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ELCIC GROUP SERVICES INC. (GSI)
ELCIC Group Services Inc. (GSI) is committed to protecting an individual’s privacy and confidentiality of personal information. GSI recognizes and respects the right of privacy of individuals with respect to their personal information.
GSI’s Privacy Policy incorporates the Provisions of Canada’s Personal Information Protection and Electronic Documents ACT (PIPEDA) and includes the ten policies of the Canadian Standards Association’s Model Code for the Protection of Personal Information, which forms the base for that law.
GSI will review its Privacy Policy at least every five years to ensure it is relevant and remains current with changing technologies and laws and the evolving needs of GSI and its members.
GSI handles personal information in a variety of ways in the course of daily service delivery. This policy balances GSI’s need to obtain and handle personal information for business purposes with an individual’s right to the protection of personal information. This policy applies to GSI’s collection, use and disclosure of personal information and is subject to the requirements and provisions of Part 1 of the Personal Information Protection and Electronic Documents Act, the regulations enacted there under, and any other applicable legislation, regulations or agreements.
Collection – The act of gathering, acquiring, recording, or obtaining personal information.
Consent – Voluntary agreement with the collection, use and disclosure of personal information for defined purposes. Consent can be either express or implied and can be provided by the individual or by an authorized representative.
Member – An individual who is enrolled in the pension plan and/or benefits plan, which is administered by Group Services Inc. (GSI)
Disclosure - Making personal information available to a third party.
Third Party – An individual or organization outside of GSI.
Use – The treatment, handling, and management of personal information by and within GSI.
Summary Of Privacy Policy Statements
1. Accountability
GSI is responsible for maintaining and protecting all personal information under its control. GSI has designated a Privacy Officer to be accountable for compliance with GSI’s Privacy Policy.
2. Identifying purposes for Collection of Personal Information
GSI identifies the purposes for which personal information is collected at or before the time the information is collected.
3. Obtaining Consent for Collection, Use or Disclosure of Personal
Information
The knowledge and consent of an individual is required for the collection, use, or disclosure of personal information, except where the law provides an exemption.
4. Limiting Collection of Personal Information
GSI limits the collection of personal information to that which is necessary for the purposes identified by GSI.
5. Limiting Use, Disclosure, and Retention of Personal Information
GSI does not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. GSI retains personal information only as long as necessary for the fulfillment of those purposes.
6. Accuracy of Personal Information
GSI makes all efforts to ensure information is accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. However, individuals are relied upon to inform GSI of changes to their personal information.
7. Safeguarding Information
GSI protects personal information with appropriate security safeguards.
8. Openness Concerning Policies and Practices
GSI will make readily available to individuals specific information about its policies and procedures relating to the management of personal information.
9. Individual Access to Personal Information
Upon request to the Privacy Officer, GSI will inform an individual of the existence, use, and disclosure of his or her personal information and will give the individual access to that information. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
10. Challenging Compliance
Upon written request an individual will be able to address a challenge concerning compliance with the above stated policies to the Privacy Officer of GSI.
Appendix
Eligibility and enrolment forms are provided in the Appendix indicating the information that is collected by GSI. Subsequent life events that impact the administration of the pension and benefits plans may require additional information to be collected relevant to the circumstance.
GSI is responsible for maintaining and protecting all personal information under its control. GSI has designated a Privacy Officer to be accountable for compliance with GSI’s Privacy Policy.
1.1.The Executive Director of GSI is hereby appointed as the personal information compliance officer (the “officer”) GSI.
1.2 All persons, whether employees, board or committee members who collect, process or use personal information will be accountable for such information to the officer.
1.3 GSI is responsible for personal information in its possession or control, including information that has been transferred to a third party for processing. The officer will use contractual or other appropriate means to protect personal information at a level comparable to this policy while a third party is processing this information.
1.4 GSI implements policies and procedures to give effect to the GSI Privacy Policy, including:
a. implementing procedures to protect personal information;
b. establishing procedures to receive and respond to complaints and inquiries;
c. training staff and communicating to staff information about GSI’s policies and practices; and
d. developing information to explain GSI’s policies and practices.
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2. Identifying Purposes For Collection Or Personal Information
Policy Statement
GSI identifies the purposes for which personal information is collected at or before the time the information is collected.
Procedures
2.1 GSI collects personal information for the following purposes:
a. to maintain membership information and to create a mailing list a for distribution of GSI communications
b. to provide service to the members and to administer ELCIC pension and benefit plans;
c. to meet legal and financial requirements
2.2 GSI specifies orally, electronically or in writing the identified purposes to the individual at or before the time personal information is collected. Persons who collect personal information on behalf of GSI are able to provide information that explains the purposes for which it is being collected.
2.3 GSI obtains an individual's consent before using or disclosing personal information for a new purpose, unless the new purpose is required by law.
3. Obtaining Consent For Collection, Use Or Disclosure Of Personal Information
Policy Statement
The knowledge and consent of an individual is required for the collection, use, or disclosure of personal information, except where the law provides an exemption.
Procedures
3.1 GSI will ensure that the individual from whom personal information is collected consents to the collection and to the manner in which it will be used and disclosed.
3.2 GSI will ensure that the individual can reasonably understand why and how the information will be used when consent is given.
3.3 GSI will ensure that the individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. The individual will promptly be informed of the implications of the withdrawal.
4. Limiting Collection Of Personal Information
Policy Statement
GSI limits the collection of personal information to that which is necessary for the purposes identified by GSI.
Procedures
4.1 GSI does not collect personal information indiscriminately. Both the amount and type of personal information collected is limited to that which is necessary to fulfill the identified purposes.
4.2 GSI will ensure that information is collected only by fair and lawful means without misleading or deceiving individuals as to the reason.
4.3 GSI will ensure that the identifying purposes and consent principles are followed in identifying why personal information is to be collected.
5. Limiting Use, Disclosure, And Retention
Policy Statement
GSI does not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. GSI retains personal information only as long as necessary for the fulfillment of those purposes.
Procedures
5.1 GSI will ensure that personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law, and any use of personal information will be properly documented.
5.2 GSI will retain personal information in accordance with documented guidelines and procedures established by GSI. GSI keeps personal information only as long as it remains necessary or relevant for the identified purposes or for fiscal, legal, or operational requirements.
5.3 GSI will ensure that all personal information that is no longer required to fulfill the identified purposes is destroyed, erased or made anonymous as soon as the purpose for which it was collected is no longer relevant.
5.4 Only those GSI employees or Board who require access for business reasons are granted access to personal information about individuals.
Policy Statement
GSI makes all efforts to ensure information is accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. However, individuals are relied upon to inform GSI of changes to their personal information.
Procedures
6.1 GSI updates personal information about an individual as necessary to fulfill the identified purposes or upon notification by the individual.
6.2 Members are responsible for informing GSI about changes to personal information, as appropriate.
Policy Statement
GSI protects personal information with appropriate security safeguards.
Procedures
7.1 GSI protects personal information against loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, with security safeguards appropriate to the sensitivity of the personal information. GSI protects personal information regardless of the format in which it is held.
GSI uses care in disposing of or destroying personal information, to prevent unauthorized parties from gaining access to the information.
7.2 The methods of protection include:
a. physical measures to restrict access to personal information (e.g. locked filing cabinets and restricted access to offices);
b. organizational measures to control access to personal information (e.g. limiting access on a need-to-know basis and staff training); and
c. technological measures to prevent unauthorized access (e.g. the use of passwords, encryption and firewalls).
7.3. GSI protects personal information disclosed to third parties by contractual agreements or understandings stipulating the confidentiality of the information and the purposes for which it is to be used.
7.4 All GSI employees and Board with access to personal information are required, as a condition of employment or Board membership, to respect the confidentiality of personal information.
8. Openness Concerning Policies And Practices
Policy Statement
GSI will make readily available to individuals specific information about its policies and procedures relating to the management of personal information.
Procedures
8.1 GSI is open about its policies and practices with respect to the management of personal information. Information about GSI policies and practices are readily available in a form that is generally understandable.
8.2 The information made available includes:
a. the name or title, and the address, of the individual who is accountable for GSI’s policies and practices and to whom complaints or inquiries can be forwarded;
b. the means of gaining access to one's own personal information;
c. a description of the type of personal information held by GSI, including a general account of its use;
d. a copy of any information that explains GSI’s policies, standards or codes; and
e. what, if any, personal information is made available to related organizations.
8.3 GSI will ensure the information that must be provided according to 8.2 is available on the GSI website.
Policy Statement
Upon request to the Privacy Officer, GSI will inform an individual of the existence, use, and disclosure of his or her personal information and will give the individual access to that information. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Procedures
9.1 Upon written request, GSI will inform an individual whether personal information is held about him/her. If possible, the information’s source will also be given. GSI will allow the individual access to this information. It will also account for the use that has been made or is being made of this information and give an account as to any third parties to whom it has been disclosed.
9.2 In order to safeguard personal information, an individual may be required to provide sufficient identification information to permit GSI to account for the existence, use and disclosure of personal information and to authorize access to the individual's file. Any such information is used only for this purpose.
9.3 GSI responds to a written request for information within a reasonable time and at minimal or no cost to the individual. The requested information will be made available in a generally understandable form with abbreviations or codes explained.
9.5.GSI will ensure when an individual successfully demonstrates the inaccuracy or incompleteness of personal information, GSI will amend the information as required. Where appropriate, the amended information will be transmitted to third parties having access to the information in question. Amendments may involve the correction, deletion or addition of information.
Policy Statement
Upon written request an individual will be able to address a challenge concerning compliance with the above stated policies to the Privacy Officer of GSI.
Procedures
10.1 GSI maintains procedures for addressing and responding to all inquiries or complaints about GSI’s policies and practices relating to the handling of personal information.
10.2 GSI informs an individual and its employees about the existence of these procedures as well as the availability of complaint procedures.
10.3 GSI investigates all complaints concerning compliance with the GSI Privacy Policy. If a complaint is found to be justified, GSI takes appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. An individual is informed of the outcome of the investigation regarding his or her complaint.