Privacy Policy
Freedom Biker Church (FBC) Surrey – Privacy Policy
FBC Surrey is committed to respecting the privacy of its church attenders, and all individuals involved in a support role in the church.
In demonstration of our commitment to this privacy and in compliance with the Personal Information Protection Act (“PIPA”) we have created the following Privacy Policy (the “Policy”). The Policy has been designed to reflect our commitment to the principles outlined in PIPA that are as follows:
1. Accountability
2. Identifying purposes
3. Consent
4. Limiting collection
5. Limiting use, disclosure, and retention
6. Accuracy
7. Safeguards
8. Openness
9. Individual access
10. Challenging compliance
All directors, officers, employees and volunteers of FBC Surrey are required to comply with the Policy and may be given restricted access to personal information solely to fulfill the purposes as set out in this Policy.
All other persons or organizations who act for, or on behalf of, FBC Surrey are also required to comply with the principles and the Policy and may be given restricted access to personal information solely to fulfill the purposes as set out in this Policy.
Privacy Officer
FBC Surrey has appointed Chuck Pearce as their Privacy Officer who will be responsible for overseeing the Policy as well as any inquiries, requests or concerns relating to privacy matters. You may contact the Privacy Officer at the following address:
# 475-19567 Fraser Highway, Surrey BC, V3S 9A4
Overview
This Policy covers our treatment of the personal information we collect from persons attending our rallies and events.
In this Policy we will outline the purposes behind our collection and use of individuals personal information. In addition we will outline our policies concerning the collection, use, distribution and retention of this information. Finally we will also set out our policies for addressing any concerns or complaints.
Requests to Add, Change or Delete
If at any time, you wish to add, change or delete your personal information that is
retained by our office, please contact our Privacy Officer at:
_____________________________
PRINCIPLE 1 – ACCOUNTABILITY
FBC Surrey is responsible for personal information which we collect, use or distribute and any personal information in our custody or under our control. In order to fulfill our responsibility and comply with current legislation:
1.1 We have designated a privacy officer who is responsible to oversee our privacy policy and ensure routine compliance with it.
1.2 We shall make known the name or names of the Privacy Officer(s) and contact information upon request.
1.3 We have developed procedures in accordance with this Privacy Policy to govern the handling of personal information and respond to complaints.
1.4 Our staff and volunteers are trained in accordance with this Privacy Policy and committed to ensuring privacy is protected.
1.5 Our policy is made available to all interested persons on our website.
1.6 In the event that personal information is made available to a contracted third party, we will hold that party responsible to maintain comparable levels of protection of privacy while the information is in their control.
PRINCIPLE 2 – IDENTIFYING PURPOSES
2.1 FBC Surrey is committed to ensuring that the purposes for which personal information is used are identified.
2.2 FBC Surrey will only collect personal information from our church attenders that is necessary to fulfill the following purposes:
• To verify identity;
• To identify [church attender] preferences;
• To deliver requested products and services
• To provide counselling services;
• To send out association and/or church information;
• To contact our [church attenders] for fundraising;
• To ensure a high standard of accountability by our leadership to our church attenders];
• To meet regulatory requirements;
2.3 FBC Surrey will make these purposes known to individuals at the time that personal information is being collected either orally, electronically or in writing.
2.4 Unless required by law, FBC Surrey will not notify and obtain the consent of an individual before using previously collected information for a new purpose.
2.5 FBC Surrey will announce prior to any video-taping of Sunday rallies at church and other biker church related events the intention to video tape and will not video tape without the consent of those persons who would be filmed. FBC Surrey places two signs in the meeting area at our church which ask that no photographs be taken. Any exception to this rule will be announced prior to the taking of any photographs and those persons not wishing to be photographed will be given the opportunity to leave the area temporarily or the photographs will not be taken.
PRINCIPLE 3 – CONSENT
3.1 FBC Surrey will obtain reasonably informed consent of a church attender to collect, use or disclose personal information except where we are authorized to do so without consent.
3.2 Consent can be provided orally, in writing, electronically or through an authorized representative. We will take reasonable steps to ensure that consent given is clearly understood.
3.3 Consent can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the church attender voluntarily provides personal information for that purpose.
3.4 Consent may also be implied where a church attender is given notice and a reasonable opportunity to opt-out of his or her personal information being used for [mailing lists, contact lists and fundraising] and the church attender does not opt-out.
3.5 Subject to certain exceptions, church attenders can withhold or withdraw their consent for FBC Surrey to use their personal information in certain ways.
3.6 A church attender may not be able to withhold consent when withdrawal of consent would frustrate the performance of a legal obligation.
3.7 When consent is requested from church attenders for the purposes of video-taping or taking photographs at rallies and events, the request for consent will be on a case by case basis. For greater clarification, consent given for one event does not constitute consent for any future or following event.
3.8 FBC Surrey will not require consent to the collection and use of information in order to access goods or services unless that information is necessary to fulfill the purpose identified. In a situation where a church attender’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 we will explain the consequences of withdrawing consent to assist the church attender making the decision.
3.9 The following are examples of when we may collect, use or disclose the personal information of a church attender without their consent:
• When the collection, use or disclosure of personal information is permitted or required by law;
• When collection is clearly in your best interests and we are unable to obtain your consent in a timely way;
• In an emergency that threatens an individual’s life, health, or personal security;
• When disclosure is required to comply with a court order;
• When disclosure is required for archival purposes;
• When the personal information is available from a public source (e.g., a telephone directory);
• When the personal information is available through observation at a public event to which you attended voluntarily;
• When we require legal advice from a lawyer;
• To protect ourselves from fraud;
• To investigate an anticipated breach of an agreement or a contravention of law.
PRINCIPLE 4 – LIMITING COLLECTION
4.1 FBC Surrey shall limit the collection of personal information to the purposes set out in this policy in compliance with our legal obligations.
4.2 FBC Surrey will not collect personal information indiscriminately.
4.3 The purposes for collecting personal information shall be reasonably clear at the time of collection and we will not deceive or mislead our MEMBERs as to why information is being collected.
PRINCIPLE 5 – LIMITING USE, DISCLOSURE AND RETENTION
5.1 FBC Surrey will only use and disclose personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes except where we are authorized to do so (see Principle 3 – Consent).
5.2 FBC Surrey will not use or disclose church attender personal information for any additional purpose unless we obtain consent to do so.
5.3 FBC Surrey will not sell MEMBER lists or personal information to other parties.
5.4 FBC Surrey will only retain personal information as long as it is needed for the purposes for which it was collected or consented to.
5.5 FBC Surrey will maintain reasonable schedules to ensure that personal information is reviewed on an ongoing basis to determine relevance and if retention is required.
5.6 When personal information collected is no longer relevant to its purpose or when it is permitted by law, FBC Surrey will ensure that it is deleted, destroyed or made anonymous. In general, all personal information shall be deleted, destroyed or made anonymous no later than seven years after the purpose for which it was collected has been completed unless the law requires otherwise.
5.7 If FBC Surrey uses personal information to make a decision that directly affects a church attender we will retain that personal information for at least one year to give the church attender a reasonable opportunity to request access to it.
PRINCIPLE 6 – ACCURACY
6.1 FBC Surrey is committed to ensuring the accuracy of its information and will take reasonable efforts to ensure that personal information is accurate and complete where it is necessary.
6.2 FBC Surrey will update information when it is necessary or when an individual notifies us.
Church attenders 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. This request should be directed to the Privacy Officer.
PRINCIPLE 7 – SAFEGUARDS
7.1 FBC Surrey is concerned about the safety of our church attenders personal information. In order to address security concerns, we have developed the following safeguards:
• Physical security measures including locked cabinets, restricted access to areas where sensitive personal information is kept.
• Technological security measures including use of passwords, firewalls and security encryptions.
7.2 FBC Surrey shall protect personal information disclosed to third parties by contractual agreement that stipulates the confidentiality and safeguard requirements that are comparable to our own.
7.3 We will use appropriate security measures when destroying personal information such as:
• Shredding any documents;
• Deleting any electronic records;
7.4 FBC Surrey will routinely review and update our security measures.
7.5 FBC Surrey shall stress to both staff and volunteers the importance of safeguarding the confidential nature of personal information.
PRINCIPLE 8 – OPENESS
8.1 FBC Surrey is committed to making its privacy policies and procedures available and clear to all interested parties.
8.2 We will demonstrate our commitment to this openness by making the Privacy Policy easy to access and by making the name and contact information of our Privacy Officer readily available.
8.3 Any questions or concerns regarding our policy or procedure may be directed in writing to our Privacy Officer.
PRINCIPLE 9 – INDIVIDUAL ACCESS
9.1 Church attenders have a right to access their personal information, subject to limited exceptions including, but not limited to:
• Situations of solicitor-client privilege;
• Situations where disclosure may reveal the personal information of another individual;
• Situations where the health or safety of an individual may be jeopardized.
9.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought and should be forwarded to the attention of the Privacy Officer. We will make the requested information available within 15 business days, or provide written notice of an extension where additional time is required to fulfill the request.
9.3 We will endeavour to make all information provided easy to understand and explain any acronyms, abbreviations, etc. used.
9.4 We reserve the right to confirm the identity of the individual seeking access to personal information before complying with any access requests. In this event, information related to the church attender’s identity would be used exclusively for the purposes of confirming access.
9.5 In certain situations, it may not be possible to provide access to all the personal information that is held and a request may be refused in whole or in part. For example, information may not be provided if to do so would reveal personal information about a third party or jeopardize the security of another.
9.6 If a request is refused in full or in part or if the information requested is not available, we will notify the church attender in writing, providing the reasons for refusal and the recourse available to the MEMBER. This notification will be kept on file.
9.7 In the event that information provided is shown to be incomplete or inaccurate, we will amend the church attender’s personal information appropriately. When appropriate, we will transmit this correction to third parties with access to this information. When a challenge is not resolved to the MEMBER’s satisfaction, we will destroy all personal information under our care and control.
PRINCIPLE 10 - CHALLENGING COMPLIANCE
10.1 Complaints made regarding the Privacy Policy or the use of personal information should be made to the Privacy Officer in writing.
10.2 The Privacy Officer shall receive and respond to all personal information requests including challenges or complaints.
10.3 It is FBC Surrey’s policy that all complaints shall be investigated.
10.4 If a complaint is found to be justified, the Officer shall take appropriate measures, including, if necessary, amending this Policy.
10.5 The Privacy Officer may seek eternal advice where appropriate before providing a final response to individual complaints.
10.6 FBC Surrey’s procedure for dealing with complaints is as follows:
• Record the date and nature of a complaint when it is received
• Acknowledge receipt of the complaint promptly
• Review the matter fairly and impartially, providing to the individual where possible, access to all relevant records.
• Notify the individual of the outcome of the investigation promptly and clearly.
• Correct any inaccurate or incomplete information when possible.
10.7 The contact information for the Privacy Officer is as follows:
“Refer to page #1 of this Privacy Policy” under the paragraph titled: Privacy Officer
