At Gibraltar Holdings Ltd., 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 clients 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.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal
information are obvious and the client 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:
To verify identity;
To verify creditworthiness;
To deliver requested products and services
To ensure a high standard of service to our clients;
Policy 2 – Consent
2.1 We will obtain client 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 or 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 client voluntarily
provides personal information for that purpose.
2.3 Consent may also be implied where a client 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 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), clients can withhold or withdraw their consent for Gibraltar
Holdings Ltd. to use their personal information in certain ways. A
client’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
client in making the decision.
2.5 We may collect, use or disclose personal
information without the client’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 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 directly about products and services that may be
of interest;
3.2 We will not use or disclose client personal
information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client lists or personal
information to other parties unless we have consent to do so.
Policy 4 – Retaining Personal Information
4.1 If we use client personal information to make a
decision that directly affects the client we will retain that personal
information for at least one year so that the client has a reasonable
opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client
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 personal information is accurate and complete where it may be used
to make a decision about the client or disclosed to another organization.
5.2 Clients 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 clients’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client
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 personal information is appropriately protected:
Offices with personal information will be secured.
6.3 We will use appropriate security measures when
destroying client’s personal information such as shredding documents and
deleting electronic files.
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 Access to Personal
Information
7.1 Clients have a right to access their personal
information, subject to limited exceptions.
[A full listing of the exceptions to access can be
found in section 23 of PIPA. 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.
7.3 Upon request, we will also tell clients 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
of the cost and request further direction from the client 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 in writing, providing the reasons for refusal and the
recourse available to the client.
Policy 8 – Questions and Complaints: The Role of the
Privacy Officer or designated individual
8.1 The Privacy Officer is responsible for ensuring
Gibraltar Holdings Ltd. compliance with this policy and the Personal
Information Protection Act.
