At the Association of Neighbourhood Houses of BC (ANHBC), we understand the importance of individual privacy. We are committed to protecting and ensuring the accuracy of the personal information that is in our control and will only collect information that we require to carry out our work.
ANHBC is responsible for all personal information that we collect, use, disclose and/or retain, provided that the information about our employees, members, volunteers, program and service participants, clients, independent contractors, and donors remains under our control.
Our CEO, Liz Lougheed Green, has been designated as our Chief Privacy Officer. Liz can be reached at 604-875-9111 or by email at email@example.com.
IDENTIFYING THE PURPOSE
Except where required or permitted by law, ANHBC will identify the purposes for the collection, use and disclosure of personal information prior to or at the time of its collection. We will limit the collection of personal information to only that information which is necessary from appropriate sources for the intended purpose.
No personal information will be used for a purpose other than previously intended and identified, without the consent of the individual, unless ANHBC is compelled or permitted to do so by law.
The following are typical purposes for which ANHBC would be required to collect personal information. This list is not exhaustive:
- to establish and maintain relationships with ANHBC’s employees, members, volunteers, program participants, independent contractors and donors
- for emergency contact information
- to assess service needs
- to determine services’ and programs’ eligibility
- to provide programs and services, and enable integrated case management where appropriate
- to ensure the safety of employees, members, volunteers, program participants, independent contractors and donors
- to identify, process and/or collect fees
- to acknowledge gifts and donations and to issue tax receipts
- to comply with legal and/or contractual requirements
ANHBC may collect personal information from sources other than the individual, in certain circumstances required or permitted by law, or with their prior consent. These sources include personal or employment references or other third parties with the right to disclose personal information.
Except where required or permitted by law, ANHBC will obtain an individual’s consent prior to or at the time of collection for the collection, use and disclosure of personal information (including photos and testimonials) about that identifiable individual. .
An individual has the right to withdraw their consent for the collection, use and disclosure of their personal information. Withdrawal of consent may result in service, legal or contractual limitations.
In the case of minors, individuals who are incapacitated, or certain other individuals contemplated in the legislation, ANHBC will obtain consent for the collection, use and disclosure of personal information from parents, caregivers or appropriate alternate decision-makers.
ANHBC may collect, use and disclose of personal information about an identifiable individual without their consent under the following exceptions:
- as required by ANHBC legal advisors;
- in an emergency situation where an individual’s life or safety is at risk (use only);
- when the information is necessary for the medical treatment of the individual, and the individual is unable to give consent to the collection, or lacks legal capacity to give consent to the use of disclosure;
- as required to collect a debt;
- in certain circumstances where it is deemed in the best interest of the individual and consent cannot be obtained in a timely way;
- in other circumstances required or permitted by law.
RETENTION OF PERSONAL INFORMATION
ANHBC will retain, for at least one year, the personal information it uses to make a decision that directly affects the individual in question. We will also retain some personal information as required by funding partners or as required by law. We will dispose of personal information after the fulfillment of the purposes for which it was collected, and retention is no longer necessary for legal and business purposes.
INDIVIDUAL ACCESS TO PERSONAL INFORMATION
An individual may request access to their personal information. Requests will be handled within the time limits set out in the legislation.
Whenever possible, access to personal information will be provided without charge to the individual. ANHBC may charge a minimal fee to the requester for access to their personal information.
ANHBC must withhold access to an individual’s personal information if access:
- can reasonably be expected to cause harm to the safety or health of the requesting individual;
- can reasonably be expected to threaten the safety or health of a third party;
- would reveal personal information about a third party;
- would reveal the identity of a third party who has provided personal information about another individual, and the third party has not consented to the disclosure of their identity.
ANHBC is not required to provide access to personal information in certain other circumstances. If access cannot be provided to the individual, ANHBC will provide a written explanation for the denial.
We respect the right of individuals about whom we have collected, used, disclosed or retained personal information, to request a review of their personal information under our control.
ANHBC is committed to using reasonable efforts to ensure that the personal information collected by us or on our behalf is accurate and complete. If the personal information is likely to be used by us to make a decision that affects the individual to whom the information relates, or is likely to be disclosed by it to another organization, individuals will have the opportunity to request correction of their personal information.
ANHBC expects its employees, members, volunteers, program participants, independent contractors and donors to notify ANHBC of changes to their personal information as required to maintain ongoing relationships. Where there is a disagreement between ANHBC and the individual requesting correction about the accuracy of personal information, ANHBC will add a document outlining the disputed information for addition into the file.
PROTECTION OF PERSONAL INFORMATION
ANHBC staff and volunteers are required to sign the ANHBC Statement of Confidentiality as a condition of their employment or volunteer placement.
Our Privacy Officer will conduct a privacy audit and has established safeguards and procedures for the collection, use and storage of personal information. Our staff and volunteers who come into contct with personal information receive privacy orientation and ongoing training.