Privacy Policy - Vancouver Mind-Body Centre

Personal Information Protection Policy

At Vancouver Mind-Body Centre Society, we are committed to providing our students and members with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our students and members, protecting their personal information is of utmost importance.

While we have always respected our students and members 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 students and members 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 students’ and members’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our students’ and members’ personal information and allowing our students’ and members’ to request access to, and correction of, their personal information.

Scope of this Policy

This Personal Information Protection Policy applies to Vancouver Mind-Body Centre Society and its affiliate groups: Vancouver Mind-Body Aikikai Society, Ken Wa Kai.

This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Vancouver Mind-Body Centre Society.

Definitions

Personal Information –means information about an identifiable individual. 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 Vancouver Mind-Body Centre complies with this policy and PIPA.

Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the student, member, 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 Personal information that is necessary to fulfill the following purposes:

To verify identity;
To verify creditworthiness;
To identify student and member preferences;
To understand the fitness, health, mental and financial needs of our students and members;
To deliver requested products and services;
To enroll the client in a program;
To send out association membership information;
To contact our students and members for fundraising;
To ensure a high standard of service to our students and members;
To assess suitability for participation in programs;
To collect and process program payments;
For any of the purposes stated above, or any other purpose that may arise we will not collect more information than that that is specifically required for the provision of services to our students and members.

Policy 2 – Consent

2.1 We will obtain student and members’ 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 in writing, verbally, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the student or member voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a student or member is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, fundraising and the student or member 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), student or member can withhold or withdraw their consent for Vancouver Mind-Body Centre to use their personal information in certain ways. A student or members’ 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 student or member in making the decision.

2.5 We may collect, use or disclose personal information without the student or member’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 student or members’ personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:

To conduct student or member surveys in order to enhance the provision of our services;
To contact our students or members directly about products and services that may be of interest;

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

3.3 We will not sell, rent or share student or member lists or personal information to or with other parties.

Policy 4 – Retaining Personal Information

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

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

5.2 Students or members 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 student’s or members’ correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of student or member 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 student or member personal information is appropriately protected:

All personal information will be kept in a locked office accessible only to authorized instructors and staff.

Electronic records will be stored on secured servers by third parties but accessible only to Vancouver Mind-Body instructors and staff.

6.3 We will use appropriate security measures when destroying student or member personal information such as shredding documents and deleting electronically 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 Student or Member Access to Personal Information

7.1 Student or member have a right to access their personal information, subject to limited exceptions as defined by section 23 of the Personal Information Protection Act.

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 students or members 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 student or member of the cost and request further direction from the student or member 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 student or member in writing, providing the reasons for refusal and the recourse available to the student or member.

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 Vancouver Mind-Body Centre’s compliance with this policy and the Personal Information Protection Act.

8.2 Students and members should direct any complaints, concerns or questions regarding Vancouver Mind-Body’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the student or member may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for Vancouver Mind-Body Centre’s Privacy Officer: privacy@vancouvermindbody.com