Personal Information Protection Policy

Definitions

Personal Information –means information about an identifiable individual, including name, email address, postal code, home address and phone number.  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 Aryze complies with this policy and PIPA.

Policy 1 – Collecting Personal Information

1.1  Unless the purposes for collecting personal information are obvious and the client/community 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 clients’ and community members’ information that is necessary to fulfill the following purposes:

• To respond to our clients’ and community members’ inquiries submitted through the website, we may collect full name, email address, phone number;
• To maintain corporate community engagement standards, we may collect full name, email address, phone number, address, postal code;
• To communicate updates regarding our proposed development, we may collect full name, phone number, email address;
• To send an invite to a community information session, we may collect full name, email address, phone number, address, postal code;
• To identify clients’ and community members’ preferences, we may collect full name, email address, phone number, address postal code;
• To understand the housing needs of our clients and community members, we may collect  full name, email address, phone number, postal code;
• To deliver requested products and services, we may collect full name, email address, phone number, postal code;
• To send our quarterly newsletter, we may collect full name and email address;

Policy 2 – Consent

2.1  We will obtain clients’ and community memebers’ 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 electronically or in writing or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client/community member voluntarily provides personal information for that purpose.

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

2.5  We may collect, use or disclose personal information without the client’s/community 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;
• When we require legal advice from a lawyer;
• 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 clients’ and community 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 clients and community members surveys in order to enhance the provision of our services;

3.2  We will not use or disclose clients’ and community members’ personal information for any additional purpose unless we obtain consent to do so.

3.3  We will not sell clients’ and community members’ lists or personal information to other parties.

Policy 4 – Retaining Personal Information

4.1  If we use clients’ and community members’ personal information to make a decision that directly affects the client/community member, we will retain that personal information for at least one year so that the clients and community members have a reasonable opportunity to request access to it.

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

5.2  Clients and community 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.

A request to correct personal information should be forwarded to the Marketing & Communications Coordinator.

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 client’s/community member’s correction request in the file.

Policy 6 – Securing Personal Information

6.1  We are committed to ensuring the security of clients’ and community members’ 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 clients’ and community members’ personal information is appropriately protected:

• Physically securing offices where personal information is held
• The use of user IDs, passwords and encryption
• Restricting employee access to personal information as appropriate

6.3  We will use appropriate security measures when destroying clients’ and community members’ personal information such as 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 Clients and Community Members Access to Personal Information

7.1  Clients and community members have a right to access their personal information, subject to limited exceptions.

Aryze is not required to disclose personal information and other information under subsection (1) or (2) in the following circumstances:

1. The disclosure of the information would reveal confidential commercial information that if disclosed, could, in the opinion of a reasonable person, harm the competitive position of the organization;

Aryze must not disclose personal information and other information under subsection (1) or (2) in the following circumstances:

1. The disclosure could reasonably be expected to threaten the safety or physical or mental health of an individual other than the individual who made the request;
2. The disclosure can reasonably be expected to cause immediate or grave harm to the safety or to the physical or mental health of the individual who made the request;
3. The disclosure would reveal personal information about another individual;
4. The disclosure would reveal the identity of an individual who has provided personal information about another individual and the individual providing the personal information does not consent to disclosure of his or her identity.
   

7.2  A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Marketing & Communications Coordinator.

7.3  Upon request, we will also tell clients and community 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 clients and community members of the cost and request further direction from the client/community 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 clients and community members in writing, providing the reasons for refusal and the recourse available to the client/community member.

Policy 8 – Questions and Complaints: The Role of the Privacy Officer

8.1 The Privacy Officer is responsible for ensuring Aryze’s compliance with this policy and the Personal Information Protection Act.

8.2 Clients and community members should direct any complaints, concerns or questions regarding Aryze’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the clients and community members may also write to the Information and Privacy Commissioner of British Columbia.