Introduction
I am committed to being accountable for how I treat personal information collected, used and disclosed in the course of my work as a facilitator, trainer and writer, and for the principles outlined in this policy.
This policy was developed in compliance with British Columbia’s Personal Information Protection Act (“PIPA”), which sets out rules for how organizations such as mine can collect, use and disclose an individual’s personal information.
What is “personal information”?
Personal information is defined in PIPA as “information about an identifiable individual.” The definition excludes work “contact information,” which is information that allows a person to be contacted at work, such as work phone number or work email address.
Why I collect and use personal information
I work with organizations in my practice as a facilitator, trainer and writer. In doing so, I often work with individuals within or associated with the organization. For example, in a training workshop I may work with individuals who are employees or clients of the organization. I may need to collect personal information such as their name, personal or work experience, personal contact information or other relevant personal information preparing for the training, during the workshop itself, or in any follow-up.
Limits on collection, use, and disclosure
I will only collect and use personal information that is necessary to fulfill the purposes identified in this policy. I will not collect, use or disclose personal information except for the identified purposes unless I have received further consent from the individual. I will only collect, use or disclose personal information in accordance with PIPA.
How I disclose personal information
I will only disclose personal information where authorized by PIPA or required by law; for example, through a court order, subpoena or search warrant. I will not sell or rent personal information to anyone.
How I obtain consent to collect, use, and disclose personal information
I will get individuals’ consent to collect, use or disclose their personal information, except where I am legally authorized or required by law to do so without consent.
Individuals can consent orally, in writing or electronically and their consent may be implied or express depending on the nature and sensitivity of the personal information. Individuals are considered to have given implied consent when my purpose for collecting, using or disclosing personal information would be considered obvious and the individual voluntarily provides personal information for that purpose. Unless it is obvious, I will tell individuals my purpose for collecting personal information and give them a chance to refuse to give me their personal information or a chance to withdraw their consent later.
Individuals may withdraw their consent at any time by giving me reasonable notice, however they cannot withdraw consent where doing so would frustrate performance of a legal obligation (such as a contract between the individual and me). When individuals tell me they are withdrawing consent, PIPA requires me to tell them the likely consequences of withdrawing consent (such as my being unable to provide them with services that require their personal information).
How long I retain personal information
PIPA requires that I keep personal information used to make a decision that directly affects individuals for at least one year after I make that decision. Otherwise, I will only retain personal information for as long as necessary to fulfil the identified purposes or as long as required for a legal or business purpose.
How I Keep Personal Information Secure
Personal information under my custody or control is kept secure. I make security arrangements to prevent against risks such as unauthorized access, collection, use, disclosure, copying, modification or disposal of personal information. These include technological measures such as password protection and physical means including keeping information in a locked cabinet. I will use reasonably secure methods whenever I destroy personal information.
How I ensure that personal information is accurate
I am committed to ensuring that the personal information collected, used or disclosed is accurate.
Individuals may write to me to ask me to correct any errors or omissions in their personal information that is under my control. If I am satisfied that an individual’s request for correction is reasonable, I will correct the personal information as soon as reasonably possible. Additionally, in accordance with PIPA I will, as soon as reasonably possible, also send an individual’s corrected personal information to any organization it was disclosed to during the year before I corrected it. If I do not correct an individual’s personal information, I will note the requested correction on copies of the personal information under your custody or control.
How I provide individuals with access to their personal information under my control or custody
Individuals have the right to access their personal information under my custody or control. A request for access must be made in writing and may be sent to me at the email address on my website contact page. I may require individuals to prove their identity before giving them access to their personal information.
I will give individuals their personal information under my control, information about the ways in which their information is or has been used, and the names of the individuals and organizations to which their personal information has been disclosed.
PIPA allows me to charge a “minimal” fee for providing individuals access to their personal information. If a fee is required, I will give the individual a written fee estimate in advance and I may require payment of a deposit or the whole fee before releasing the requested information.
I will provide requested personal information within 30 business days after it is requested or give written notice if I need more time to respond. In some cases, I may not give an individual access to certain personal information where authorized or required by PIPA to refuse access.
If I refuse an access request, I will tell the applicant in writing, stating the reasons for my refusal and outlining further steps that are available to the applicant (including the right to ask the Office of the Information and Privacy Commissioner for British Columbia to review the decision).
How individuals can complain, ask for access or ask questions
An individual may contact me directly to ask for information about how I treat their personal information, to ask for access to their own personal information, or to complain about my treatment of their personal information.
If an individual is not satisfied with my response, they can complain to the Office of the Information and Privacy Commissioner for British Columbia.