1. Protection of Personal Information
Statement of Principles:
The British Columbia Personal Information Protection Act, which came into effect January 1, 2004, sets out the rules for how not-for-profit organisations like the Iyengar Yoga Centre of Victoria may collect, use and disclose personal information. We have developed policy and procedures to ensure that we conform to the legislation and ensure we treat any personal information we are given with respect and care. The IYCV policy is based on the following principles:
· Be accountable for the protection of personal information
· Identify the purposes for collecting personal information
· Obtain consent for the collection and use of personal information
· Limit collection of personal information to only that which is necessary
· Limit the use of personal information to the purpose for which it was collected
· Ensure the accuracy of the personal information collected and used
· Ensure safeguards are in place to protect the personal information in our care
· Provide information about our policies and procedures
· Provide access for individuals to their personal information
· Develop procedures for complaints and provide information about the remedies available
The Iyengar Yoga Centre of Victoria is committed to protecting the privacy and security of personal information held about its students, members, teachers, employees, and volunteers. We value the trust of those with whom we work and endeavour to always be accountable in how we treat the information that is shared with us.
British Columbia Personal Information Protection Act (PIPA), which came into effect January 1, 2004, sets out the rules for how not-for-profit organisations like the Iyengar Yoga Centre of Victoria may collect, use and disclose personal information. The Iyengar Yoga Centre of Victoria will inform you of why and how we collect, use, and disclose and personal information, obtain your consent where required, and only handle your personal information the way a reasonable person would consider appropriate in the circumstances. This policy, in compliance with the Act, outlines the principles and practices we will follow in protecting your personal information. Our commitment to privacy includes ensuring the accuracy, confidentiality, and security of your personal information.
Personal Information – information about an identifiable individual including name, age, home address and phone number, social insurance number, medical information, education, or employment information. Personal information does not include contact information described below.
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, business e-mail or business fax number. Contact information is not covered by the policy or PIPA.
Privacy Officer – the individual or individuals designates responsibility for ensuring The Iyengar Yoga Centre of Victoria complies with this policy and PIPA.
Collecting Personal Information
Unless the purpose for collecting personal information is obvious and you voluntarily provide your personal information for that purpose, we will communicate the purpose for which personal information is being collected, either orally or in writing, before or at the time of collection. We will only collect information that is necessary to fulfil the following purposes: to deliver IYCV programs; to understand the needs of our students, members, teachers, employees, and volunteers; to send out newsletters, and IYCV class, fund raising and event information; to train and evaluate students and teachers; and to enable IYCV to employ or contract staff.
We will obtain your consent to collect, use or disclose personal information (except, where as noted above, consent is not required). Consent can be provided in writing, electronically, or it can be implied where the purpose for collecting, using, or disclosing the personal information would be considered obvious and you provide personal information for that purpose. Consent may also be implied where you are given notice and reasonable opportunity to opt out of your personal information being used, for example, mail-outs, fund raising. Subject to certain exceptions under the legislation, (e.g., where the withdrawal of consent would frustrate the performance of a legal obligation) you can withhold or withdraw your consent for your personal information to be used in certain ways. Your decision to withhold or withdraw consent may restrict our ability to provide a service or program. We will explain the situation to assist you in making such a decision.
We may collect, use, or disclose personal information without your consent in certain limited circumstances permitted under the legislation, for example, 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).
Using and Disclosing Personal Information
We will only use or disclose your personal information where necessary to fulfil the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as: student surveys to enhance our programs; to contact you about programs, special events or news about the Iyengar Yoga Centre of Victoria that may be of interest to you. We will not use or disclose your personal information for any additional purpose unless we obtain consent to do so. We will not sell your personal information to other parties.
Retaining Personal Information
If we use our personal information to make a decision that directly affects you, (for example in the course of a teacher evaluation) we will retain that personal information for at least one year so that you have a reasonable opportunity to request access to it. Subject to that, we will retain personal information only as long as it is necessary to fulfil the identified purposes or a legal or business purpose.
Ensuring Accuracy of Personal Information
We will make reasonable efforts to ensure that your personal information is accurate and complete where it is used to make a decision about you or is disclosed. You may request correction to your 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 information and the correction being sought. Such a request should be forwarded to the Privacy Officer. If the personal information is shown to be inaccurate or incomplete, we will correct the information and ensure that any disclosure of the information in the last year is corrected as well. If the correction is not made, we will note the correction request in the file.
Securing Personal Information
We are committed to ensuring the security of your personal information in order to protect it from unauthorised access, collection, use, disclosure, copying, modification or disposal. The following security measures will be followed to ensure that your personal information is appropriately protected: the use of locked filing cabinets; physically securing offices where personal information is held; the use of user IDs, passwords, restricting access to personal information as appropriate; contractually requiring any service providers to provide comparable security measures. We will review and update our security policies and controls to ensure ongoing personal information security.
Providing Access to Personal Information
You have a right to access your personal information, subject to limited exceptions required by the legislation. Some examples include: solicitor-client privilege, or disclosure that would reveal personal information about another person. A request to access personal information must be made in writing and provide sufficient detail to identify the personal information sought. The request will be provided to the Privacy Officer. Upon request we will also specify the use of the personal information and to whom it has been disclosed, if applicable. We will make the requested information available within 30 business days or provide notice of an extension where additional time is required. A minimal fee may be charged. If so, we will inform you of the cost and seek your direction as to whether to proceed. If a request is refused in full or in part we will provide you with written reasons for the refusal and the recourse available to you.
Questions and Complaints: The Role of the Privacy Officer
The Privacy Officer or designated individual will ensure compliance with this policy and the Personal Information and Protection of Privacy Act. You should direct any complaints, concerns, or questions regarding the Iyengar Yoga Centre of Victoria compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, you may also write to the Information and Privacy Commissioner of British Columbia. The Iyengar Yoga Centre of Victoria’s Privacy Officer is the General Manager.