Information Protection Policy
3Pikas collects and hosts certain types of information about the Individuals or Users who come into contact with 3Pikas’ Sites and Services. This personal information must be collected and dealt with appropriately whether is collected in the clouds, on paper, stored in a computer database, or recorded on other material and there are safeguards to ensure this under the Privacy Laws in Canada.
3Pikas may share data with site sponsors such as clients, the local authority, and other agencies.
The Individual/Service User will be made aware in most circumstances how and with whom their information will be shared. However, there are circumstances where the law allows 3Pikas to disclose data (including sensitive data) without the data subject’s consent.
- a) Carrying out a legal duty
- b) Protecting vital interests of an Individual/Service User or another person
- c) The Individual/Service User has already made the information public
- d) Conducting any legal proceedings, obtaining legal advice or defending any legal rights
- e) Monitoring for equal opportunities purposes – i.e. race, disability or religion
- f) Providing a confidential service where the Individual/Service User’s consent cannot be obtained or where it is reasonable to proceed without consent: e.g. where we would wish to avoid forcing stressed or ill Individuals/Service Users to provide consent signatures.
3Pikas regards the lawful and correct treatment of personal information as very important, and to maintaining the confidence of those with whom we deal.
3Pikas intends to ensure that personal information is treated lawfully and correctly.
To this end, 3Pikas will adhere to the following Principles of Data Protection.
Specifically, the Principles require that personal information:
- Shall be processed fairly and lawfully and, in particular, shall not be processed unless specific conditions are met,
- Shall be accurate and, where necessary, kept up to date,
- Shall not be kept for longer than is necessary,
- Shall be processed in accordance with the rights of data subjects under the Privacy Laws in Canada,
- Shall be kept secure by the Data Controller who takes appropriate technical and other measures to prevent unauthorized or unlawful processing or accidental loss or destruction of, or damage to, personal information,
- Shall not be transferred to a country or territory outside the Canada unless that country or territory ensures an adequate level of protection for the rights and freedoms of Individuals/Service Users in relation to the processing of personal information.
3Pikas will, through appropriate management and strict application of criteria and controls:
- Observe fully conditions regarding the fair collection and use of information
- Meet its legal obligations to specify the purposes for which information is used
- Collect and process appropriate information, and only to the extent that it is needed to fulfill its operational needs or to comply with any legal requirements
- Ensure the quality of information used
- Ensure that the rights of people about whom information is held can be fully exercised. These include:
- The right to be informed that processing is being undertaken,
- The right of access to one’s personal information
- The right to prevent processing in certain circumstances and
- The right to correct, rectify, block or erase information which is regarded as wrong information)
- Take appropriate technical and organizational security measures to safeguard personal information
- Ensure that personal information is not transferred abroad without suitable safeguards
- Treat people justly and fairly whatever their age, religion, disability, gender, sexual orientation or ethnicity when dealing with requests for information
- Set out clear procedures for responding to requests for information
Informed consent is when:
- An Individual/Service User clearly understands why their information is needed, who it will be shared with, the possible consequences of them agreeing or refusing the proposed use of the data
- And then gives their consent.
3Pikas will ensure that data is collected within the boundaries defined in this policy. This applies to data that is collected in person, or by completing a form.
When collecting data, 3Pikas will ensure that the Individual/Service User:
- Clearly, understands why the information is needed
- Understands what it will be used for and what the consequences are should the Individual/Service User decide not to give consent to processing
- As far as reasonably possible, grants explicit consent, either written or verbal for data to be processed
- Is, as far as reasonably practicable, competent enough to give consent and has given so freely without any duress
- Has received sufficient information on why their data is needed and how it will be used
Information and records relating to service users will be stored securely and will only be accessible to authorized staff and partners. However, employees and partners should not be allowed to access information until the Data Protection Manager is satisfied that they understand and agree the legislated responsibilities for the information that they will be handling.
Information will be stored for only as long as it is needed or required statute and will be disposed of appropriately.
It is 3Pikas’ responsibility to ensure all personal and company data is non-recoverable from any computer system previously used within the organization, which has been passed on/sold to a third party.
Databases holding personal information will have a defined security and system management procedure for the records and documentation.
Files identified as a potential security risk should only be stored on secure network areas.
Data Access and Accuracy
All Individuals/Service Users have the right to access the information 3Pikas holds about them. 3Pikas will also take reasonable steps to ensure that this information is kept up to date by asking data subjects whether there have been any changes.
In addition, 3Pikas will ensure that:
- It has a Data Protection Officer with specific responsibility for ensuring compliance with Data Protection
- Everyone processing personal information understands that they are contractually responsible for following good data protection practices
- Everyone processing personal information is appropriately trained to do so
- Everyone processing personal information is appropriately supervised
- Anybody wanting to make inquiries about handling personal information knows what to do
- It deals promptly and courteously with any inquiries about handling personal information
- It describes clearly how it handles personal information
- It will regularly review and audit the ways it hold, manage and use personal information
- It regularly assesses and evaluates its methods and performance in relation to handling personal information
- All employees and partners are aware that a breach of the rules and procedures identified in this policy may lead to disciplinary action being taken against them
This policy will be updated as necessary to reflect best practice in data management, security, and control and to ensure compliance with any changes or amendments made to the Privacy Laws in Canada.
- In the case of any queries or questions in relation to this policy please contact the 3Pikas Data Protection Officer:
- Name: Simon Lapointe
- Position: Founder/CEO
- Date: January 20, 2017
Author: Simon Lapointe
Filename: Information Protection Policy
Owner: Simon Lapointe, Founder & CEO
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