Privacy Protection Policies
In accordance with the Personal Information Protection Act of British Columbia, staff must be familiar with, and adhere to, Jericho Kids’ Club Privacy Protection Policies regarding the collection, use and disclosure of personal information.
Statement and Purpose
Jericho Kids’ Club Child Care Centres respect and uphold an individual’s rights to privacy and to protection of his or her personal information. Jericho Kids’ Club Child Care Centres (referred to as Jericho Kids’ Club) are committed to collecting, using and disclosing personal information in a manner that complies with the Personal Information Protection Act (PIPA) of British Columbia.
Jericho Kids’ Club sets out the procedures that will be observed with respect to the collection, use and disclosure of information about any identifiable individual who is a past, current or prospective:
- Parent/ Guardian of Enrolled Child
- Person Identified on Registration Information
Principles and Procedures
Jericho Kids’ Club is responsible for all personal information under its control. The organisation’s Privacy Officer is accountable for Jericho Kids’ Club’s compliance with the principles described in this policy. The Privacy Officer can be contacted at the Jericho Kids’ Club office. Jericho Kids’ Club is responsible, not only for personal information in its physical possession or custody, but also for personal information that is transferred by Jericho Kids’ Club to a third party and will implement procedures to:
- Protect personal information;
- Receive and respond to complaints and enquiries;
- Orient employees and volunteers in the policies and procedures regarding the collection, use and disclosure of personal information under Jericho Kids’ Club’s protection;
- Purposes for Collection, Use and Disclosure
Personal information will be collected on a “need to know” basis for the operation of Jericho Kids’ Club. Jericho Kids’ Club may collect personal information concerning children and their families, staff, volunteers and/or donors for the following purposes:
- To comply with legal and regulatory requirements
- To operate Jericho Kids’ Club Child Care Centres
- To administer and maintain accounts relating to operations and/or donations.
Written consent of the individual is required for the collection, use and/or disclosure of personal information by Jericho Kids’ Club, except where inappropriate by law or by circumstance. Implied consent may arise through action or inaction on the part of the individual.
- Limiting Collection
Jericho Kids’ Club will limit the amount and type of personal information collected to information that is necessary for the purposes of Jericho Kids’ Club Child Care Centres.
- Limiting Use, Disclosure and Retention
Jericho Kids’ Club will not use or disclose personal information for purposes other than those for which it was collected, except with the written consent of the individual or as required or permitted by law. Personal information will be retained only as long as necessary for the fulfillment of legal or business purposes. Personal information will be stored in a locked cabinet at Jericho Kids’ Club and will be accessed on a “need to know” basis.
Jericho Kids’ Club will make a reasonable effort to ensure that personal information collected by Jericho Kids’ Club or on its behalf is as accurate and complete as is necessary for the purposes for which it is to be used. Jericho Kids’ Club will generally rely on individuals to provide updated information, such as changes to addresses and other contact information.
Jericho Kids’ Club will make reasonable security arrangements to protect personal information. Safeguard arrangements are employed to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use modification, or disposal. The methods of protection employed by Jericho Kids’ Club will include:
- Physical measures, including locked filing cabinets and restricted access to offices;
- Organizational measures, such as “clean desk” policy and limiting access to a “need to know” basis;
- Technological measures, such as use of passwords to access electronic files;
- Shredding of discarded documents containing personal information.
Jericho Kids’ Club will ensure that individuals are able to acquire information about Jericho Kids’ Club policies and procedures on privacy protection. Jericho Kids’ Club will make this information available in a form that is generally understandable.
- Accessing Personal Information
When requested in writing to the privacy officer, Jericho Kids’ Club shall inform an individual of the existence, use, and disclosure of his/her personal information and the individual shall be given access to that information, except where the law requires or permits Jericho Kids’ Club to deny access. Jericho Kids’ Club will respond to requests in writing as accurately and completely as is reasonably possible within 30 days after receipt of the request.
An individual will be able to direct complaints concerning Jericho Kids’ Club’s compliance with privacy protection to the Privacy officer(s). A complaint must be in writing to the Privacy Officer(s). Jericho Kids’ Club will:
- Promptly acknowledge receipt of the complaint in writing
- Contact the individual to clarify the complaint, if necessary
- Take any complaint forward to the Parent Advisory Council
- Investigate all complaints received
- Notify the individual of the outcome of investigations promptly, informing them clearly of any relevant steps taken
- Correct any inaccurate personal information or modify policies and procedures based on the outcome of complaints
- Make reasonable effort to process complaints within 30 days or apply to the Privacy Commissioner for an extension.