At 45 Conversations Media & Education Ltd., we are committed to providing our clients with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, protecting their personal information is one of our highest priorities.
While we have always respected our clients 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 clients 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 clients personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients personal information and allowing our clients to request access to, and correction of, their personal information.
- Personal Information –means information about an identifiable individual – for example E.g., including name, age, home address and phone number, marital status, religion, income, medical information, education, employment information]. 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 45 Conversations Media & Education Ltd. complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the client, customer, 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 client, customer, member information that is necessary to fulfill the following purposes:
- To verify identity;
- To identify client preferences;
- To understand the educational, professional development and learning needs of our clients;
- To open and manage an account;
- To deliver requested products and services
- To guarantee an event reservation;
- To process an online product subscription;
- To provide learning, professional development, education or consulting services;
- To enrol the client in a workshop, online educational service, product or program;
- To send out child care, education, consulting and/or professional development related information or professional development certificates;
- To contact our clients for educational opportunities;
- To ensure a high standard of service to our clients;
- To meet regulatory requirements;
- To assess suitability for a specific role or service they have applied to;
- To collect and process consulting, educational service and product related payments.
Policy 2 – Consent
2.1 We will obtain client 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, electronically, through an authorized representative] or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client 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, conference, online workshops and the client 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), clients can withhold or withdraw their consent for 45 Conversations Media & Education Ltd. to use their personal information in certain ways. A client’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 clients in making the decision.
2.5 We may collect, use or disclose personal information without the client’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 client 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 client, customer, member surveys in order to enhance the provision of our services;
- To contact our clients directly about products and services that may be of interest;
- To deliver professional development workshops, services, consulting, education and related learning services;
- To verify professional development certificates we have issued;
- To conduct research related to consulting projects that we have been retained for.
3.2 We will not use or disclose client’s personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client lists or personal information to other parties unless we have the consent to do so.
Policy 4 – Retaining Personal Information
4.1 If we use client personal information to make a decision that directly affects the client we will retain that personal information for at least one year so that the client has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client 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 client personal information is accurate and complete where it may be used to make a decision about the client or disclosed to another organization.
5.2 clients 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 clients correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client’s 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 clients personal information is appropriately protected:
- Password protected online learning management system, forms, project management, online documents, email and email marketing services, use of user IDs, restricting employee access to personal information and a range of other privacy measures.
6.3 We will use appropriate security measures when destroying client’s personal information such as shredding documents and 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 clients Access to Personal Information
7.1 Clients have a right to access their personal information, subject to limited exceptions:
- the information is protected by solicitor-client privilege;
- the disclosure of the information would reveal confidential commercial information that if disclosed, could, in the opinion of a reasonable person, harm the competitive position of the organization;
- the information was collected or disclosed without consent, as allowed under section 12 or 18 of the Personal Information Protection Act, for the purposes of an investigation and the investigation and associated proceedings and appeals have not been completed;
- the information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act under a collective agreement, under an enactment, or by a court;
- the information is in a document that is subject to a solicitor’s lien.
- We cannot disclose personal information and other information under the following circumstances:
- the disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request.
- the disclosure can reasonably be expected to cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request
- the disclosure would reveal personal information about another individual.
- the disclosure would reveal the identity of an individual who has provided personal information about another individual and the individual providing the personal information does not consent to disclosure of his or her identity.
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 Jane Boyd at jane@45Conversations.com
7.3 Upon request, we will also tell clients 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 clients of the cost and request further direction from the clients 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 clients in writing, providing the reasons for refusal and the recourse available to the clients.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 Jane Boyd is responsible for ensuring 45 Conversations Media & Education Ltd.’s compliance with this policy and the Personal Information Protection Act.
8.2 Clients should direct any complaints, concerns or questions regarding 45 Conversations Media & Education Ltd.’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for 45 Conversations Media & Education Ltd.’s designated individual:
- Jane Boyd, CEO/Privacy Officer – Jane@45Conversations.com