Purpose
The Whistler Writing Society (the Society) is committed to protecting the privacy and security of personal information entrusted to it by its members, volunteers, staff, donors, attendees, contractors and others who interact with the Society.
This policy outlines how the Society collects, uses, discloses, stores, retains and safeguards personal information in compliance with British Columbia’s Personal Information Protection Act (PIPA) and Canada’s Anti-Spam Legislation (CASL).
Scope
This policy applies to all personal information collected, used or retained by the Society in carrying out its activities.
Personal information may be collected from:
• staff and contractors;
• volunteers;
• members;
• donors;
• event attendees;
• individuals who have expressed an interest in the Society.
Information may be collected by telephone, mail, email, online forms, social media, ticketing agencies or in person.
Definitions
Personal Information
Personal information is information about an identifiable individual, including but not limited to name, address, email, telephone number, date of birth, gender, language preference and membership information. It does not include publicly available business contact information used in an individual’s professional capacity.
Policy Statement
The Society is committed to collecting only the personal information necessary to fulfill its mandate and administer its programs and services.
Personal information will be collected, used, disclosed, retained and protected responsibly, transparently and only for purposes that individuals would reasonably expect.
The Society will not sell, rent or otherwise distribute personal information.
Roles & Responsibilities
Board of Directors
• approves this policy and provides governance oversight.
Privacy Officer
• the Artistic and Executive Director (AED) serves as Privacy Officer and oversees compliance, responds to privacy inquiries and access requests, and coordinates privacy training.
Staff and Volunteers
• protect the confidentiality of personal information;
• use information only for authorized purposes;
• follow this policy and related procedures.
Procedures
Collection
• collect only information necessary to operate Society programs.
Use
• administer memberships, donations, events, tax receipts, communications, audit and HR requirements.
Disclosure
• disclose information only for the purpose collected, related purposes, where required by law or with consent.
Retention
• retain information only as long as necessary in accordance with PIPA.
Storage and Security
• restrict access to authorized personnel and maintain appropriate safeguards.
Online Privacy
• use anonymous website analytics including Google Analytics.
Third-Party Service Providers
The Society may use third-party service providers to support its operations. Personal information will be shared with service providers only as reasonably necessary for the services being provided, and the Society will take reasonable steps to select providers that maintain appropriate privacy and security safeguards.
Privacy Breaches
The Society will respond promptly to any actual or suspected loss, unauthorized access, use or disclosure of personal information. Privacy breaches will be reported immediately to the Privacy Officer, who will coordinate the Society’s response in accordance with its privacy procedures.
The Society will take reasonable steps to:
- contain and investigate the breach;
- assess the nature and potential risk of harm;
- notify affected individuals and the Office of the Information and Privacy Commissioner for British Columbia, where appropriate; and
- take corrective action to reduce the risk of a similar breach occurring again.
All privacy breaches and the Society’s response will be appropriately documented.
Confidentiality / Compliance
Individuals may request access to or correction of their personal information through the Privacy Officer. The Society will provide privacy training to staff, Board members and volunteers and will make this policy publicly available.
Photography and Recording
The Society may take photographs or video recordings at its events for communications, archival and promotional purposes. Where appropriate, attendees will be informed that photography or recording is taking place and consent will be obtained where required.
Revision History
This policy will be reviewed every 5 years or sooner if legislation or Society operations require revision.