Administrative Policy: Personal Information Protection Policy
Date Issued: February 01, 2018
At the Victoria Conservatory of Music, we are committed to providing our students, donors, and customers with exceptional service. As providing this service involves the collection, use, and disclosure of some personal information, protecting our students’, donors’, and customers’ personal information is important.
British Columbia’s Personal Information Protection Act (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 students, donors, and customers 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 the PIPA, outlines the principles and practices we will follow in protecting students’, donors’, and customers’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our students’, donors’, and customers’ personal information and allowing them to request access to, and correction of, their personal information.
Personal Information: information about an individual, including, but not limited to, name, home address, telephone numbers, social insurance number, birth date, medical information, and payment card or banking information.
Contact information: 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, or business email. Contact information is not covered by this policy of the PIPA.
Privacy Officer: the individual designated responsible for ensuring that the Victoria Conservatory of Music complies with this policy and the PIPA.
1. Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the student, donor, or customer 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 student, donor, or customer information that is necessary to fulfill the following purposes:
• To verify identity;
• To register someone in programs or lessons;
• To sell a ticket;
• To identify student, donor, or customer preferences;
• To deliver requested products and services;
• To contact our students, donors, and customers for fundraising;
• To ensure a high standard of service to our students, donors, and customers;
• To meet regulatory requirements; and
• To collect and process rental payments.
2.1 We will obtain student, donor, or customer 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 student, donor, or customer voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a student, donor, or customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, and/or fundraising and the student, donor, or customer 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), students, donors, and customers can withhold or withdraw their consent for the Victoria Conservatory of Music to use their personal information in certain ways. A student’s, donor’s, or customer’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 student, donor, or customer in making the decision.
2.5 We may collect, use, or disclose personal information without the student’s, donor’s, or customer’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; and
• To investigate an anticipated breach of an agreement or a contravention of law.
3. Using and Disclosing Personal Information
3.1 We will only use or disclose student, donor, or customer 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 contact students or customers about changes to our organization, classes, concerts, or lessons;
• To promote or invite supporters to special events or fundraising efforts;
• To publish donor names in Victoria Conservatory of Music materials and to phone or mail donors to thank them and provide tax receipts;
• To conduct student, donor, or customer surveys in order to enhance the provision of our services;
• To contact students, donors, and customers directly about products and services that may be of interest;
• To provide third party concert or concert series organizers with ticket buyer information of their particular concerts, which they may use for promotional or fundraising purposes for similar future concerts or series; and
• Any photos in Victoria Conservatory of Music promotional materials are used with a ‘photo release’ consent, signed by the parent, student, staff, or individual depicted in the image, excepting large group photos as permitted by law and not considered to be an image of an individual.
3.2 We will not use or disclose student, donor, or customer personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell student, donor, or customer lists or personal information to other parties.
4. Retaining Personal Information
4.1 If we use student, donor, or customer personal information to make a decision that directly affects the student, donor, or customer, we will retain that personal information for at least one year so that the student, donor, or customer has a reasonable opportunity to request access to it.
4.2 Subject to 4.1, we will retain student, donor, or customer personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
5. Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that student, donor, or customer personal information is accurate and complete where it may be used to make a decision about the student, donor, or customer or it is disclosed to another organization.
5.2 Students, donors, and customers 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.
6. Securing Personal Information
6.1 We are committed to ensuring the security of student, donor, or customer personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks.
6.2 The following security measures will be followed to ensure that student, donor, or customer personal information is appropriately protected as follows:
• The use of locked filing cabinets;
• Physically securing offices where personal information is held;
• The use of user IDs, passwords, encryption, firewalls; and
• Restricting employee access to personal information as appropriate.
6.3 We will use appropriate security measures when destroying student, donor, or customer personal information such as shredding documents and deleting electronically stored information.
7. Providing Access to Personal Information
7.1 Students, donors, and customers have a right to access their personal information, subject to limited exceptions as found in section 23 of the PIPA.
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 students, donors, and customers 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 student, donor, or customer of the cost and request further direction from the student, donor, or customer 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 student, donor, or customer in writing, providing the reasons for refusal and the recourse available to the student, donor, or customer.
8. Questions and Complaints: The Role of the Privacy Officer
8.1 The Privacy Officer is responsible for ensuring the Victoria Conservatory of Music’s compliance with this policy and the Personal Information Protection Act.
8.2 Students, donors, and customers should direct any concerns or questions regarding the Victoria Conservatory of Music’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the student, donor, or customer may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for the Victoria Conservatory of Music’s Privacy Officer:
Chief Financial & Operating Officer
Victoria Conservatory of Music
900 Johnson Street
VICTORIA, BC V8V 3N4
Or by email:
Attn: Chief Financial & Operating Officer