CHILLIWACK HOSPICE SOCIETY PRIVACY POLICY

January 1, 2004

Privacy Statement

The Society will maintain policies and practices necessary for compliance with the Personal Information Protection Act of British Columbia and a process to respond to complaints that may arise, and make information available, on request, about the policies and practices and the complaint process.

The privacy and the security of personal information are important to us. We aspire to serve all individuals effectively and conveniently with the highest level of service while maintaining confidentiality.

Our Commitment

We are committed to ensuring the confidentiality and privacy and protecting the personal information of all individuals whose personal information is collected and held by the Chilliwack Hospice Society and to adhere to all Provincial legislative requirements with respect to protecting privacy.

We understand the concerns of individuals in providing personal information and are committed to protecting the confidentiality and privacy of all personal information.

Privacy Officer

The Society has designated the Executive Director as the Privacy Officer, to oversee the protection of personal information and compliance with the British Columbia Personal Information Protection Act, and the Society's privacy policies and practices.

Consent

The Society will obtain consent for the collection, use, and disclosure of personal information, except in circumstances permitted by the Personal Information Protection Act or other law.

Express Consent
The Society will obtain express written or oral consent to the collection, use and disclosure of personal information, except in circumstances when the Personal Information Protection Act authorizes the collection, use, or disclosure without consent or deems the collection, use, or disclosure to be consented to.

Implicit 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
The Society may obtain consent to collect, use, or disclose personal information for specified purposes.  If the Society sends notice to the individual that it intends to collect, use, or disclose personal information for those specified purposes and gives the individual a reasonable opportunity to decline to have the personal information collected, used, or disclosed for those purposes.  If the individual does not decline the collection, use, or disclosure for those purposes, and the collection, use or disclosure is reasonable having regard to the sensitivity of the personal information in the circumstance, deemed consent will be implied.

Condition
The Society will not, as a condition of providing a service, require an individual to consent to the collection, use, or disclosure of personal information beyond what is necessary to provide the service.

Withdrawal
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 the Society.

On receipt of notice of withdrawal of consent, the Society will inform the individual of the likely consequences of the withdrawal of consent, which may include the inability of the Society to provide certain services, if the information is necessary to provide the services.

Withdrawal Request
If at any time an individual wishes his/her name to be removed from the mailing list or would prefer his/her name not be listed as a donor, the individual must contact the Society and the Society will accommodate the request.

Any request must be directed to:

• By phone at 604-795-4660
• Via Email
• By mail at 45360 Hodgins Ave, Chilliwack, BC V2P 1P5

Collecting Information

Purposes
When collecting information, the Society will state the purpose of collection and provide, on request, the contact information for the officer who can answer the individual's questions about the collection.

Collection
The Society will limit the collection of information to information that is necessary to provide a service or 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.

Use
The Society will not use personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or authorized by law.

The personal information we hold from donors and members will be used to provide tax receipts and to keep them informed and up to date on the activities of the Society including programs, services, special events, funding needs and opportunities to volunteer.

The personal information we hold from clients will be used to assess needs and ensure the appropriate services are provided. 

The personal information we hold from volunteers will be used when enrolling as a volunteer, to assess his/her skills and determine the appropriate services they can provide.

The personal information we hold from staff will be used when hiring, to assess ongoing performance and for providing employee benefits.

Periodically the Society will publish the names of its supporters.

Disclosure
The Society will not disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or authorized by law.

When disclosing personal information the Society will take all reasonable steps to protect the interests of the individual.

Sharing
The Society will not share personal information with other agencies that are not directly related to the Societies ongoing mandate and interest without the consent of the member, client, volunteer and other individual or as required or authorized by law.

Accuracy
The Society will make a reasonable effort to ensure that personal information it is using or disclosing is accurate and complete.

Access to Personal Information

Personal information will be provided upon request as consented, or as required or authorized by law.

The Society will provide the individual making the request with the personal information under the control of the Society, 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.

All requests for personal information must be made in writing and contain sufficient information to permit the Society to provide and disclose the personal information it holds.

Assistance
The Society 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 the Society to provide, use, and disclose the personal information it holds. The additional information provided will only be used for this purpose.

Exceptions
The Society 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
The Society will endeavour to respond to an access to information request within 30 days.

If additional time is required because the applicant has not provided sufficient detail, a large amount of material is requested or must be retrieved, or more time is needed to consult with other organizations, the Society may apply to the BC Privacy Commissioner for an extension under the Personal Information Protection Act.

Refusals
If the Society refuses access to personal information, the Society'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 the Society who can answer the applicant's questions about the refusal.
The Society may refuse to confirm or deny the existence of personal information collected as part of an investigation.

Corrections
If an individual demonstrates the inaccuracy or incompleteness of personal information, the Society will amend the information as required. If appropriate, the Society will send the amended information to third parties to whom the information has been disclosed, if applicable.

When a challenge regarding the accuracy of personal information is not resolved to the satisfaction of the individual, the Society will annotate the personal information under its control with a note that the correction was requested but not made.

Security

Protection
The Society 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.

Safeguarding
The Society 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 offices
• organizational measures such as restricting employee and volunteers access to files and databases
• electronic measures such as passwords and encryption, and
• investigative measures if the Society has reasonable grounds to believe that personal information is being inappropriately collected, used, or disclosed.

Retention
The Society will keep personal information used to make a decision that affects the individual for at least one year after using it to make the decision.

The Society 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.

The Society may retain personal information about members, clients, volunteers and other individuals with their consent in order to assist in the provision of future services and for fundraising purposes, such as sending information about services that may be of interest, and may update the information as necessary to provide services applied for.

Destruction
The Society will take due care with the destruction of personal information so as to prevent unauthorized parties from gaining access to the information.

Complaint Process
The Society will maintain a complaint procedure, which will be accessible and simple to use.

All complaints relating to personal information must be made in writing and addressed to the Privacy Officer. The complaint must contain sufficient information to permit the Society to respond to the complaint.  Information required includes the circumstances forming part of the complaint, the name of the individual making the complaint, the circumstances leading to the complaint and any other information believed relevant to assist with the resolution of the complaint.

The Society will ensure that inquiries, concerns, and complaints regarding personal information receive prompt attention and are resolved in a timely manner.

Individuals should direct any inquiries or complaints regarding their personal information to the Society's Privacy Officer by inquiring at the Society office:

• By phone at 604 795-4660
• Via Email 
• By mail at 45360 Hodgins Ave, Chilliwack, BC  V2P 1P5.

Appeal
All complaints and/or concerns must firstly be brought to the attention of the Society.

Where appropriate, individuals will be informed of their right to file a complaint with the BC Privacy Commissioner.

If the individual and the Society are unable to resolve the complaint, the individual may contact the BC Privacy Commissioner, an independent officer of the Legislature, to review, investigate the complaint and authorize mediation and negotiate to resolve the dispute.

Office of the Information and Privacy Commissioner for British Columbia
PO Box 9038
Station Provincial Government
Victoria, BC V8W 9A4

Telephone: 1-800-663-1376
Fax: 1-250-387-1696

E-Mail: info@oipc.bc.ca
Web Site: www.oipc.bc.ca

Personal Information Protection Act
Additional information on the Personal Information Protection Act. may be obtained from:

The Corporate Privacy and Information Access Branch
Ministry of Management Services
PO Box 9403
Station Provincial Government
Victoria, BC V8W 9V1

Telephone: 1-800-663-1376
Fax: 1-250-953-0455

E-Mail: CPIAADMIN@gems5.gov.bc.ca
Web Site: www.mser.gov.bc.ca/FOI_POP/