At the Green Party of British Columbia, we are committed to providing our constituents (members and supporters) with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our constituent, protecting their personal information is one of our highest priorities.
While we have always respected our constituent’s 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, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.
We will inform our constituents as to 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 constituent’s personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our constituent’s personal information and allowing our constituent’s to request access to, and correction of, their personal information.
Scope of this Policy; The scope of the Green Party’s efforts will encompass all personal information under the custodianship of the Green Party. We must protect it and use it for only the purposes that have been agreed to in order to maintain the confidence and trust of our constituents.
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Green Party of BC.
Personal Information –means information about an identifiable individual Defined by the Canadian Institute of Chartered Accountants (CICA) and the American Institute of Certified Public Accountants (AICPA). Personally Identifiable Information is any information relating to an identified or identifiable individual broken into two of the following categories:
(a). ‘Private Information’ (PI) customer’s name address, telephone number, social security/insurance, other government identification numbers, employer, credit card numbers, personal or family financial information, personal or family medical information, employment history, history of purchases or other transactions, credit records and similar information.
(b). ‘Sensitive Private Information’ medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, sexual preferences.
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 Green Party of BC complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the constituent 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 constituent information that is necessary to fulfill the following purposes:
• To verify identity;
• To identify constituents’ preferences;
• To understand the needs of our constituents;
• To open and manage an account;
• To deliver requested pertinent information and services
• To enrol the constituent in a program;
• To send out Green Party membership information;
• To contact our constituents for fundraising;
• To ensure a high standard of service to our constituents;
• To meet regulatory requirements;
Policy 2 – Consent
2.1 We will obtain constituent 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 orally, in writing, electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the constituent voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where constituent is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail, fundraising and the constituent 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), a constituent can withhold or withdraw his or her consent for Green Party of BC to use their personal information in certain ways. A constituent’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 constituent in making the decision.
2.5 We may collect, use or disclose personal information without the constituent’s knowledge or consent in the following limited circumstances:
• When the collection, use or disclosure of personal information is permitted or required by law;
• In an emergency that threatens an individual’s life, health, or personal security;
• When the personal information is available from a public source (e.g., a telephone directory);
• When we require legal advice from a lawyer;
• For the purposes of collecting a debt;
• To protect ourselves from fraud;
• To investigate an anticipated breach of an agreement or a contravention of law
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose constituent’s personal information where necessary to fulfill the purposes identified at the time of collection for the following purposes generally:
• To conduct constituent surveys in order to enhance the Green Party of BC’s ability to serve its constituency more effectively;
• To contact our constituents directly regarding the Green Party of BC’s political plans and services that may be of interest;
• To request donations from our constituents for the Green Party of BC or constituency associations of the party;
3.2 We will not use or disclose constituent personal information for any additional purpose unless we obtain consent to do so.
3.3 The Green Party of BC shares member information with the Green Party of Canada unless otherwise instructed by a member. We will not sell or otherwise provide constituent lists or personal information to other political parties.
Policy 4 – Retaining Personal Information
4.1 If we use constituent personal information to make a decision that directly affects the constituent, we will retain that personal information for at least one year so that the constituent has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain constituent 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 constituent’s personal information is accurate and complete where it may be used to make a decision about the constituent or disclosed to another organization.
5.2 Constituents 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 to the designated Green Party Privacy Officer 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 constituent correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of constituent’s 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 constituent’s personal information is appropriately protected:
Standard /Classification: Security Standard
Granting Access Rights: Executive Director
Network Access Control: VPN
Physical Removal: Not Advised
Duplicating/Copying: Permission of Owner Advised
Faxing: Restricted Mailbox or Attended Receipt
Third-party / External-party Disclosure: Contract, SLA, NDA
US Personnel Disclosure: Orientation, NDA
Electronic Media Labeling: Release Date plus Classification
External and Internal Labels
Hardcopy Labeling Required: Each Page if Loose Sheets
Physical Mail Handling: Address to Specific Person but Label
Tracking Process by Log: Recipients, Copies Made, Locations, Addresses
Those who Viewed and Confirmation of Destruction.
Human Resources: Orientation, NDA
Remote Access: VPN
Desktop: Restricted Access, USB, DVD, IR
Laptop: Restricted Access, USB, DVD, IR
6.3 We will use appropriate security measures when destroying, constituent’s personal information such as:
Standard /Classification: Security Standard
Disposal/Destruction: Shred or Secure Disposal Box
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 Constituents with Access to Personal Information
7.1 Constituent’s 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 constituents 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 constituents of the cost and request further direction from the constituents 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 constituents in writing, providing the reasons for refusal and the recourse available to the constituents.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer or designated individual is responsible for ensuring the Green Party of BC’s compliance with this policy and the Personal Information Protection Act.
8.2 Constituents should direct any complaints, concerns or questions regarding Green Party of BC’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the constituents may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Green Party of BC’s Privacy Officer:
1-888-473-3686 ext. 0