PFLA Privacy Policy

POLICY: Protection of Personal Information
TYPE: Operational
APPROVAL: Executive Director
DATE APPROVED: April 7, 2009

Intent of the Policy:
To ensure that the personal information about members, non-members, employees, directors and volunteers is protected in compliance with applicable privacy legislation.

Purpose and Scope:
The Private Forest Landowners Association (PFLA) respects and upholds an individual’s right to privacy and to the protection of his or her personal information. The PFLA is committed to ensuring compliance with applicable privacy legislation. This policy applies to individuals who are employed to work at any location with the PFLA, as well as to the Directors, members of PFLA and non-members.

Definitions:
“Personal information” for the purposes of this policy means information about an individual. It does not include aggregate information which cannot be associated with a specific individual and it does not include the name, title, business address, or business telephone number of an individual.

“Employee” for the purposes of this policy is any individual employed to work at any location with the PFLA, and includes persons working in a volunteer capacity.

“Director” for the purposes of this policy is a person elected or appointed as a Director of PFLA.

“Member” for the purposes of this policy is any individual, organization, agency, association, business, or society who has registered and paid membership fees to PFLA.

“Third party” for the purposes of this policy is an individual or an organization other than the PFLA and the member, non-member employee or Director.

Our Responsibilities:

Section 1: Accountability

The PFLA is accountable for the personal employee, member, non-member and Director information under its control. The Privacy Officer is responsible for the organization’s compliance with this policy.

Other individuals within the PFLA may be delegated to act on behalf of the Privacy Officer, or to take responsibility for the day-to-day collection and processing of personal information.

Section 2: Purposes for Collection, Use, and Disclosure

The PFLA collects and uses personal information about employees for the following purposes:

  1. To administer compensation, benefits, and pension programs.
    For example, we collect and use personal information to administer automatic payroll deposits and to provide employee medical benefits. We also collect medical and other information for the purposes of approving leaves of absence.
  2. To comply with legal and regulatory requirements.
    For example, we may collect personal information in response to a court order or to satisfy government reporting requirements.
  3. To otherwise establish and manage the employment relationship and to plan and manage the PFLA’s workload and activities.
    For example, we collect and use personal information to check references, make staffing and employee development decisions, to measure and reward performance, and to assess our ability to meet the organization’s objectives.

The PFLA collects and uses personal information about Directors for the following purposes:

  1. To communicate with Directors.
    For example, we collect Director’s phone numbers and e-mail addresses so that we may contact them regarding Board meeting arrangements.
  2. To comply with legal and regulatory requirements.
    For example, we collect personal information to satisfy reporting requirements for The Societies Act.

The PFLA collects and uses personal information about Members for the following purposes:

  1. To communicate with them on membership matters.
    For example, providing information about programs and services available to them, inviting them to housing related events, invoicing, and sharing news of interest to the sector.
  2. To enable members to communicate with each other

The PFLA collects and uses personal information about Non-Members for the following purposes:

  1. To receive payment for products and services.
    The only circumstances under which personal information may be disclosed to third parties is for the fulfillment of any purposes identified above, as required by law, or with consent. Where personal information is disclosed to a third party for the fulfillment of any purposes identified above, the PFLA will make all reasonable efforts to ensure that the third party has appropriate security procedures in place for the protection of the personal information transferred to it.

Section 3: Consent

The acceptance of employment and benefits by an employee is viewed as consent for the PFLA to collect, use, and disclose personal information about an employee for the purposes identified above. The PFLA views the purposes identified in this policy as reasonable and necessary to manage the organization and the employment relationship.

An employee may choose, however, to withhold or withdraw consent for the collection, use, and disclosure of personal information, subject to legal and contractual restrictions and reasonable notice, where the provision of this information is optional, such as in the case of consent for the use of a photograph for newsletters, other publications or the PFLA Website.

The acceptance of an appointment as a Director is viewed as consent for the PFLA to collect, use, and disclose personal information for the purposes identified above.

A Director may choose, however, to withhold or withdraw consent for the collection, use, and disclosure of personal information, subject to legal and contractual restrictions and reasonable notice, where the provision of this information is optional, such as in the case of consent for the use of a photograph for newsletters, other publications or the PFLA Website.

The application for membership with PFLA is viewed as consent for the PFLA to collect, use, and disclose personal information for the purposes identified above. A member may choose however, to withhold or withdraw consent for the collection, use, and disclosure of personal information, subject to legal and contractual restrictions and reasonable notice, where the provision of this information is optional, such as in the case of consent for the use of a photograph for newsletters, other publications or the PFLA Website.

Section 4: Limiting Collection

We collect personal information only for the purposes identified above.

Section 5: Limiting Use, Disclosure, and Retention

We do not use or disclose personal information for any purpose other than those for which it was collected, except as required by law, or with consent.

Personal information is retained only as long as is necessary for the fulfillment of the purposes for which it was collected, or as required by law.

Section 6: Accuracy

The PFLA will make all reasonable efforts to ensure that personal information is as accurate, complete, and current as required for the purposes for which it was collected. In some cases, the PFLA relies on employees, members, non-members, and Directors to ensure that certain information about them, such as their home address and phone number, or emergency contact information, is current, complete, and accurate.

Section 7: Safeguards

The PFLA will make all reasonable efforts to ensure that personal information is protected against such risks as loss, theft, unauthorized access, disclosure, copying, use, modification, or destruction. Safeguards include physical, administrative, and electronic security measures.

If personal information is disclosed to a third party, the PFLA will make all reasonable efforts to ensure that the third party has appropriate security procedures in place for the protection of the personal information transferred to it.

Section 8: Openness Concerning Policies and Practices

The PFLA will make available specific information about its policies and practices regarding the management of personal information.

To contact us to obtain further information regarding our policies and practices, please refer to Section 11 below.

Section 9: Access

All employees, members, non-members and Directors have the right to access their personal information under the control of the PFLA.

The Privacy Officer will assist employees, members, and Directors with their access requests. Access requests should be submitted in writing to the Executive Director. In certain exceptional situations, further to privacy legislation, the PFLA may not be able to provide access to certain personal information that it holds about an employee, member, or a Director. Examples of where the PFLA may not provide access include, but are not limited to, the following:

  • Where provision may reveal personal information about another individual;
  • Where the information is subject to solicitor-client privilege; or
  • Where the information was collected in relation to the investigation of a breach of an agreement or a contravention of a federal or provincial law.

If access cannot be provided, the PFLA will notify the individual making the request, in writing, of the reasons for the refusal.
Where access has been provided and where the information is demonstrated to be inaccurate or incomplete, the PFLA will amend the information as required. Where appropriate, the PFLA will transmit the amended information to third parties having access to the information in question.

Section 10: Revisions To This Privacy Policy

The development of the PFLA’s policies and procedures for the protection of personal information is an ongoing process. Due to changes in technology and legal requirements we may revise this policy from time to time. Please ensure that you refer to the current version of the PFLA’s Protection of Personal Information Policy. The current version will be found in the PFLA Policy Manual and on the PFLA website.

Section 11: Concerns or Questions Regarding The PFLA’s Compliance

Employees, members, non-members, and Directors may direct their general questions regarding privacy at the PFLA, as well as any questions or concerns regarding the PFLA’s compliance with this policy, to the Privacy Officer at:

info@pfla.bc.ca or 250-381-7565, ext. 21

The PFLA will investigate all complaints received in writing. If a complaint is found to be justified, the PFLA will take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. An individual will be informed, in writing, of the outcomes of the investigation regarding his or her complaint.

For general questions regarding privacy regulations or for a copy of the Personal Information Protection Act contact the Office of the Information and Privacy Commissioner of British Columbia at PO Box 9038, Stn. Prov. Govt., Victoria, B.C. V8W 9A4, or online at www.oipcbc.org.