PERSONAL INFORMATION PROTECTION POLICY
Scope of this Policy
Definitions
POLICY 1 - COLLECTING PERSONAL INFORMATION
1.1 Unless the purposes for collecting personal information are obvious and the customer and Band-Aid+ 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 customer and Band-Aid+ member information that is necessary to fulfill the following purposes:
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To verify identity;
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To identify customer and Band-Aid+ member preferences;
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To ensure a high standard of service to our customers and Band-Aid+ members
POLICY 2 - CONSENT
2.1 We will obtain customer and Band-Aid+ 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 electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the customer and Band-Aid+ member voluntarily provides personal information for that purpose (e.g., when registering as a Band-Aid+ member).
2.3 Consent may also be implied where a customer and Band-Aid+ member is given notice and a reasonable opportunity to opt-out of his or her personal information being used for email newsletters and the marketing of new services or products, and the client, customer, 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), the customers and Band-Aid+ members can withhold or withdraw their consent for House of Knives to use their personal information in certain ways. A customer's and Band-Aid+ members 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 customer and Band-Aid+ member in making the decision.
2.5 We may collect, use or disclose personal information without the customer's and Band-Aid+ member's knowledge or consent in the following limited circumstances:
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When the collection, use or disclosure of personal information is permitted or required by law;
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In an emergency that threatens an individual's life, health, or personal security;
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When the personal information is available from a public source (e.g., a telephone directory);
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When we require legal advice from a lawyer;
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For the purposes of collecting a debt;
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To protect ourselves from fraud;
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To investigate an anticipated breach of an agreement or a contravention of law
POLICY 3 - USING AND DISCLOSING PERSONAL INFORMATION
3.1 We will only use or disclose customer and Band-Aid+ member personal information where necessary to fulfill the purposes identified at the time of collection or or for a purpose reasonably related to those purposes such as:
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To conduct customer and Band-Aid+ member surveys in order to enhance the provision of our services;
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To contact our customers and Band-Aid+ members directly about products and services that may be of interest
3.2 We will not use or disclose customer and Band-Aid+ member personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell customer and Band-Aid+ member lists or personal information to other parties.
POLICY 4 - RETAINING PERSONAL INFORMATION
4.1 If we customer and Band-Aid+ member personal information to make a decision that directly affects the customer and Band-Aid+ member, we will retain that personal information for at least one year so that the customer and Band-Aid+ member has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain customer and Band-Aid+ 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 customer and Band-Aid+ member personal information is accurate and complete where it may be used to make a decision about the customer and Band-Aid+ member or disclosed to another organization.
5.2 customer and Band-Aid+ member 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.
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 customer and Band-Aid+ member correction request in the file.
POLICY 6 - SECURING PERSONAL INFORMATION
6.1 We are committed to ensuring the security of customer and Band-Aid+ 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 customer and Band-Aid+ member personal information is appropriately protected:
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Physically secure offices where personal information is held
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The use of user IDs, passwords, passwords, encryption, and firewalls
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Restricted employee access to personal information as appropriate (i.e., only those that need to know will have access)
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Contractually requiring any service providers to provide comparable security measure
6.3 We will use appropriate security measures when destroying customer's and Baind-Aid+ member's personal information by 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 CUSTOMERS AND BAND-AID+ MEMBERS ACCESS TO PERSONAL INFORMATION
7.1 Customers and Band-Aid+ members have a right to access their personal information, subject to limited exceptions.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell customers and Band-Aid+ 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 customer and Band-Aid+ member of the cost and request further direction from the customer and Band-Aid+ 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 customer and Band-Aid+ member in writing, providing the reasons for refusal and the recourse available to the customer and Band-Aid+ member.
POLICY 8 - QUESTIONS AND COMPLAINTS: THE ROLE OF THE PRIVACY OFFICER OR DESIGNATED INDIVIDUAL
8.1 The Privacy Officer is responsible for ensuring House of Knives compliance with this policy and the Personal Information Protection Act.
8.2 Customers and Band-Aid+ members should direct any complaints, concerns or questions regarding House of Knives' compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer and Band-Aid+ member may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for House of Knives Privacy Officer:Burnaby, BC
V5C 3M2
