SAD Mag Publishing Society

Personal Information Protection Policy

At SAD Mag Publishing Society, we are committed to providing our contributors and customers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our contributors and customers, protecting their personal information is one of our highest priorities.

We reserve the right to change from time to time the nature of personal information protection policy as well as the contents of this personal information protection policy so as to bring our notice in line with the changes in applicable legal provisions, as amended from time to time, and applicable organizational changes. This is why we would recommend that you check and take note of our personal information protection policy protection notice at regular intervals.

While we have always respected our contributors’ and customers' 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 contributors and customers 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 contributors’ and customers’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our contributors’ and customers’ personal information and allowing our contributors and customers to request access to, and correction of, their personal information.

Scope of this Policy

This Personal Information Protection Policy applies to SAD Mag Publishing Society. This policy also applies to any service providers collecting, using or disclosing personal information on behalf of SAD Mag Publishing Society.

Definitions

Personal Information – means information about an identifiable individual including name, age, home address and phone number, email address, income, employment information, gender, sexual orientation, and race and ethnicity. Personal information does not include contact information (described below).

Contact information – means 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 email or business fax number. Contact information is not covered by this policy or PIPA.

Designated individual – means the person with the responsibility to ensure that SAD Mag Publishing Society complies with this policy and PIPA.

Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the contributors and customers 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 contributors and customers information that is necessary to fulfil the following purposes:

To verify identity and age we may collect name, home address, birth date, telephone number.
To identify customer preferences we may collect we may collect demographic information and preferences provided voluntarily by our customers and contributors.
To deliver requested products and services we may collect email address, name, address, phone number
To process a magazine subscription we may collect email address, name, home address, telephone number
To enrol the contributor and/or customer in a program we may collect name, email address
To contact our customers for fundraising we may collect name, email address and telephone number
To ensure a high standard of service to our customers we may collect demographic information and preferences provided voluntarily by our customers and contributors.

Policy 2 – Consent

2.1 We will obtain contributor and customer 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 orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the customer voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a contributors and customers 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 contributors and customers does not opt-out.

2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), contributors and customers, can withhold or withdraw their consent for SAD Mag Publishing Society to use their personal information in certain ways. A contributor’s and customer’s 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 contributors and customers in making the decision.

2.5 We may collect, use or disclose personal information without the contributor’s and customer’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;
When the collection is necessary to determine the individual's suitability
When the individual is to be selected for an artistic purpose,
When the individual is a recipient of an honour, award or similar benefit, scholarship or bursary,
When SAD Magazine Publishing Society collect information by observation at a performance or art show or a similar event.

at which the individual voluntarily appears, and that is open to the public,

When the collection is required or authorized by law,
SAD Magazine Publishing Society may use personal information collected from or on behalf of another organization without the consent of the individual to whom the information relates, if

When the individual consented to the use of the personal information by the other organization, and the personal information is used by the organization solely
for the purposes for which the information was previously collected, and
to assist that organization to carry out work on behalf of the other organization.

Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose customer personal information where necessary to fulfill the purposes identified at the time of collection and for a purpose reasonably related to those purposes such as:

To conduct contributor and/or customer surveys in order to enhance the provision of our services;
To contact our contributor and/or customers directly about products and services that may be of interest;

3.2 We will not use or disclose contributor and customer personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell contributor and customer lists or personal information to other parties.

Policy 4 – Retaining Personal Information

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

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

5.2 Contributors and customers 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.

A request to correct personal information should be forwarded to the designated individual listed at the end of the document.

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 contributors’ and customers’, correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of contributor and customer 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 contributor and customer personal information is appropriately protected:

The use of user IDs, passwords, and 2-factor authentication;
Restricting staff and volunteer access to personal information as appropriate, only those that need to know will have access;

6.3 We will use appropriate security measures when destroying contributor’s and customer’s personal information such as shredding documents, and 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 Contributors and Customers Access to Personal Information

7.1 Contributors and customers have a right to access their personal information, subject to limited exceptions.

Some examples include: 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. A request to access personal information should be forwarded to the designated individual.

7.3 Upon request, we will also tell contributors and customers 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 fulfil 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 contributors and customers of the cost and request further direction from the contributor and/or customer 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 contributor and/or customer in writing, providing the reasons for refusal and the recourse available to the contributors/customers.

Policy 8 – Questions and Complaints: The Role of the designated individual

8.1 The designated individual is responsible for ensuring SAD Magazine Publishing Society’s compliance with this policy and the Personal Information Protection Act.

8.2 Contributors and Customers should direct any complaints, concerns or questions regarding SAD Magazine Publishing Society’s compliance in writing to the designated individual. If the designated individual is unable to resolve the concern, the contributor and/or customer may also write to the Information and Privacy Commissioner of British Columbia.