1.1 At Place des Arts, 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 client 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 client 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. We do not sell or exchange our patron lists or personal information to other parties.
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 client to request access to, and correction of, their personal information.
1.2.1 Personal Information - is information about an identifiable individual including name, date of birth, home address and phone number, email address, mobile number, health concerns, special needs. Personal information does not include contact information (described below).
1.2.2 Contact information - is information that would enable an individual to be contacted at a place of business and includes name, business telephone number and business fax number. Contact information is not covered by this policy or PIPA.
1.2.3 Privacy Officer - is the individual designated responsibility for ensuring that Place des Arts complies with this policy and PIPA. At Place des Arts, the Administrative Coordinator is the Privacy Officer.
1.3 Collecting Personal Information
1.3.1 Unless the purposes for collecting personal information are obvious and the client 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.
1.3.2 We will only collect client information that is necessary to fulfill the following purposes:
126.96.36.199 To communicate with the client generally;
188.8.131.52 To verify identity;
184.108.40.206 To identify client preferences;
220.127.116.11 To deliver requested products and services;
18.104.22.168 To enroll the client in a program (registration, amendments, cancellations);
22.214.171.124 To notify clients of Place des Arts programs, services, special events, open houses, exhibitions, performances and fundraising initiatives;
126.96.36.199 To collect and process lesson and/or course payments;
188.8.131.52 Protecting against fraud or error;
184.108.40.206 To solicit information for potential media profile.
1.4.1 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).
1.4.2 Consent can be provided orally, in writing, electronically, 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.
1.4.3 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, fundraising and the client does not opt-out.
1.4.4 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), client can withhold or withdraw their consent for Place des Arts 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 client, in making the decision.
1.4.5 We may collect, use or disclose personal information without the client's knowledge or consent in the following limited circumstances:
220.127.116.11 when the collection, use or disclosure of personal information is permitted or required by law;
18.104.22.168 In an emergency that threatens an individual's life, health, or personal security;
22.214.171.124 When the personal information is available from a public source (e.g., a telephone directory);
126.96.36.199 When we require legal advice from a lawyer;
188.8.131.52 For the purposes of collecting a debt;
184.108.40.206 To protect ourselves from fraud;
220.127.116.11 To investigate an anticipated breach of an agreement or a contravention of law.
1.5 Using and Disclosing Personal Information
1.5.1 We will only use or disclose client personal information where necessary to fulfill the purposes identified at the time of collection such as:
18.104.22.168 To conduct client surveys in order to enhance the provision of our services;
22.214.171.124 To contact our client directly about products and services that may be of interest;
1.5.2 We will not use or disclose client personal information for any additional purpose unless we obtain consent to do so.
1.5.3 We will not sell client lists or personal information to other parties.
1.6 Retaining Personal Information
1.6.1 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.
1.6.2 Subject to policy 1.6.1, we will retain client personal information for as long as it is required for as required by federal and provincial laws, or business purposes.
1.7 Ensuring Accuracy of Personal Information
1.7.1 We will make reasonable efforts to ensure that client personal information is accurate and complete.
1.7.2 Client may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made with 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 or designated individual.
1.7.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required.
1.8 Securing Personal Information
1.8.1 We are committed to ensuring the security of client personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
1.8.2 The following security measures will be followed to ensure that client personal information is appropriately protected:
126.96.36.199 Use of locked filing cabinets and cupboards;
188.8.131.52 Physically securing offices where personal information is held;
184.108.40.206 Secured server and network including; use of user IDs, passwords;
220.127.116.11 Restricting employee access to personal information as appropriate (i.e., only those that need to know will have access;
18.104.22.168 Contractually requiring any service providers to provide comparable security measures
1.8.3 We will use appropriate security measures when destroying client's personal information such as shredding documents, deleting electronically stored information.
1.8.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
1.9 Providing Client Access to Personal Information
1.9.1 Clients have a right to access their personal information, subject to limited exceptions.
1.9.2 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 or designated individual.
1.9.3 Upon request, we will also tell clients how we use their personal information and to whom it has been disclosed if applicable.
1.9.4 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.
1.9.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client of the cost and request further direction from the client on whether or not we should proceed with the request.
1.10 Questions and Complaints: The Role of the Privacy Officer or designated individual
1.10.1 The Privacy Officer or designated individual is responsible for ensuring Place des Arts' compliance with this policy and the Personal Information Protection Act.
1.10.2 Clients should direct any complaints, concerns or questions regarding Place des Arts' compliance in writing to the Privacy Officer or designated individual c/o Place des Arts, 1120 Brunette Avenue, Coquitlam, British Columbia, V3K 1G2.. If the Privacy Officer or designated individual is unable to resolve the concern, the client may also write to the Information and Privacy Commissioner of British Columbia.
1.10.3 Clients who notice any errors in our correspondence, of if clients whish to be removed from our mailing lists, please contact Place des Art directly at 1120 Brunette Avenue, Coquitlam, British Columbia, V3K 1G2.