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Privacy Policy

Privacy Policy

HOMELESSNESS SERVICES ASSOCIATION OF BC
Personal Information Protection Policy

The Homelessness Services Association of BC is committed to providing our members, non-members, employees, directors and volunteers with exceptional leadership, service and support in our collective efforts to end homelessness.  As providing our services and supports involves the collection, use and disclosure of some personal information about our members, non-members, employees, directors and volunteers, protecting their personal information is one of our highest priorities.

While we have always respected our members, non-members, employees, directors and volunteers’ 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 members, non-members, employees, directors and volunteers 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 members, non-members, employees, directors and volunteers’ personal information.  Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our members, non-members, employees, directors and volunteers’ personal information and allowing our members, non-members, employees, directors and volunteers’ to request access to, and correction of, their personal information.

This Personal Information Protection Policy applies to the Homelessness Services Association.

This policy also applies to any service providers collecting, using or disclosing personal information on behalf of the Homelessness Services Association.

Definitions

Personal Information –means information about an identifiable individual such as name, age, 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 the Homelessness Services Association complies with this policy and PIPA.

Policy 1 – Collecting Personal Information

1.1  Unless the purposes for collecting personal information are obvious and the members, non-members, employees, directors and volunteers 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 members, non-members, employees, directors and volunteers’ information that is necessary to fulfill the following purposes:

  • To verify identity;
  • To open and manage a membership account;
  • To deliver requested products and services such as training
  • To provide training services;
  • To send out HSABC information;
  • To ensure a high standard of service to our members, non-members, employees, directors and volunteers; and,
  • To meet regulatory requirements.

Policy 2 – Consent

2.1  We will obtain members, non-members, employees, directors and volunteers’ 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 orally or in writing electronically  or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the members, non-members, employees, directors and volunteers voluntarily provides personal information for that purpose.

2.3  Consent may also be implied where a member, non-member, employee, director and volunteer 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, fundraising and the member, non-member, employee, director and volunteer 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), members, non-members, employees, directors and volunteers’ can withhold or withdraw their consent for Homelessness Services Association of BC to use their personal information in certain ways.  A member, non-member, employee, director and volunteer’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 member, non-member, employee, director and volunteer’s in making the decision.

2.5  We may collect, use or disclose personal information without the member, non-member, employee, director and volunteer’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);

Policy 3 – Using and Disclosing Personal Information

3.1  We will only use or disclose a member, non-member, employee, director and volunteer’s personal information for a purpose reasonably related to those purposes such as:

  • To conduct surveys with our members, non-members, employees, directors and volunteers in order to enhance the provision of our services;
  • To contact our members, non-members, employees, directors and volunteers directly about products and services that may be of interest;]

3.2  We will not use or disclose member, non-member, employee, director and volunteer’s personal information for any additional purpose unless we obtain consent to do so.

3.3  We will not sell member, non-member, employee, director and volunteer lists or personal information to other parties.

Policy 4 – Retaining Personal Information

4.1  If we use member, non-member, employee, director and volunteer’s personal information to make a decision that directly affects the member, non-member, employee, director and volunteer,  we will retain that personal information for at least one year so that the member, non-member, employee, director and volunteer has a reasonable opportunity to request access to it.

4.2  Subject to policy 4.1, we will retain member, non-member, employee, director and volunteer’s 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 members, non-members, employees, directors and volunteers’ personal information is accurate and complete where it may be used to make a decision about the member, non-member, employee, director and volunteer’s or disclosed to another organization.

5.2  Members, non-members, employees, directors and volunteers 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 member, non-member, employee, director and volunteers’ correction request in the file.

Policy 6 – Securing Personal Information

6.1  We are committed to ensuring the security of members, non-members, employees, directors and volunteers’ 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 members, non-members, employees, directors and volunteers’ personal information is appropriately protected:

  • the use of locked filing cabinets;
  • physically securing offices where personal information is held;
  • the use of user IDs and passwords;
  • restricting employee access to personal information as appropriate (i.e., only those that need to know will have access); and,
  • contractually requiring any service providers to provide comparable security measures.

6.3  We will use appropriate security measures when destroying members, non-members, employees, directors and volunteers’ personal information by 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 Members, Non-members, Employees, Directors and Volunteers’ Access to Personal Information

7.1  Members, non-members, employees, directors and volunteers’ 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.  A request to access personal information should be forwarded to the Executive Director at

7.3  Upon request, we will also tell members, non-members, employees, directors and volunteers 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 member, non-member, employee, director and volunteer of the cost and request further direction from the member, non-member, employee, director and volunteer 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 member, non-member, employee, director and volunteer in writing, providing the reasons for refusal and the recourse available to the member, non-member, employee, director and volunteer.

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

8.1  The Executive Director is responsible for ensuring the Homelessness Services Association of BC’s compliance with this policy and the Personal Information Protection Act.

8.2  Members, non-members, employees, directors and volunteers should direct any complaints, concerns or questions regarding the Homelessness Services Association of BC compliance in writing to the Executive Director. If the Executive Director is unable to resolve the concern, the member, non-member, employee, director and volunteer may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for Homelessness Services Association of BC’s Executive Director:


4445 Norfolk Street, Burnaby BC V5G 0A7
Tel: 778.945-7789
Cell: 604.817.8218