Personal Information Protection Policy

At Peninsula Consumer Services Co-operative (“Peninsula Co-op”), we are committed to providing our customers and members with exceptional products and services. As providing these products and services involves the collection, use and disclosure of some personal information about our customers and members, protecting their personal information is one of our highest priorities. While we have always respected our customers and 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 customers and 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 customers’ and members’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our customers’ and members’ personal information and allowing our customers and members to request access to, and correction of, their personal information.

Definitions

Personal Information – means information about an identifiable individual [E.g., including name, birthdate, home address and phone number, social insurance number, credit history, employment information]. 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 Peninsula Co-op complies with this policy and PIPA.

Policy 1 – Collecting Personal Information

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

• To verify creditworthiness;
• To identify customer or member preferences;
• To open and manage an account;
• To deliver requested products and services;
• To process a membership application;
• To change a customer’s or member’s information; (E.g., mailing address, phone number, email address, legal name)
• To verify identity; (E.g., To verify identity, we may collect name, customer or member number, mailing address, birth date, 3 digits of Social Insurance Number)
• To send out customer or membership information;
• To process a customer or member payment;
• To ensure a high standard of service to our customers or members;
• To meet regulatory requirements;
• To meet Canada Revenue Agency income tax withholding and form filing regulations;
• To assess suitability for tenancy;
• To collect and process rent payments;
• To facilitate electronic voting for election of Directors and resolutions, as required

Policy 2 – Consent

2.1 We will obtain customer or 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 [E.g., 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 or member voluntarily provides personal information for that purpose. 2.3 Consent may also be implied where a customer or 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, promotions and the customer or 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), customers or members can withhold or withdraw their consent for Peninsula Co-op to use their personal information in certain ways. A customer’s or 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 customer or member in making the decision. 2.5 We may collect, use or disclose personal information without the customer’s or 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;
• The disclosure is necessary to determine suitability to receive an honour, award, scholarship, bursary or to be selected for an athletic or artistic purpose

Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose customer or 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 customer or member surveys in order to enhance the provision of our products or services;
• To contact our customers or members directly about products and services that may be of interest;
• To process a customer or membership application

3.2 We will not use or disclose customer or member personal information for any additional purpose unless we obtain consent to do so. 3.3 We will not sell customer or 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 customer or member personal information to make a decision that directly affects the customer or member, we will retain that personal information for at least one year so that the customer or member has a reasonable opportunity to request access to it. 4.2 Subject to policy 4.1, we will retain customer or 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 customer or member personal information is accurate and complete where it may be used to make a decision about the customer or member or disclosed to another organization. 5.2 Customers or 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 customers ’or members’ correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of customer and 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 customer or member personal information is appropriately protected: Examples include:

• physically securing offices where personal information is held;
• the use of user IDs, passwords and encryption where appropriate;
• restricting employee access to personal information as appropriate (i.e., only those that need to know will have access;)

6.3 We will use appropriate security measures when destroying customer’s or member’s personal information such as: Examples include:

• Shredding documents;
• Securely 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 Customers and Members Access to Personal Information

7.1 Customers and Members have a right to access their personal information, subject to limited exceptions. Examples include:

• The information is protected by solicitor-client privilege;
• Disclosure would reveal personal information about another individual;
• The disclosure could reasonably be expected to create health and safety concerns for the individual making the request or another individual;

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. When applicable, a request to access personal information should be forwarded to the Privacy Officer [or designated individual] 7.3 Upon request, we will also tell customers or 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 customer or member of the cost and request further direction from the customer or 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 customer or member in writing, providing the reasons for refusal and the recourse available to the customer or member.

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

8.1 The Privacy Officer or designated individual is responsible for ensuring Peninsula Co-op’s compliance with this policy and the Personal Information Protection Act. 8.2 Customers or members should direct any complaints, concerns or questions regarding Peninsula Coop’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer or member may also write to the Information and Privacy Commissioner of British Columbia.