At the BC Green Party, we are committed to providing our constituents (members, supporters and voters) with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about constituents and voters, protecting their personal information is one of our highest priorities.
While we have always respected our constituents’ 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 BC 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 constituents’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our constituents’ personal information and allowing our constituents’ to request access to, and correction of, their personal information.
Scope of this policy
The scope of the BC Green Party’s efforts will encompass all personal information under the custodianship of the BC 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 BC Green Party.
Personal Information and Protection Act (PIPA)
Personal Information Protection Act (PIPA) is a British Columbia law that sets out rules for how private sector organization (such as a business or corporation, union, political party, and not-for-profit) collect, use and disclose personal information. PIPA came into effect in February 2004.
“Information about an identifiable individual, which means a person can be identified by the information, either directly (e.g. name, image, job title) or in combination with other information,” excluding business contact information or work product information. For example, personal information includes an individual’s name, mailing address, email address, phone number and engagement history with the party.
Consent occurs when an individual:
- Understands the purpose for the collection of their personal information; and
- Voluntarily provides their personal information.
Consent is further defined by the type of understanding of the purpose for the collection of their personal information required:
Express consent occurs when an individual voluntarily provides personal information after being presented with the purpose of the collection of that information. Express consent can be given in writing or verbally.
Implied consent occurs when an individual voluntarily provides personal information for a collection purpose that a reasonable person would consider appropriate in the circumstances.
Opt-out consent is consent by not declining consent. For example, a form notifying an individual of the organization’s intended use of the personal information with a “check-off” box. Individuals can check the box if they do not want the business using their information for this purpose.
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 the 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 the BC Green Party 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 the 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 BC Green Party will not sell or 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 Constituents 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 BC Green Party’s compliance with this policy and the Personal Information Protection Act.
8.2 Constituents should direct any complaints, concerns or questions regarding BC Green Party’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 the BC Green Party Privacy Officer
1-888-473-3686 ext. 0