Established by a motion of the CoDevelopment Canada Board of Directors on September 28, 2004.
CoDevelopment Canada 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 CoDevelopment Canada.
Policy – detailed clauses
CoDevelopment Canada 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.
CoDevelopment Canada 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: CoDevelopment Canada 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: CoDevelopment Canada 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
- CoDevelopment Canada 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.
CoDevelopment Canada 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.
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 CoDevelopment Canada. On receipt of such notice, CoDevelopment Canada will inform the individual of the likely consequences of the withdrawal of consent, which may include the inability of CoDevelopment Canada to provide certain products, services, or communications pertaining to CoDevelopment Canada and the work it conducts if the information is necessary to provide said products, services and communications.
When collecting personal information such as the name, position, business or home address, telephone number, email, or opinions of an individual, CoDevelopment Canada will state the purpose of collection as follows:
CoDevelopment Canada may use your personal information to send you newsletters, meeting notices, urgent actions, membership renewals, donation requests, official receipts, notices of elections to the Board of Directors, 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.
CoDevelopment Canada 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.
CoDevelopment Canada will limit the collection of information to information that is necessary to provide a product, service, or communication pertaining to CoDevelopment Canada 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.
CoDevelopment Canada 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.
CoDevelopment Canada 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, CoDevelopment Canada will take all reasonable steps to protect the interests of its members and other individuals.
CoDevelopment Canada will not share personal information with other individuals, service providers or related organizations without explicit consent, unless required or authorized by law.
On a need-to-know basis, the employees and selected volunteers of CoDevelopment Canada will have access to personal information under the control of CoDevelopment Canada. CoDevelopment Canada may also contract the services of another organization which may have access to personal information and which will act in the same manner as CoDevelopment Canada’s employees and volunteers to ensure privacy.
A member may request a record of his or her personal information under the control of CoDevelopment Canada, 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. CoDevelopment Canada may charge a minimal fee for providing this information.
For other information, upon written request, CoDevelopment Canada will provide the individual with personal information under the control of CoDevelopment Canada, 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. CoDevelopment Canada may charge a minimal fee for providing this information, and will provide an estimate of this fee upon receiving the access to information request. CoDevelopment Canada may require a deposit for all or part of the fee.
- Assistance: CoDevelopment Canada 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 CoDevelopment Canada 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: CoDevelopment Canada 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: CoDevelopment Canada 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, CoDevelopment Canada may apply to the BC Privacy Commissioner for an extension under the Personal Information Protection Act.
- Refusals: If CoDevelopment Canada refuses access to personal information, CoDevelopment Canada’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 CoDevelopment Canada who can answer the applicant’s questions about the refusal. CoDevelopment Canada may refuse to confirm or deny the existence of personal information collected as part of an investigation.
CoDevelopment Canada will make a reasonable effort to ensure that personal information it is using or disclosing is accurate and complete.
If an individual demonstrates the inaccuracy or incompleteness of personal information, CoDevelopment Canada will amend the information as required. If appropriate, CoDevelopment Canada 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, CoDevelopment Canada will annotate the personal information under its control with a note that the correction was requested but not made.
CoDevelopment Canada 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. CoDevelopment Canada 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.
CoDevelopment Canada 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.
CoDevelopment Canada 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. CoDevelopment Canada will take due care with the destruction of personal information so as to prevent unauthorized parties from gaining access to the information.
CoDevelopment Canada 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 CoDevelopment Canada and its work, and may update the information as necessary to provide communications, products, and services applied for.
CoDevelopment Canada 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 CoDevelopment Canada’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 CoDevelopment Canada has reasonable grounds to believe that personal information is being inappropriately collected, used, or disclosed.
CoDevelopment Canada will, on request, inform members and other individuals of its complaint procedures, which will be accessible and simple to use.
CoDevelopment Canada 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
Members and other individuals may direct any inquiries or complaints regarding their personal information to CoDevelopment Canada’s Privacy Officer at 604-708-1495 ext.112 or firstname.lastname@example.org