The Midwives Association of British Columbia (MABC) is committed to fulfilling the mandate of the MABC Bylaws and to protecting the privacy of the personal information of our members, subject matter experts and all users of its services. As providing this service involves the collection, use and disclosure of members’ personal information, protecting personal information is a high priority.
The MABC respects the members’ privacy and safeguards their personal information. The MABC is committed to high standards of confidentiality and we comply with British Columbia’s Personal Information Protection Act (PIPA), with the federal legislation, Personal Information Protection and Electronic Documents Act (PIPEDA), and with other applicable statutes.
The MABC will inform members 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, as informed by PIPA and PIPEDA, outlines the principles and practices the MABC will follow in protecting members’ personal information. The MABC’s privacy commitment includes ensuring the accuracy, confidentiality, and security of its members’ personal information and allowing our members to request access to, and correction of, their personal information.
1.1. Personal Information – means any information about an “identifiable individual” that can be used to distinguish, identify or contact a specific individual, including name, age, home address and phone number, social insurance number, marital status, income, medical information, education, employment information.
1.2. Business contact information means information on business cards and certain publicly available information, such as names, addresses and telephone numbers as published in telephone directories that are not considered personal information under federal legislation (PIPEDA). Information about corporations is not considered personal information.
1.3. Privacy Officer – means the individual designated responsible for ensuring that the MABC complies with this policy, PIPA and PIPEDA.
2.1. Unless the purposes for collecting personal information are obvious and the member 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.
2.2. We will only collect member information that is necessary to fulfill the following purposes:
2.2.1. To verify identity;
2.2.2. To meet regulatory requirements;
2.2.3. To collect and process payments;
2.2.4. To identify member preferences and to understand the needs of our members;
2.2.5. To deliver requested products and services;
2.2.6. To process a journal subscription;
2.2.7. To enrol a member in a program;
2.2.8. To send out Association membership information.
2.2.9. To contact our members for fundraising
2.3. We collect no personal information about you unless you choose to provide that information to us and we do not use techniques that collect personal information about anyone without their knowledge.
2.4. You may provide us with your credit card information in order to make a purchase. We collect this information only to set up your account, process the order, and provide you with services. The MABC does not store credit card information for later use. MABC’s online payment service, Moneris collects and retains information about your transaction history when you use the MABC services and program.
3.1. A visitor to the MABC website is not required to reveal any individually identifiable information, nor is such information collected passively by electronic means. Personal information is only collected when an individual voluntarily submits his or her information such as in an online membership application form, meeting registration form or an online survey. The personal information collected in this manner is subject in full to this policy. If you do nothing during your visit but browse through the website, read pages, or download information, we will neither gather nor store any personal information about you. Our web server collects statistical data about visitor information used only in aggregate. This tracking system does not record personal information about individuals or link this information to any personal data collected.
4.1. The MABC will obtain member consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
4.2. 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 member voluntarily provides personal information for that purpose.
4.3. Consent may also be implied where a member 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, or fundraising, and the member does not opt-out.
4.4. 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), members can withhold or withdraw their consent for the MABC to use their personal information in certain ways. A member’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 member in making the decision.
4.5. We may collect, use or disclose personal information without the member’s knowledge or consent in the following limited circumstances:
4.5.1. When the collection, use or disclosure of personal information is permitted or required by law;
4.5.2. In an emergency that threatens an individual's life, health, or personal security;
4.5.3. When the personal information is available from a public source (e.g., a telephone directory);
4.5.4. When we require legal advice from a lawyer;
4.5.5. For the purposes of collecting a debt;
4.5.6. To protect ourselves from fraud;
4.5.7. To investigate an anticipated breach of an agreement or a contravention of law.
5.1. The MABC will only use or disclose member 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:
5.1.1. To conduct member surveys in order to enhance the provision of our services;
5.1.2. To contact our members directly about products and services that may be of interest;
5.1.3. To confirm sign-up or registration, receipts, invoices, reminders of events you registered for, membership renewal reminders or notifications regarding website activity that pertains to your account;
5.2. We will not use or disclose member personal information for any additional purpose unless we obtain consent to do so.
5.3. We will not sell member lists or personal information to other parties unless we have consent to do so.
5.4. The MABC uses email to communicate with its members. You may receive personally-targeted emails from us for the following reasons: confirmations of sign-up or registration, receipts, invoices, reminders of events you registered for, membership renewal reminders, or notifications regarding website activity that pertain to your account.
5.5 Members will receive regular e-mail digests from the MABC regarding important and relevant information. These e-mails may take the form of announcements, newsletters, or program updates. Members can control whether or not they receive these digests through a setting in their profiles. These group emails conform to Canada’s Anti-Spam (CASL) Regulations, so you will only receive these if you are a member of MABC and have not opted out (unsubscribed) from such notices.
6.1. If the MABC uses member personal information to make a decision that directly affects the member, we will retain that personal information for at least one year so that the member has a reasonable opportunity to request access to it.
6.2. Subject to policy 6.1, we will retain member personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
7.1. We will make reasonable efforts to ensure that member personal information is accurate and complete where it may be used to make a decision about the member or disclosed to another organization.
7.2. Each MABC member is responsible for maintaining accurate and updated information in their MABC online profile by accessing their MABC account, located in the member’s section of the MABC website.
8.1. We are committed to ensuring the security of member personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks. We endeavor to maintain appropriate safeguards and adequate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any unauthorized access.
8.2. The following security measures will be followed to ensure that member personal information is appropriately protected: The use of locked filing cabinets; the use of user IDs, passwords, firewalls; restricting employee access to 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); and the use of technological measures by way of secure access and encryption.
8.3 MABC Board of Directors is authorized to access personal information based only on their need to deal with the information for the reason(s) it was obtained.
8.4. We will use appropriate security measures when destroying member’s personal information such as shredding documents, and deleting electronically stored information.
8.5. We will take measures to ensure the integrity of this information is maintained and to prevent its being lost or destroyed.
8.6. We will ensure the integrity and privacy of your credit card information and that online payments to the MABC are in compliance with Payment Card Industry Standards (PCI DSS). The payment transaction is managed by MABC’s online payment service, Moneris. MABC does not see or retain any data pertaining to your credit cards or other methods of electronic payment. The only information we collect about the payment transaction is whether or not it was successful.
9.1. Members have a right to access their personal information, subject to limited exceptions including solicitor-client privilege, if disclosure would reveal personal information about another individual, and/or if there are health and safety concerns.
9.2. 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 MABC Staff and the MABC Board.
9.3. Upon request, we will also tell members how we use their personal information and to whom it has been disclosed if applicable.
9.4. 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.
9.5. A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the member of the cost and request further direction from the member on whether or not we should proceed with the request.
9.6. If a request is refused in full or in part, we will notify the member in writing, providing the reasons for refusal and the recourse available to the member.
10.1. The MABC may share aggregate information about its members with stakeholders to help them better understand MABC members and their interests.
10.2. Such aggregate information is used to give MABC demographic data about its members in order to improve the organization and the programs and services we provide. Aggregate information does not include individual data.
11.1. When personal information is sent across provincial boundaries, the MABC understands that its responsibility is to comply with the Federal Privacy Protection Act as well as the BC Personal Information Protection Act. The Principles included in this Policy relating to collection, consent, use and disclosure, retention, accuracy, security, access and complaints also apply to information shared across provincial boundaries. Any organization outside the province will be required to sign a privacy agreement with the MABC.
12.1. Individuals involved in a work-related relationship with MABC are considered employees in this Section (this includes full and part-time salaried employees, independent contractors, and volunteers). The Principles included in this Policy relating to collection, consent, use and disclosure, retention, accuracy, security, access and complaints also apply to information collected for pre-employment (pre-work) and employment (work) purposes.
13.1. The MABC may disclose, without the consent of the individual, personal information for a research purpose only if:
13.1.1. The research purpose cannot be accomplished unless the personal information is provided in an individually identifiable form;
13.1.2. The disclosure is on condition that it will not be used to contact persons to ask them to participate in the research;
13.1.3. Linkage of the personal information to other information is not harmful to the individuals identified by the personal information and the benefits to be derived from the linkage are clearly in the public interest;
13.1.4. The organization to which the personal information is to be disclosed has signed an agreement to comply with the following:
13.1.4.1. PIPA and PIPEDA;
13.1.4.2. The policies and procedures relating to the confidentially of personal information of the organization that collected the personal information;
13.1.4.3. Security and confidentiality conditions require removal or destruction of individual identifiers at the earliest reasonable opportunity
13.1.4.4. Prohibition of any subsequent use of disclosure of that personal information in individually identifiable form without the express authorization of the organization that disclosed the personal information, and
13.1.5. It is impracticable for the organization to seek the consent of the individual for the disclosure.
13.2. Section 13 does not authorize MABC to disclose personal information for market research purposes.
14.1. The Privacy Officer or designated individual is responsible for ensuring the Midwives Association of British Columbia’s compliance with this Policy and the Personal Information Protection Act (PIPA) and the Personal Information Protection and the Electronic Documents Act (PIPEDA).
14.2. Members should direct any complaints, concerns or questions regarding The Midwives Association of British Columbia’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the member may also write to the Information and Privacy Commissioner of British Columbia.
Email:
Website: www.bcmidwives.com
Telephone: 604.736.5976
Fax: 604.736.5957
Address: Suite 2 - 175 East 15th Avenue, Vancouver BC, V5T 2P6
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