Introduction/Overview
Café Ético is committed to ensuring the confidentiality, privacy, and protection of the personal information of all members and other individuals whose personal information is held or controlled by Café Ético.
Policy – detailed clauses
Privacy Officer
Café Ético will designate a Privacy Officer to oversee the protection of personal information in compliance with the BC Personal Information Protection Act, the Federal Personal Information Protection and Electronic Documents Act, and Café Ético’s privacy policy.
Practices
Café Ético will develop practices necessary for compliance with the Personal Information Protection Act and a process to respond to complaints that may arise, and make information available on request about the policy and practices and the complaint process.
Consent
Café Ético will obtain written or verbal consent for the collection, use, or disclosure of personal information, except in circumstances permitted by the Personal Information Protection Act or other law.
· Express Consent: Café Ético will obtain express written or oral consent for the collection, use, and disclosure of personal information, except in circumstances whereby the Personal Information Protection Act authorizes the collection, use, or disclosure without consent or deems the collection, use, or disclosure to be consented to.
· Implied Consent: Implied consent may be relied on when the purpose would be considered obvious to a reasonable person, and the individual voluntarily provides the personal information for that purpose.
· Deemed Consent: Café Ético will be deemed to have obtained consent to collect, use, or disclose personal information for specified purposes if:
· The specified purpose is reasonable, having regard to the sensitivity of the personal information in the circumstance; and
· Café Ético sends written notice to the individual that it intends to collect, use or disclose personal information for those specified purposes; and
· The individual is provided a reasonable opportunity to decline the request;
· The individual does not decline the request within the specified time period.
Conditions
Café Ético will not, as a condition of providing a product or service, require an individual to consent to the collection, use, or disclosure of personal information beyond what is necessary to provide the product or service.
Withdrawal
An individual may withdraw consent at any time, subject to legal or contractual restrictions, provided that reasonable notice of withdrawal of consent is given to Café Ético. On receipt of such notice, Café Ético will inform the individual of the likely consequences of the withdrawal of consent, which may include the inability of Café Ético to provide certain products, services, or communications pertaining to Café Ético and the work it conducts if the information is necessary to provide said products, services, and communications.
Purposes
When collecting personal information such as the name, position, business or home address, telephone number, email, or opinions of an individual, Café Ético will state the purpose of collection as follows:
Café Ético may use your personal information to send you newsletters, meeting notices, urgent actions, membership renewals, donation requests, official receipts, and other information related to the goals and functioning of the organization. We will not sell your personal information, nor share it without explicit consent or as required by law. Please advise us in writing if you do not want to be contacted or receive any mail or emails from us.
Café Ético will also provide on request the position or title and contact information of a Privacy Officer who can answer the individual’s questions about the collection, use, and disclosure of his or her personal information.
Collection
Café Ético will limit the collection of information to information that is necessary to provide a product, service, or communication pertaining to Café Ético and its work, or information that is necessary for the purpose consented to by the individual or to information otherwise permitted to be collected by the Personal Information Protection Act or other law.
Use
Café Ético will not use personal information for purposes other than those for which it was collected, except with the consent of the member or as required or authorized by law.
Disclosure
Café Ético will not disclose personal information for purposes other than those for which it was collected, except with the consent of the member or other individual or as required or authorized by law. When disclosing personal information, Café Ético will take all reasonable steps to protect the interests of its members and other individuals.
Sharing
Café Ético will not share personal information with other individuals, service providers or related organizations without explicit consent, unless required or authorized by law.
Access
On a need-to-know basis, the employees and selected volunteers of Café Ético will have access to personal information under the control of Café Ético. Café Ético may also contract the services of another organization which may have access to personal information and which will act in the same manner as Café Ético’s employees and volunteers to ensure privacy.
A member may request a record of his or her personal information under the control of Café Ético , information about the ways in which the personal information requested has been and is being used, and the names of individuals and organizations to whom the personal information requested has been disclosed. Café Ético may charge a minimal fee for providing this information.
For other information, upon written request, Café Ético will provide the individual with personal information under the control of Café Ético, information about the ways in which the personal information requested has been and is being used, and the names of individuals and organizations to whom the personal information requested has been disclosed. Café Ético may charge a minimal fee for providing this information, and will provide an estimate of this fee upon receiving the access to information request. Café Ético may require a deposit for all or part of the fee.
· Assistance: Café Ético will assist individuals to complete an access to information request to ensure that the information wanted or needed is provided accurately, completely, and promptly. An applicant may be required to provide sufficient information to permit Café Ético to provide an account of the existence, use, and disclosure of personal information it holds. The additional information provided will only be used for this purpose.
· Exceptions: Café Ético may not provide information that it is not required to disclose and will not disclose information that it is required not to disclose by law, such as information that would reveal the identity of another individual without his or her consent.
· Time Limit: Café Ético will endeavour to respond to an access to information request within 30 days. If additional time is required because sufficient detail has not been provided by the applicant, a large amount of material is requested or must be retrieved, or more time is needed to consult with other organizations, Café Ético may apply to the BC Privacy Commissioner for an extension under the Personal Information Protection Act.
· Refusals: If Café Ético refuses access to personal information, Café Ético’s response to the access to information request will provide the reasons for refusal and provide the name, position/title, address, and telephone number of an officer of Café Ético who can answer the applicant’s questions about the refusal. Café Ético may refuse to confirm or deny the existence of personal information collected as part of an investigation.
Accuracy
Café Ético will make a reasonable effort to ensure that personal information it is using or disclosing is accurate and complete.
Corrections
If an individual demonstrates the inaccuracy or incompleteness of personal information, Café Ético will amend the information as required. If appropriate, Café Ético will send the amended information to third parties to whom the information has been disclosed. When a challenge regarding the accuracy of personal information is not resolved to the satisfaction of the individual, Café Ético will annotate the personal information under its control with a note that the correction was requested but not made.
Protection
Café Ético will protect the personal information in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks. Café Ético will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who assist in providing services to members and other individuals.
Retention
Café Ético will keep personal information used to make a decision that affects the individual for at least one year after it has been used to make the decision.
Café Ético will, in accordance with its retention schedule, destroy, erase, or make anonymous documents containing personal information, as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes. Café Ético will take due care with the destruction of personal information so as to prevent unauthorized parties from gaining access to the information.
Café Ético may retain personal information about members and account holders with their consent in order to assist in the provision of future products and services and for purposes such as sending information about Café Ético and its work, and may update the information as necessary to provide communications, products, and services applied for.
Safeguarding
Café Ético will employ electronic and physical security safeguards appropriate to the sensitivity level of personal information, including:
· Physical measures such as locked filing cabinets and restricted access to Café Ético’s office.
· Organizational measures such as restricting employee and volunteer access to files and databases
· Electronic measures such as passwords and/or encryption
· Investigative measures if Café Ético has reasonable grounds to believe that personal information is being inappropriately collected, used, or disclosed.
Procedures
Complaint Process
Café Ético will, on request, inform members and other individuals of its complaint procedures, which will be accessible and simple to use.
Café Ético will ensure that inquiries, concerns, and complaints regarding personal information receive prompt attention and are resolved in a timely manner.
Where appropriate, members and other individuals will be informed of their right to file a complaint or review with the BC Privacy Commissioner, and will be provided with the contact information in order to initiate this process.
Responsibilities of Various Stakeholders
Questions
Members and other individuals may direct any inquiries or complaints regarding their personal information to Café Ético’s Privacy Officer at 604-708-8782 or etico@etico.ca
