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Personal Information Protection
2017 Great Lakes Economic Forum
Personal Information Protection Policy


At Council of the Great Lakes Region, we are committed to providing our online visitors to our website with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our website visitors, protecting their personal information is one of our highest priorities.

While we have always respected our website visitors’ 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 and amended on July 1, 2014, sets out the ground rules for how Canadian businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our website visitors 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 website visitors’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our website visitors’ personal information and allowing our website visitors’ to request access to, and correction of, their personal information.


Scope of this Policy


This Personal Information Protection Policy applies to Council of the Great Lakes Region and its event, the Great Lakes Economic Forum.

This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Council of the Great Lakes Region.


Definitions


Personal Information –means information about an identifiable individual including name, age, address, phone number. 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 Council of the Great Lakes Region complies with this policy and PIPA.


Policy 1 – Collecting Personal Information


1.1 Unless the purposes for collecting personal information are obvious and the website visitor 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 website visitor information that is necessary to fulfill the following purposes:

  • To verify identity;
  • To identify website visitor preferences;
  • To open and manage an online profile;
  • To deliver requested products and services;
  • To process a registration;
  • To send out organization membership information;
  • To contact our website visitors for fundraising.


Policy 2 – Consent


2.1 We will obtain website visitors’ 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 electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the website visitor voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a website visitor is given notice and a reasonable opportunity to opt-out of his or her personal information being used for marketing services and fundraising and the website visitor 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), website visitors can withhold or withdraw their consent for Council of the Great Lakes Region to use their personal information in certain ways. A website visitor’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 website visitor in making the decision.


Policy 3 – Using and Disclosing Personal Information


3.1 We will only use or disclose website visitor personal information where necessary to fulfill the purposes identified at the time of collection or for the purpose to conduct surveys and contact our website visitors directly about products and services that may be of interest to them.

3.2 We will not use or disclose website visitor personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell website visitor lists or personal information to other parties.


Policy 4 – Retaining Personal Information


4.1 If we use website visitor personal information to make a decision that directly affects the website visitor, we will retain that personal information for at least one year so that the website visitor has a reasonable opportunity to request access to it.

4.2 Subject to policy 4.1, we will retain website visitor 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 website visitors personal information is accurate and complete where it may be used to make a decision about the website visitors or disclosed to another organization.

5.2 Website visitors 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 website visitors’ correction request in the file.


Policy 6 – Securing Personal Information


6.1 We are committed to ensuring the security of website visitors 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 website visitors personal information is appropriately protected:

6.3 We will use appropriate security measures when destroying website visitors’ personal information such as electronically deleting 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 Website Visitors Access to Personal Information


7.1 Website Visitors have a right to access their personal information, subject to limited exceptions.

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.

7.3 Upon request, we will also tell website visitors 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 website visitor of the cost and request further direction from the website visitor 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 website visitor in writing, providing the reasons for refusal and the recourse available to the website visitor.


Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual


8.1 The Privacy Officer is responsible for ensuring Council of the Great Lakes Region compliance with this policy and the Personal Information Protection Act.

8.2 Website visitors should direct any complaints, concerns or questions regarding the Council of the Great Lakes Region’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the website visitor may also write to the Information and Privacy Commissioner of Canada.

Contact information for Council of the Great Lakes Region’s Privacy Officer: grc (at) greatrivercreative.com