Privacy Policy



Privacy Policy

Personal Information Protection Policy (Summary)

At Camp Homewood, we are committed to providing our campers, guests, volunteers, supporters and employees with exceptional service. As providing this service involves the collection, use and appropriate disclosure of some personal information about our campers, guests, volunteers, supporters and employees, protecting their personal information is one of our highest priorities.

Homewood has approved and implemented personal information policy in compliance with British Columbia's Personal Information Protection Act, which specifies the principles and practices we will follow in protecting campers', guests', volunteers' and employees' personal information. This policy can be viewed on our web site at: www.homewood.bc.ca. Our Camp Director is responsible for administering our Personal Information Protection Policy and for responding to questions, requests and complaints under the policy.

We will inform our campers, guests, volunteers, supporters and employees 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. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of personal information and allowing our campers, guests, volunteers, supporters and employees to request access to, and correction of, their personal information.

Personal Information Protection Policy (Full Policy)

At Camp Homewood, we are committed to providing our campers, guests, volunteers, supporters and employees with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our campers, guests, volunteers, supporters and employees, protecting their personal information is one of our highest priorities.

While we have always respected the privacy of our campers, guests, volunteers, supporters and employees 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 requirements for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our campers, guests, volunteers, supporters and employees 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 campers', guests', volunteers' and employees' personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our campers', guests', volunteers' and employees' personal information and allowing our campers, guests, volunteers, supporters and employees to request access to, and correction of, their personal information.

Scope of this Policy

This Personal Information Protection Policy applies to Camp Homewood and Pacific Coast Children's Mission, the not-for-profit Society that operates Camp Homewood. This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Camp Homewood.

Definitions

Personal Information - means information about an identifiable individual [e.g., including name, age, home address and phone number, social insurance number, marital status, religion, income, credit history, medical information, education, 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 Camp Homewood complies with this policy and PIPA.

Policy 1 - Collecting Personal Information

1.1
Unless the purposes for collecting personal information are obvious and the camper, guest, volunteer, employee or supporter 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 camper, guest, volunteer, employee or supporter information that is necessary to fulfill the following purposes:

  • To enrol campers and guests for Camp Homewood programs or services;
  • To ensure a high standard of service to our campers, guests, volunteers, supporters and employees;
  • To identify camper, guest, volunteer, supporter or employee preferences and to understand their needs;
  • To assess the suitability of potential volunteers or employees;
  • To provide emergency medical services;
  • To contact our supporters for fundraising;
  • To send newsletters, notices and information to our campers, guests, volunteers or supporters;
  • To provide camp follow-up;
  • To administer benefit programs for Camp Homewood volunteers and employees;
  • To verify identity;
  • To verify creditworthiness;
  • To open and manage an account;
  • To deliver requested products and services
  • To guarantee a reservation;
  • To meet regulatory requirements;>
  • To assess suitability for tenancy;
  • To collect and process rent payments;

Policy 2 - Consent

2.1
We will obtain camper, guest, volunteer, employee or supporter 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, 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 camper, guest, volunteer, employee or supporter voluntarily provides personal information for that purpose.

2.3
Consent may also be implied where a camper, guest, volunteer, employee or supporter 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 camper, guest, volunteer, employee or supporter 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), campers, guests, volunteers, supporters and employees can withhold or withdraw their consent for Camp Homewood to use their personal information in certain ways. A camper's, guest's, volunteer's, employee's or supporter'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 camper, guest, volunteer, employee or supporter in making the decision.

2.5
We may collect, use or disclose personal information without the camper's, guest's, volunteer's, employee's or supporter's knowledge or consent in the following limited circumstances:

  • When the collection, use or disclosure of personal information is permitted or required by law;
  • When a reasonable person would consider that it is clearly in the interests of the individual and consent cannot be obtained in a timely way;
  • If the information is used to decide whether an individual is suitable for an honour, award or other similar benefit;>
  • 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 camper, guest, volunteer, supporter or employee personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes.

3.2
We will not use or disclose camper, guest, volunteer, supporter or employee personal information for any additional purpose unless we obtain consent to do so or unless otherwise authorized or required by law.

3.3
We will not sell camper, guest, volunteer, supporter or employee lists or personal information to other parties.

Policy 4 - Retaining Personal Information

4.1
If we use camper, guest, volunteer, supporter or employee personal information to make a decision that directly affects the camper, guest, volunteer, supporter or employee, we will retain that personal information for at least one year so that the camper, guest, volunteer, supporter or employee has a reasonable opportunity to request access to it.

4.2
Subject to policy 4.1, we will retain camper, guest, volunteer, supporter or employee 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 camper, guest, volunteer, supporter or employee personal information is accurate and complete where it may be used to make a decision about the camper, guest, volunteer, supporter or employee or disclosed to another organization.

5.2
Campers, guests, volunteers, supporters and employees may request correction to their personal information in order to ensure its accuracy and completeness. A request to access or correct personal information must be made in writing to the Privacy Officer and provide sufficient detail to identify the personal information and/or 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 camper's, guest's, volunteer's, supporter's or employee's correction request in the file.

Policy 6 - Securing Personal Information

6.1
We are committed to ensuring the security of camper, guest, volunteer, supporter and employee personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2
The security measures specified in the Homewood Staff Manual will be followed to ensure that camper, guest, volunteer, supporter and employee personal information is appropriately protected.

6.3
We will use appropriate security measures when destroying camper, guest, volunteer, supporter and employee personal 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 Campers, guests, volunteers, supporters and employees Access to Their Personal Information

7.1
Campers, guests, volunteers, supporters and employees have a right to access their personal information, subject to limited exceptions found in section 23 of PIPA. Some examples of these exceptions include: solicitor-client privilege, disclosure would reveal personal information about another individual, health and safety concerns.

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 Privacy Officer.

7.3
Upon request, we will also tell campers, guests, volunteers, supporters and employees 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 camper, guest, volunteer, supporter or employee of the cost and request further direction from the camper, guest, volunteer, supporter or employee 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 camper, guest, volunteer, supporter or employee in writing, providing the reasons for refusal and the recourse available to the camper, guest, volunteer, employee or supporter.

Policy 8 - Questions and Complaints: The Role of the Privacy Officer

8.1
The Privacy Officer is responsible for ensuring Camp Homewood's compliance with this policy and the Personal Information Protection Act.

8.2
Campers, guests, volunteers, supporters and employees should direct any complaints, concerns or questions regarding Camp Homewood's compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the camper, guest, volunteer, employee or supporter may also write to the Information and Privacy Commissioner of British Columbia. Contact information for Camp Homewood's Privacy Officer:

Irwin Harder, General Director

Policy Approved: June 26, 2004

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