Ray-Cam Co-operative centre is committed to the protection and care of the personal information of its members and program participants.
At Ray-Cam, we are committed to providing our participants and members with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our participants and members, protecting their personal information is one of our highest priorities.
While we have always respected our participants and members 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 participants and 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 participants and members’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our participants and members” personal information and allowing our participants and members’ to request access to, and correction of, their personal information.
Scope of this Policy
This Personal Information Protection Policy applies to the attached organizations.
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Ray-Cam.
Personal Information –means information about an identifiable individual, including name, age, home address, phone number etc. 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 Ray-Cam complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the participant and 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 participant and member information that is necessary to fulfill the following purposes:
To verify identity To identify participant and member preferences;To understand the financial, needs of our participants and members To deliver requested services and products-To provide support and specialized services; e.g. counselling To enrol the participant, member in a program;To send out association membership information;To ensure a high standard of service to our participants and members;To meet regulatory requirements;To assess suitability for services funded by Government or another funding body;To provide required data for funding bodies;
Policy 2 – Consent
2.1 We will obtain participant and 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 through and authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the participant, and member voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a participant and member is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, marketing of services, fundraising and the participant, and 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), participants and members can withhold or withdraw their consent for Ray-Cam to use their personal information in certain ways. A participant and members 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 participant and member in making the decision.
2.5 We may collect, use or disclose personal information without the participants and members’ 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 for research of statistical data purposes;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 participant, and member personal information where necessary to fulfill the purposes identified at the time of collection or for purpose reasonably related to those purposes such as:
To conduct client, customer, member surveys in order to enhance the provision of our services;To contact our [clients, customers, members] directly about programs, opportunities or services that may be of interest;]
3.2 We will not use or disclose participant and member personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell participant and member lists or personal information to other parties unless we have consent to do so.
Policy 4 – Retaining Personal Information
4.1 If we use participant and member personal information to make a decision that directly affects the participant and member we will retain that personal information for at least one year so that the participant and member has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain participant and 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 participant and member personal information is accurate and complete where it may be used to make a decision about the participant and member or disclosed to another organization.
5.2 Participants and 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 to the Privacy Officer of Ray-Cam.
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 participant or members correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of participant and member 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 participant and member personal information is appropriately protected. This will include such measures as:
Use of locked filing cabinets; physically securing offices where personal information is held; the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access; contractually requiring any service providers to provide comparable security measures.
6.3 We will use appropriate security measures when destroying participant and 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 Participants and Members Access to Personal Information
7.1 Participants and Members have a right to access their personal information, subject to limited exceptions.
Such exceptions include: solicitor-client privilege, disclosure would reveal personal information about another individual, health and safety concerns or identify another individual who has provided information about another individual and that individual does not want their identity disclosed, the information was collected as part of an investigation.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. To the Privacy Officer or designate of Ray-Cam.
7.3 Upon request, we will also tell participants and 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 participants and member of the cost and request further direction from the participant and 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 participant and member in writing, providing the reasons for refusal and the recourse available to the participant and member.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer or designated individual is responsible for ensuring Ray-Cam’s compliance with this policy and the Personal Information Protection Act.
8.2 Participants and Members should direct any complaints, concerns or questions regarding Ray-Cam’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the Participant and member may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Ray-Cam’s Privacy Officer :
Noreen Leveque or Lorelei Hawkins
920 E. Hastings Street Vancouver B.C. V6A 3T1