Privacy Policy

Spinal Cord Injury BC Privacy Policy Approved – Management Group – January, 2008

Spinal Cord Injury BC Privacy Policy

Guiding Principles

Spinal Cord Injury BC (SCI BC) values and upholds the right to privacy and the protection of personal information of our clients, employees, volunteers, donors/contributors, members and all stakeholders. Our commitment is to be transparent and accountable in the use of any personal information you provide to us.

In fulfilling our mission “to assist people with spinal cord injuries and other physical disabilities to achieve independence, self-reliance and full community participation” from time to time we may collect and use personal information (as defined in this policy). BCPA is compliant with the Personal Information Protection Act of BC (PIPA).

The purpose of PIPA is to “Govern the collection, use and disclosure of personal information by organizations in a manner that recognizes both the right of individuals to protect their personal information and the need of organizations to collect, use or disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances.”

SCI BC collects and maintains personal information on five major groups of people: people we serve (clients), their families and related third parties; employees; volunteers; members and donors/contributors.

Personal Information

Personal information is information about an identifiable individual such as someone’s name, home address, home phone number, personal email address, social insurance number, gender, income or family status. It also includes donation information, health information, financial information and employment and volunteer history.

Employee personal information is information that is collected, used or disclosed for the purposes of establishing, maintaining or managing a relationship between an employee (including a volunteer) and the BC Paraplegic Association. Information that allows an individual to be identified at work is not personal information. Work product information that is prepared or collected by an employee as a part of their work responsibilities is not considered the personal information of that individual. All employees must read and sign a copy of the SCI BC privacy policy upon hire.

Purpose of Collection and Use of Personal Information

SCI BC only collects and uses personal information for purposes necessary to fulfill our mission and in order to comply with any legal requirements. These specific purposes include: 

• To share information about the Association with members, volunteers, clients, donors and those who may be interested in our activities
• To track and issue tax receipts for donations received in accordance with Canada Revenue Agency requirements
• To establish, build and maintain relationships
• To process financial transactions (including donations and membership fees)
• To determine the eligibility of an individual to receive a grant scholarship or bursary and/or to issue grants, scholarships or bursaries
• To administer programs offered by the Association
• To conduct research
• BCPA Privacy Policy Approved – Management Group – January, 2008 2
• To use photographs, film or other media taken at events in future SCI BC publications and on our website
• To establish, maintain and manage employment relationships between the SCI BC and an employee/volunteer
• To share other peoples’ stories in relation to the SCI BC, SCI and other physical disabilities
• To improve our ability to provide services in accordance with our mission

SCI BC discloses personal information only for purposes necessary to fulfill our mission and in order to comply with legal requirements. This includes the following purposes:

• To assist an individual in receiving a grant, scholarship, bursary or service in accordance with our mission
• To use photographs, film or other media in future SCI BC publications including magazines, newsletters or on our website
• To establish, maintain and manage employment relationships between SCI BC and an employee/volunteer
• To share other peoples stories in relation to SCI BC, SCI and other physical disabilities
• To give donor/contributor recognition where permission to do so has been granted by the donor/contributor
• To solicit new support through exchanging donor information with like-minded organizations
• To use third party service providers to process personal information on our behalf or to assist us with various other services such as research and mail distribution (refer to Limits on Collection, Use and Disclosure section for more detail).

In order to achieve the above-stated purposes, SCI BC collects the following types of information:

• Contact information including name, address, phone number and email
• Demographic and biographical information
• Financial information required to process donations and membership fees and to establish eligibility for grants, scholarships and bursaries
• Employment history and other human resource information, including current and previous assessments, observations and opinions – both formal and informal
• Health information including spinal cord injury and other physical disability information
• Photographs, film or other media and personal stories (which are voluntarily provided) to use in future publications including: magazines, newsletters and on our website.

Limits on Collection, Use and Disclosure

SCI BC will only collect, use and disclose personal information for the purposes stated above and in compliance with the Personal Information Protection Act. Should we require your personal information for any purposes other than those for which it was originally obtained, we will first ask for your permission.

In the case of employee home contact information, no employee is authorized to share this information with anyone outside of SCI BC unless authorized by that employee. In the case of emergency contact information, it is only to be used in the case of an emergency. SCI BC Privacy Policy Approved – Management Group – January, 2008 3

Disclosure of Personal Information

Personal information will be disclosed to other organizations when service providers are contracted on our behalf to process your information or assist us with various other services such as mail distribution and research, if it is to help an individual in receiving a grant, scholarship, bursary or service in accordance with our mission, or if we are required to do so by law. Donor information may be exchanged with other like-minded organizations in order to solicit new support. In this case, an opportunity to opt out is provided (see Consent by Not Declining Consent below).

In the case where another organization is contracted to process your information or assist us with other services, legally binding confidentiality agreements exist that commit those organizations to strictly adhere to SCI BC’s privacy policy. Other than with donor information as noted above, SCI BC will not rent, sell, lease or barter your information to any organization or individuals.

Obtaining Consent to Collect, Use and Disclose Personal Information

When SCI BC does find it necessary to collect, use and/or disclose personal information, consent to do so will be obtained either through express (informed) consent, deemed consent or by giving an individual opportunity to decline consent.

• Express Consent signifies that an individual, knowing what personal information is being collected and for what purposes, willingly agrees to the information being collected, used and disclosed as notified.
• Deemed Consent is when an individual provides information for a purpose that, at the time, would be considered obvious to a reasonable person.
• Consent by Not Declining Consent is when an individual has been given a reasonable opportunity to decline consent when they have been given an easy to understand notice of why their information is being collected, used or disclosed prior to the time of collection.

SCI BC will make every effort to notify an individual of the purpose for collection, use or disclosure of personal information and give a reasonable chance to refuse consent and/or to withdraw consent at a later date.

In the case of photographs, film or other media taken by SCI BC at private events, signs will be placed at the entrances and other visually accessible places to notify people that this will be taking place, what the photographs and film will be used for, and that give the contact information for the privacy officer should that person wish to not have their photo used or disclosed.

An individual may withdraw their consent at any time after collection by giving a reasonable amount of notice to BCPA. The only exception is when it would interfere with the performance of a legal proceeding as required under Part 6 Section 18(1)(i) and (j) of the Personal Information Protection Act of BC. The consequence of withdrawing consent may be that BCPA cannot provide a service that requires the use of certain personal information.

PIPA allows SCI BC to use or disclose certain types of employee personal information without consent if it is reasonable for the purposes of establishing, managing or terminating an employment relationship with an individual. Under applicable legislation, employees have the right to make access requests to any and all of their personal information under SCI BC control. Employees will be notified of the collection, use and disclosure of their personal information. SCI BC Privacy Policy Approved – Management Group – January, 2008 4

Access & Accuracy of Information

SCI BC strives to ensure that any personal information in its custody is accurate and up to date. You have the right to access your personal information and request correction where you believe it is inaccurate. In most instances we reply on individuals to notify us if their personal information changes.

Security and Protection of Personal Information

BCPA has appropriate security measures to protect the privacy of personal information that is collected, depending on its sensitivity and how it is stored. These include:

a) Implementing administrative procedures;

b) Ensuring physical safeguards,

c) Managing technical security services and mechanisms.

All BCPA employees sign a confidentiality agreement.

Retention of Personal Information

The retention of personal information differs with each major group of people we collect information from. Once the appropriate time period has been surpassed, paper files are shredded and electronic files are deleted.

Communication-Privacy Officer

Your privacy is important to us. To oversee compliance with this policy and to address privacy issues or concerns, SCI BC has designated Maureen Brownlee as the Privacy Officer. You may contact the Privacy Officer at:

Spinal Cord Injury BC
780 SW Marine Drive
Vancouver, BC V6P 5Y7

Phone: 604-326-1225 Fax: 604-326-1227
Email: privacy@sci-bc.ca