Personal Information Protection

Private Sector Privacy Legislation

Personal Information Protection Policy

Respond & Rebuild Consulting and Coaching Service

Personal Information Protection Policy

At Respond & Rebuild, we are committed to providing our clients with exceptional service.  As providing this service involves the collection, use and disclosure of some personal information about our clients protecting their personal information is one of our highest priorities.

 While we have always respected our client’s privacy 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 ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our clients 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 clients’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients ‘personal information and allowing our clients to request access to, and correction of, their personal information.

This Personal Information Protection Policy applies to Respond & Rebuild.

This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Respond & Rebuild.

 Definitions of Personal Information & Contact Information

 Personal Information -A Client’s’ personal information is only collected on behalf of Respond & Rebuild and is not shared nor sold to any third party/vendors. The following personal information collected is for coaching and/or consulting services only including name, age, home address and phone number, marital status, income, education, employment information/for individual coaching services and consulting services for the business’s statistic and/or surveys. Personal information does not include contact information.

Contact information – Respond & Rebuild will only gather information for professional services only. This enables Respond & Rebuild to collect and use information of the business’s individual contact, business department or owner, the location of business and which includes name, position name or title, business telephone number, business address, business email.  Contact information is not covered by this policy or PIPA.
Privacy Officer – Shannon Formo is the designated privacy officer and responsible for ensuring that Respond & Rebuild complies with this policy and PIPA.

 Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the client or business 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 client information that is necessary to fulfill the following purposes:

Respond & Rebuild will only collect personal information for purposes providing individual or group coaching service and/or professional training and consulting services. The following information will be collected for professional business purposed only.

 · To identify client or business’s preferences;

· To understand the financial, banking, insurance needs of our clients and businesses;

· To open and manage an account;

· To deliver requested services;

· To provide Coaching or Consulting services;

· To enrol the client in a coaching program;

· To ensure a high standard of service to our clients and businesses;

· To meet regulatory requirements;

· To collect and process payments

 Policy 2 – Consent

2.1 We will obtain client and business 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 to Respond & Rebuild through methods of written types of email, letter or text or through authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client and business voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a client or business 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 client or business does not opt-out.

2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or the withdrawal of consent would frustrate the performance of a legal obligation), The client or business can withhold or withdraw their consent for Respond & Rebuild to use their personal information in certain ways. A client’s or businesses 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 client or business in making the decision.

2.5 We may collect, use or disclose personal information without the client’s or business’s knowledge or consent in the following limited circumstances:

 · When the collection, use or disclosure of personal information is permitted or required by law;

· 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 client or business personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:

· To conduct client, customer, member surveys in order to enhance the provision of our services;

·  To contact our[clients, customers, members] directly about products and services that may be of interest;]

3.2 We will not use or disclose client or business’s personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell client or business lists or personal information to other partie [unless we have consent to do so].

Policy 4 – Retaining Personal Information

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

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

5.2 Clients or business may request correction to their 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 personal information and 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 client’s or business’s correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of client or business personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2 The following security measures will be followed to ensure that client and business personal information is appropriately protected:

Respond & Rebuild will adhere to the following practices in the way of Security measures as and including: the use of locked filing cabinets; physically securing offices where personal information is held; the use of user IDs, passwords, encryption, firewalls; restricting business access to only the business owner and operator for personal information as appropriate (i.e., only those that need to know will have access; contractually requiring any service providers to provide comparable security measures].

6.3 We will use appropriate security measures when destroying client’s, customer’s and business personal information such as and include shredding documents, deleting electronically stored 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 Clients and Businesses Access to Personal Information

 7.1 Clients or Businesses have a right to access their personal information, subject to limited exceptions.  i) 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. [IF APPLICABLE: A request to access personal information should be forwarded to the Privacy Officer or Owner, Shannon Formo

7.3 Upon request, we will also tell clients or businesses 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 client or business of the cost and request further direction from the client or business 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 client or business in writing, providing the reasons for refusal and the recourse available to the client or business.

 Policy 8 – Questions and Complaints:  The Role of the Privacy Officer or Business Owner

8.1 The Privacy Officer or Business Owner is responsible for ensuring Respond & Rebuild compliance with this policy and the Personal Information Protection Act.

8.2 Clients or Businesses should direct any complaints, concerns or questions regarding Respond & Rebuild compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client or business may also write to the Information and Privacy Commissioner of British Columbia.

 Contact information for Respond & Rebuild Privacy Officer or business owner, S. Formo.

shannon@respondandrebuild.com