Personal Information Protection Policy

At Friends of the Ottawa Public Library Association (FOPLA), we are committed to providing our volunteers, customers and members with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our volunteers, customers and members, protecting their personal information is one of our highest priorities.

While we have always respected our volunteers’, customers’ and members’ privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of the Personal Information Protection and Electronic Documents Act (PIPEDA). PIPEDA, which received Royal Assent on April 13, 2000, sets out the ground rules for how Canadian businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our volunteers, 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 PIPEDA, outlines the principles and practices we will follow in protecting volunteers’, customers’ and members’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our volunteers’, customers’ and members’ personal information and allowing our volunteers, customers and members to request access to, and correction of, their personal information.

Scope of this Policy

This Personal Information Protection Policy applies to FOPLA. This policy also applies to any service providers collecting, using or disclosing personal information on behalf of FOPLA.

Definitions

Personal Information means information about an identifiable individual. 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 or at home, and includes name, telephone number, street address, and email. Contact information is not covered by this policy or PIPEDA.

Privacy Officer means the individual designated responsibility for ensuring that FOPLA complies with this policy and PIPEDA.

Policy 1 – Collecting Personal Information

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

To verify identity;
To identify volunteer, customer or member preferences;
To open and manage an account;
To deliver requested products and services
To process an association membership subscription;
To send out association membership information;
To contact our volunteers, customers, and members for fundraising;
To ensure a high standard of service to our volunteers, customers, and members;
To meet regulatory requirements;

Policy 2 – Consent

2.1 We will obtain volunteer, customer, and 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 directly provided electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the volunteer, customer, or member voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a volunteer, 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, and fundraising, and the volunteer, 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), clients, customers, and members can withhold or withdraw their consent for FOPLA to use their personal information in certain ways. A client’s, 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 volunteer, customer, or member in making the decision.

2.5 We may collect, use or disclose personal information without the client’s, 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.

Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose volunteer, customer, and 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 volunteer, customer, and member surveys in order to enhance the provision of our services;
To contact our volunteers, customers, and members directly about products and services that may be of interest.

3.2 We will not use or disclose volunteer, customer, or member personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell volunteer, customer, and member lists or personal information to other parties.

Policy 4 – Retaining Personal Information

4.1 If we use volunteer, customer, and member personal information to make a decision that directly affects the volunteer, customer, or member, we will retain that personal information for at least one year so that the volunteer, customer, or member has a reasonable opportunity to request access to it.

4.2 Subject to Policy 4.1, we will retain volunteer, customer, and 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 volunteer, customer, and member personal information is accurate and complete where it may be used to make a decision about the volunteer, customer, or member or disclosed to another organization.

5.2 Volunteers, customers, and 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 volunteer’s, customer’s, or member’s correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of volunteer, 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 volunteer, customer, and 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; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access); and contractually requiring any service providers to provide comparable security measures.

6.3 We will use appropriate security measures when destroying volunteer, customer, and member personal information, such as shredding documents and 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 Volunteer, Customer, and Member Access to Personal Information

7.1 Volunteers, customers, and members have a right to access their personal information, subject to limited exceptions; for instance, if such 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 volunteers, customers, and 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 volunteer, customer, or member of the cost and request further direction from the volunteer, customer, and 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 volunteer, customer, or member in writing, providing the reasons for refusal and the recourse available to the volunteer, customer, and member.

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

8.1 The Privacy Officer is responsible for ensuring FOPLA’s compliance with this policy and the Personal Information Protection and Electron Documents Act.

8.2 Volunteers, customers, and members should direct any complaints, concerns or questions regarding FOPLA’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the volunteer, customer, or member may also write to the Privacy Commissioner of Canada.

Contact information for FOPLA’s Privacy Officer:
Jackie Young
jackie.young@biblioottawalibrary.ca
(613) 580-2400 x14383