Personal Information Protection Policy
At Victoria Platinum Concierge, we are committed to providing our contractors, employees, associates and clients with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our contractors, employees, associates and clients, protecting their personal information is one of our highest priorities.
While we have always respected our contractors’, employees’, associates’ and clients’ 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 sets out the ground rules for how B.C. businesses may collect, use and disclose personal information.
We will inform our contractors, employees, associates and clients 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 contractors’, employees’, associates’ and clients’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our contractors’, employees’, associates’ and clients’ personal information and allowing our contractors, employees, associates and clients to request access to, and correction of, their personal information.
Scope of this Policy
This Personal Information Protection Policy applies to Victoria Platinum Concierge. This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Victoria Platinum Concierge.
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/s designated responsibility for ensuring that Victoria Platinum Concierge complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the contractor, employee and associate 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 contractor, employee and associate information that is necessary to fulfill the following purposes:
- To verify identity;
- To identify [contractors’, employees’, associates’ and clients’] preferences
- To open and manage an account
- To deliver requested products and services
- To guarantee a travel or hotel reservation
- To process a magazine subscription
- To provide [medical, dental, counselling] services;
- To enrol the [contractors, employees, associates and clients] in a program
- To send out association membership information
- To ensure a high standard of service to our [contractors, employees, associates and clients]
- To meet regulatory requirements
- To assess suitability for contractual engagement
- To determine contract rates
- To manage training and/or certifications requirements
- To obtain permissions and securities clearances from official bodies such as Transport Canada.
Policy 2 – Consent
2.1 We will obtain contractors, employees, associates and clients 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 in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the contractors, employees, associates and clients voluntarily provides personal information for that purpose.
2.3 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), contractors, employees, associates and clients can withhold or withdraw their consent for Victoria Platinum Concierge to use their personal information in certain ways. A client’s, customer’s, 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 contractor, employee and associate in making the decision.
2.4 We may collect, use or disclose personal information without the client’s, customer’s, 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;
- 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 law
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose contractors’, employees’, associates’ and clients’ personal information where necessary to fulfill the purposes identified at the time of collection
- To conduct contractors, employees, associates and clients surveys in order to enhance the provision of our services
- To contact our [contractors, employees, associates and clients] directly about products and services that may be of interest or required in the course of providing services for Victoria Platinum Concierge]
3.2 We will not use or disclose contractors, employees, associates and clients personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell contractors, employees, associates and clients lists or personal information to other parties [unless we have consent to do so].
Policy 4 – Retaining Personal Information
4.1 If we use contractors’, employees’, associates’ and clients’ personal information to make a decision that directly affects the contractors, employees, associates and clients, we will retain that personal information for at least one year so that the contractor, employee, associate and client has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain contractor, employee, associate and client 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 contractor, employee, associate and client personal information is accurate and complete where it may be used to make a decision about the contractor, employee and associate or disclosed to another organization.
5.2 Contractors, employees, associates and clients 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.
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’, members’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of contractor, employee, associate and client 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 contractor, employee, associate and client personal information is appropriately protected in cloud-storage provided by DropBox.
Unique, strong passwords – Creation of passwords that are not used anywhere else, and make it hard to guess. Testing of password with our strength estimator when you create your account or reset your password. Learn more
Two-step verification – This security feature adds an extra layer of protection to your account. Once enabled, Dropbox will require a six-digit code or a USB security key when signing in or linking a new device. For security keys, Dropbox supports the open standard FIDO Universal 2nd Factor (U2F). A U2F security key uses cryptographic communication and provides additional protection against credential theft attacks like phishing.
Monitor account activity – We monitor linked devices, active web sessions, and third-party apps with access to your account. From the Events page, you can track changes to files and folders, including edits, deletions, and shared folder membership.
6.3 We will use appropriate security measures when destroying client’s, customer’s, member’s personal information such as secure deletion of pertinent data.
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 Contractors, Employees, Associates and Clients Access to Personal Information
7.1 Contractors, employees, associates and clients 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 contractors, employees, associates and clients 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 contractors, employees, associates and clients of the cost and request further direction from the contractor, employee and associate 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 contractors, employees, associates and clients in writing, providing the reasons for refusal and the recourse available to the contractor, employee and associate.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual/s
8.1 The Privacy Officer or designated individual/s is responsible for ensuring Victoria Platinum Concierge’s compliance with this policy and the Personal Information Protection Act.
8.2 Contractors, employees, associates and clients should direct any complaints, concerns or questions regarding Victoria Platinum Concierge’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the contractor, employee and associate may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Victoria Platinum Concierge’s Privacy Officer or designated individual/s:
I have read, understood the scope of this document and am in agreement with the collection of personal data as outlined in this document. Initial all pages and sign:
|V1.0||Created by||Fredy Boese||Date||9 March 2019|
|Verified by||Steve Duck||Date||9 March 2019|