Privacy Notice
HORSE COMMUNITY JOURNALS INC.
Personal Information Protection Policy
At HORSE COMMUNITY JOURNALS INC, we are committed to providing our
clients, customers, and subscribers with exceptional service. As
providing this service involves the collection, use and disclosure of
some personal information about our clients, customers and subscribers,
protecting their personal information is one of our highest priorities.
While we have always respected our clients’, customers’ and
subscribers’ 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 and subscribers 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’ and subscribers’ personal information. Our privacy
commitment includes ensuring the accuracy, confidentiality, and
security of our clients’, customers’ and subscribers’ personal
information, and allowing our clients, customers and subscribers to
request access to, and correction of, their personal information.
Scope of this Policy
This Personal Information Protection Policy applies to Horse Community
Journals Inc. (HCJI) and its subsidiaries. This policy also applies to
HCJI collecting, using or disclosing personal information on behalf of
Horse Council of British Columbia and the Alberta Equestrian
Federation, and other not-for-profit associations that exchange
information with HCJI from time to time.
Definitions
Personal Information: means information about an identifiable
individual, eg: name, age, home address, home phone number, income.
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 HCJI 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 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
client, customer or member information that is necessary to fulfill the
following purposes:
• To verify identity;
• To verify creditworthiness;
• To identify client, customer or subscriber
preferences;
• To understand the advertising, informational and
service needs of our clients, customers or subscribers;
• To open and manage an account;
• To deliver requested products and services
• To process a magazine subscription;
• To process an association membership;
• To contact our clients, customers or subscribers
for fundraising;
• To ensure a high standard of service to our
clients, customers and subscribers;
• To meet regulatory requirements;
• To collect and process payments for advertising,
services or subscriptions;
Policy 2 – Consent
2.1 We will obtain client,
customer or subscriber 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,
eg: 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 client, customer or subscriber voluntarily provides
personal information for that purpose.
2.3 Consent may also be
implied where a client, customer or subscriber 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, customer or subscriber does not opt-out.
2.4 Subject to certain
exceptions (eg: 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 or subscribers
can withhold or withdraw their consent for HCJI to use their personal
information in certain ways. A client’s, customer’s or subscriber’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 or subscriber in making the decision.
2.5 We may collect, use or
disclose personal information without the client’s, customer’s or
subscriber’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 (eg: 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 or subscriber 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 or subscriber surveys
in order to enhance the provision of our services;
• To contact our clients, customers or subscribers
directly about products and services that may be of interest;
3.2 We will not use or
disclose client, customer or subscriber personal information for any
additional purpose unless we obtain consent to do so.
3.3 We will not sell client,
customer or subscriber 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
or subscriber personal information to make a decision that directly
affects the client, customer or subscriber, we will retain that
personal information for at least one year so that the client, customer
or subscriber has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we
will retain client, customer or subscriber 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 or subscriber personal
information is accurate and complete where it may be used to make a
decision about the client, customer or subscriber or disclosed to
another organization.
5.2 Clients, customers or
subscribers 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
Privacy Officer or designated individual.
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’ or subscribers’ correction request in the file.
Policy 6 – Securing Personal
Information
6.1 We are committed to
ensuring the security of client, customer or subscriber 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 or subscriber
personal information is appropriately protected: physically securing
offices where personal information is held by use of alarm system; the
use of user IDs, passwords, encryption, firewalls; restricting employee
access to personal information as appropriate (ie: only those that need
to know will have access; contractually requiring any service providers
to provide comparable security measures).
6.3 We will use appropriate
security measures when destroying client’s, customer’s or subscriber’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, Subscribers Access to Personal Information
7.1 Clients, customers and
subscribers have a right to access their personal information, subject
to limited exceptions. Some examples of exceptions include:
solicitor-client privilege, where 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 Privacy Officer
or designated individual.
7.3 Upon request, we will also
tell clients, customers and subscribers 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 or subscriber of the cost
and request further direction from the client, customer or subscriber
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 or subscriber in
writing, providing the reasons for refusal and the recourse available
to the client, customer or subscriber.
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 Horse Community
Journals Inc.’s compliance with this policy and the Personal
Information Protection Act.
8.2 Clients, customers and
subscribers should direct any complaints, concerns or questions
regarding HCJI’s compliance in writing to the Privacy Officer. If the
Privacy Officer is unable to resolve the concern, the client, customer
or subscriber may also write to the Information and Privacy
Commissioner of British Columbia.
Contact information for Horse Community Journal Inc.’s Privacy Officer
or designated individual:
Kathy Smith, Publisher
Phone: 250-655-8883
Fax: 250-655-8913
Email: editor@horsejournals.com