Personal Information Protection Policy
At Tango Burnaby Studio Inc., we are committed to providing our clients, customers, members with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, customers, members, protecting their personal information is one of our highest priorities.
While we have always respected our clients, customers, members 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, customers, 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, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients’, customers’, members’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’, customers’, members’ personal information and allowing our clients, customers, members to request access to, and correction of, their personal information.
Personal Information: means information about an identifiable individual E.g., including name, home address phone number, email address, emergency contact, medical info relevant to physical activity (i.e. asthmatic), how the client, customer, member learned about us. 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.
Privacy Officer: means the individual designated responsibility for ensuring that Tango Burnaby Studio Inc. 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, customer, 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.
1.2 We will only collect client, customer, member information that is necessary to fulfill the following purposes:
– To identify [client, customer, member] preferences: to understand what courses/services the client, customer, member is interested in to aid in trying to send only relevant promotional info, newsletters etc.
– To deliver requested products and services: helps us to better understand the client, customer, member needs
– To enrol the client in a program/course:
– To ensure a high standard of service to our [clients, customers, members]
– To meet the requirements of our insurance company: they require our clients, customers, members to provide personal information and to sign the registration form that includes a waiver and acknowledgement stating that the client, customer, member understands the risks involved in participating in the activities offered at Tango Burnaby Studio Inc.
– To know what part of the community the client, customer, member comes from: this helps us know if our marketing is cost effective which benefits our client, customer, member, with lower prices.
– To obtain a signature from the client, customer, member acknowledging and understanding our refund policy, waiver of liability, code of conduct, model release and miscellaneous terms of enrollment.
– To facilitate the purchase of our services, products, courses by telephone. We collect the client, customer, member credit card information but we do not keep this information on file. Instead we shred the card information immediately after the purchase has been processed. (except in the case of youth course monthly payments in which the credit card information which is kept in an encrypted file and or post dated cheques that are stored in a locked filing cabinet)
Policy 2: Consent
2.1 We will obtain client, customer, member 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 in writing and/or orally or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client, customer, member voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client, customer, 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, and the client, customer, member 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, customers, members can withhold or withdraw their consent for Tango Burnaby Studio Inc. to use their personal information in certain ways. A client’s, customer’s, 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 client, customer, member in making the decision.
2.5 We may collect, use or disclose personal information without the client’s, customer’s, member’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, customer, 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:
– To conduct client, customer, member surveys in order to enhance the provision of our services;
– To contact our clients, customers, members directly about products, services, event updates, dance and music tips that may be of interest;
3.2 We will not use or disclose client, customer, member personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client, customer, member 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, customer, member personal information to make a decision that directly affects the client, customer, member, we will retain that personal information for at least one year so that the client, customer, member has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client, customer, member 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, customer, member personal information is accurate and complete where it may be used to make a decision about the client, customer, member or disclosed to another organization.
5.2 Clients, Customers, Members 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’, customers’, members’ correction request in the file.
Policy 6: Securing Personal Information
6.1 We are committed to ensuring the security of client, customer, member 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, customer, member personal information is appropriately protected:
– The use of locked filing cabinets;
– Physically securing offices where personal information is held;
– The use of user IDs, passwords, encryption, firewalls;
6.3 We will use appropriate security measures when destroying client’s, customer’s, member’s personal information such as
– 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, Customers, Members Access to Personal Information
7.1 Clients, Customers, Members have a right to access their personal information, subject to limited exceptions. (See section 23 of the BC PIPA)
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 may be forwarded to the Privacy Officer [or President of Operations]
7.3 Upon request, we will also tell clients, customers, members 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, customer, member of the cost and request further direction from the client, customer, member 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, customer, member in writing, providing the reasons for refusal and the recourse available to the client, customer, member.
Policy 8: Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer is responsible for ensuring Tango Burnaby Studio Inc.’s compliance with this policy and the Personal Information Protection Act.
8.2 Clients, Customers, Members should direct any complaints, concerns or questions regarding Tango Burnaby Studio Inc.’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client, customer, member may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Tango Burnaby Studio Inc.’s Privacy Officer:
Tango Burnaby Studio Inc.