unless it is permitted under PIPA. PWC limits any disclosure of personal information to only that information which a reasonable person would consider appropriate in the circumstance.

​

4.7    In compelling circumstances where health and safety may be at stake, disclosures of personal information will be made in accordance with exceptions for such circumstances in the legislation. Staff or volunteers considering disclosure of personal information in such circumstances may seek advice from the Privacy Officer. If this is not possible during an emergency, staff or volunteers will take reasonable measures to protect personal information.

​

4.8   PWC retains personal information in accordance with legal and business guidelines and only as long as needed to fulfill the purpose for which it was collected.  Whenever personal information qualifies as destroyable, the Privacy Officer follows procedures for safe and confidential destruction of that information.

​

4.9    When personal information is used to make a decision affecting someone, the Privacy Officer will ensure the information is kept for at least one year after that decision so that the individual will have sufficient opportunity to access the information, if desired.

 

 

5          Privacy Officer

 

5.1     The Privacy Officer is the first point of contact for any query, concern, or decision on PWC  privacy–related matters. Staff and volunteers who have questions about privacy-related issues will consult with the Privacy Officer.

 

5.2     Anyone may request access to their personal information and may request changes to personal information.  Access requests should be in writing and addressed to the Privacy Officer.  Requests should state very specifically what personal information is being requested.

 

5.3     The Privacy Officer will respond to formal requests within thirty days.  If PWC is unable to respond within this time, the requestor will be advised.

 

5.4     The Privacy Officer will ensure that personal information is protected through security and records management processes including:

• Limiting access to those staff, volunteers or elected officials who require it in the performance of their job function;

• Installing and maintaining reasonable safeguards to prevent unauthorized access of PWC’s electronic and hard copy records;

• Limiting collection, use, disclosure, and retention;

• Ensuring that personal information records are kept reasonably accurate and current;

• Destroying personal information (when appropriate) in a thorough and confidential manner.

 

5.5     The Privacy Officer will review all projects involving personal information.

 

 

6          Access to Personal Information

 

6.1     PWC provides individuals means by which to

• Request access or changes to their personal information,

• Decline provision of personal information, and

• Report an incident or make a formal complaint relating to PWC’s protection of their privacy. 

 

6.2     An individual may access his or her personal information by making a written request to the Privacy Officer. PWC may require an individual to prove his/her identity before providing access to his/her information.

 

7          Complaints

 

7.1     All privacy complaints and reported incidents are investigated and responded to in accordance with PIPA guidelines.  If a complaint is justified, PWC will take appropriate measures to rectify an identified issue.

 

7.2     Any complaint concerning the PWC privacy policy or procedures should be forwarded in writing to the attention of the Privacy Officer.  To ensure that all relevant information necessary to an investigation is provided, the complaint and incident form attached (Appendix A & B) to this policy should be used. If the complaint is justified, PWC will take the steps necessary to resolve the issue.

 

7.3     If an individual is not satisfied that their complaint has been dealt with adequately, they may appeal to the Board of Directors.

 

7.4     If PWC is not able to resolve a complaint, or if a member has any other concerns about the PWC privacy policy and procedures, an individual may contact the Office of the Provincial Privacy Commissioner.

 

 

 

8       Privacy Breaches

 

8.1   A privacy breach occurs when there is unauthorized access to or collection, use, disclosure, or disposal of personal information. PWC notifies affected individuals of any potentially detrimental breaches of its privacy controls.

 

8.2   PWC staff who act in good faith and who execute their employment responsibilities with a reasonable standard of care will not be subject to discipline for unintentional privacy breaches.

 

8.3   Privacy breaches arising from non-compliance with the legislation or this policy may result in disciplinary action up to and including dismissal.

 

 

Related Policies & References:

 

Personal Information Protection Act

Records Policy

 

 

Appendices:

 

A - Breach of Privacy Incident Report

B - Privacy Complaint Form

​

Approved by Board Resolution: August 18, 2016  

First Revision: Approved by Board Resolution:  March 3, 2018

Next Review date:    August 2019                              

 

Contact Information

Questions, concerns or suggestions related to the Privacy Policy to:

Geoff Trafford

Executive Coordinator

Designated Privacy Officer (Information and Privacy Matters)

PWC - Peachland Wellness Centre

4475 4th Street

Peachland, BC V0H 1X6

wellnesscentre@telus.net