At The Coalition to Support ELDER RIGHTS (referred to herein as “ELDER RIGHTS”), we are committed to providing members of our coalition and members of the public (referred to herein as “our members” or “members”) with exceptional service. As providing this service involves the collection, use and disclosure of some personal information, protecting personal information is one of our highest priorities.
We respect privacy and safeguard personal information in accordance with the Canadian Charter of Rights and Freedoms, the British Columbia Personal Information Protection Act (PIPA), and the B.C. Residents’ Bill of Rights. These Acts of legislation set out the ground rules for how we collect, use and disclose personal information, and the spirit in which we do so.
ELDER RIGHTS is a non-profit coalition of volunteer individuals and organizations, not a society, business or government entity. The Coalition to Support ELDER RIGHTS does not solicit funding from any of the aforementioned vested interests.
We will inform people 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 reasonable, responsible and appropriate manner.
Scope of this Policy
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 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 by PIPA or any other legislation in Canada.
Privacy Officer – means the individual designated responsibility for ensuring that the ELDER RIGHTS complies with this policy.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the 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 member information that is necessary to fulfill the following purposes: To identify member preferences; To send out membership information; To promote elder rights and protection; To create a network of empowered seniors and elder rights supporters; To provide elder rights and protection information, education, and resources for the public, seniors and elder rights supporters; To provide elder rights and protection tools, news and data for seniors and elder rights supporters; To provide information and resources for seniors and elder rights supporters who have experienced an adverse event of any kind; To provide information and resources which will help seniors and elder rights supporters avoid adverse events of any kind; To survey the general public on matters related to elder rights and protection; To engage and empower seniors and elder rights supporters to help resolve concerns regarding elder rights; To provide advocacy on behalf of seniors and their families or friends to protect and ensure elder rights and elder safety; To encourage seniors, elder rights supporters and the public to work together toward positive outcomes and make improvements where rights are in jeopardy or have been disregarded.
1.3 We use your personal information to:
• Provide you with personalized services and interactive communication through our website and offline;
• Provide you with timely and reliable services;
• Do all the things necessary to administer those services;
• Research, develop, manage, protect and improve those services;
• Prepare aggregated research based on de-identified information for the purposes of publication; and
• Develop and maintain our relationship with you and communicate with you.
1.4 ELDER RIGHTS collects personal information about you only when you voluntarily provide it. Typically, we will seek consent for the use or disclosure of your personal information at the time of collection. In certain circumstances, consent may be sought after the information has been collected but before use (for example, when we want to use information for a purpose not previously identified). The form of consent that we seek, including whether it is express or implied, will largely depend on the sensitivity of the personal information and the reasonable expectations of the individual in the circumstances.
Policy 2 – Consent
2.1 We will obtain 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 orally, in writing, electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the member voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a member is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, including newsletters, surveys, invitations, and the 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), members can withhold or withdraw their consent for ELDER RIGHTS to use their personal information in certain ways. A 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 member in making the decision.
2.5 We may collect, use or disclose personal information without the 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 we require legal advice from a lawyer; When personal information is available from a public source.
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose 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 member surveys in order to enhance the provision of our services;
To contact our members directly about products and services that may be of interest;
To provide names of members participating in ELDER RIGHTS events.
3.2 We will not use or disclose member personal information for any additional purpose unless we obtain consent to do so.
3.4 We will not sell member lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use member personal information to make a decision that directly affects the member we will retain that personal information for at least one year so that the member has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain 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 member personal information is accurate and complete where it may be used to make a decision about the member or disclosed to another organization.
5.2 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. It 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 members’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of 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 member personal information is appropriately protected: The use of user IDs, passwords, encryption and firewalls, requiring any service providers to provide comparable security measures
6.3 We will use appropriate security measures when destroying members’ personal information such as 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 Members Access to Personal Information
7.1 Members have a right to access their personal information, subject to limited exceptions.
The information is protected by solicitor-client privilege;
The disclosure of the information would reveal confidential commercial information, that if disclosed, could, in the opinion of a reasonable person, harm the competitive position of the organization;
The information was collected or disclosed without consent, as allowed under section 12 or 18 of PIPA, for the purpose of an investigation and the investigation and associated proceedings and appeals have not been completed;
The information is in a document that is subject to a solicitor’s lien; and
The information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act (i) under a collective agreement (ii) under an enactment (iii) by a court
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 official.
7.3 Upon request, we will also tell 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 member of the cost and request further direction from the 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 member in writing, providing the reasons for refusal and the recourse available to the member.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer is responsible for ensuring the ELDER RIGHTS’s compliance with this policy and the Personal Information Protection Act.
8.2 Members should direct any complaints, concerns or questions regarding the ELDER RIGHTS’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the member may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for the ELDER RIGHTS’s Privacy Officer:
Administrator, ELDER RIGHTS website firstname.lastname@example.org