PRIVACY
Naramata Slow Community Group
Personal Information Protection Policy
Providing this service involves the collection, use and disclosure of some personal information about our
subscribers protecting their personal information is one of our highest priorities.
While we have always respected our subscriber’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 subscribers 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 subscribers’ personal information. Our privacy commitment includes ensuring the
accuracy, confidentiality, and security of our subscribers’ personal information and allowing our subscribers’ to
request access to, and correction of, their personal information.
This Personal Information Protection Policy applies to Naramata Slow Community Group.
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of
Naramata Slow Community Group.
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 Naramata Slow Community
Group complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the subscriber 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 subscriber information that is necessary to fulfill the following purposes:
To deliver requested products and services
To contact our subscribers for fundraising;
To meet regulatory requirements;
Policy 2 – Consent
2.1 We will obtain subscriber 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 verbally 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 subscriber voluntarily
provides personal information for that purpose.
2.3 Consent may also be implied where a subscriber is given notice and a reasonable opportunity to opt-out
of his or her personal information being used for mail-outs, and/or fundraising and the subscriber 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), subscriber
can withhold or withdraw their consent for Naramata Slow Community Group to use their personal
information in certain ways. A subscriber’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 subscriber in making the decision.
2.5 We may collect, use or disclose personal information without the subscriber 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;
To protect ourselves from fraud;
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose subscriber personal information where necessary to fulfill the purposes
identified at the time of collection
To conduct subscriber surveys.
To contact our subscribers directly about community related matters that may be of interest;
3.2 We will not use or disclose subscriber personal information for any additional purpose unless we obtain
consent to do so.
3.3 We will not sell subscriber lists or personal information to other parties [unless we have consent to do
so].
Policy 4 – Retaining Personal Information
4.1 If we use subscriber personal information to make a decision that directly affects the subscriber we will
retain that personal information for at least one year so that the subscriber has a reasonable opportunity
to request access to it.
4.2 Subject to policy 4.1, we will retain subscriber 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 subscriber personal information is accurate and complete
where it may be used to make a decision about the subscriber or disclosed to another organization.
5.2 Subscribers 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 email address
naramataslow@gmail.com
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 subscriber
correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of subscriber 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 subscriber personal information is
appropriately protected:
6.3 We will use appropriate security measures when destroying subscriber 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 Subscribers Access to Personal Information
7.1 Subscribers 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 subscribers 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 subscriber of the cost and request further direction from the subscriber 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 subscriber in writing, providing the reasons for
refusal and the recourse available to the subscriber.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 Our Directors are responsible for ensuring Naramata Slow Community Group compliance with this policy
and the Personal Information Protection Act.
8.2 Subscribers should direct any complaints, concerns or questions regarding Naramata Slow Community
Group’s compliance in writing to naramataslow@gmail.com. If a Director is unable to resolve the
concern, the subscriber may also write to the Information and Privacy Commissioner of British
Columbia.
Contact information for Naramata Slow Community Group:
naramataslow@gmail.com