Ookpik Services Inc. Personal Information Protection Policy
At Ookpik Services Inc. (“Ookpik”), we are committed to providing our clients, customers and colleagues with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, customers and colleagues, protecting their personal information is one of our highest priorities.
We always respect our clients’, customers’ and colleagues’ privacy and safeguard their personal information by strictly adhering to 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 clients, customers and colleagues 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 clients’, customers’ and colleagues’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’, customers’ and colleagues’ personal information and allowing our clients, customers and colleagues to request access to, and correction of, their personal information.
Scope of this Policy
This Personal Information Protection Policy applies to Ookpik and its subsidiaries, and to any service providers collecting, using or disclosing personal information on behalf of Ookpik.
Personal Information – means information about an identifiable individual, including name, home address and phone number, employment information. 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 Ookpik 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, customer or colleague voluntarily provides their 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’, customers’ and colleagues’ information that is necessary to fulfill the following purposes:
To identify clients’, customers’ and colleagues’ preferences;
To assess and determine clients’, customers’ and colleagues’ needs;
To quote on, contract for and deliver requested products and services;
To provide educational services;
To send out information about services and events;
To ensure a high standard of service to our clients, customers and colleagues; and
To collect and process payments for services rendered.
Policy 2 – Consent
2.1 We will obtain client, customer and colleague 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, or electronically, or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client, customer or colleague voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client, customer or colleague is given notice and a reasonable opportunity to opt-out of their personal information being used for mail-outs, the marketing of new services or products, fundraising and the client, customer or colleague 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, customers and colleagues can withhold or withdraw their consent for Ookpik to use their personal information in certain ways. A client’s, customer’s or colleague’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, customer or colleague in making the decision.
2.5 We may collect, use or disclose personal information without the client’s, customer’s or colleague’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 we require legal advice from a lawyer;
To protect ourselves from fraud; and
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 client, customer or colleague 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 client, customer and colleague surveys in order to enhance the provision of our services; and
To contact our clients, customers and colleagues directly about products and services that may be of interest.
3.2 We will not use or disclose clients’, customers’ or colleagues’ personal information for any additional purpose unless we obtain consent to do so.
3.3 We will never sell client, customer or colleague lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use clients’, customers’ and colleagues’ personal information to make a decision that directly affects the client, customer or colleague, we will retain that personal information for at least one year so that the client, customer or colleague has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain clients’, customers’ and colleagues’ 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 every reasonable effort to ensure that clients’, customers’ and colleagues’ personal information is accurate and complete where it may be used to make a decision about the client, customer or colleague or disclosed to another organization.
5.2 Clients, customers and colleagues 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, orally, or electronically 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 clients’, customers’ or colleagues’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client, customer and colleague 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’, customers’ and colleagues’ personal information is appropriately protected:
Restricting employee access to personal information as appropriate (i.e., only those that need to know will have access; contractually requiring any service providers to provide comparable security measures]; and
Encrypting data and internet connections to the best of our capabilities.
6.3 We will use appropriate security measures when destroying clients’, customers’ and colleagues’ 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 Clients, Customers and Colleagues Access to Personal Information
7.1 Clients, customers and colleagues have a right to access their personal information, subject to limited exceptions, for example, if the disclosure would reveal personal information about another individual.
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 clients, customers and colleagues 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 client, customer or colleague of the cost and request further direction from the client, customer or colleague 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 client, customer or colleague in writing, providing the reasons for refusal and the recourse available to the client, customer or colleague.
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 Ookpik’s compliance with this policy and the Personal Information Protection Act.
8.2 Clients, customers and colleagues should direct any complaints, concerns or questions regarding Ookpik’s compliance in writing to the Privacy Officer. If
the Privacy Officer is unable to resolve the concern, the client, customer or colleague may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Ookpik’s Privacy Officer or designated individual:
Last updated: September 10, 2019