Van Isle Marina Co. Ltd. Personal Information Protection Policy
At Van Isle Marina, we are committed to providing our customers with exceptional service. Providing this level of service involves the collection, use and disclosure of personal information. Protecting this personal information is a priority.
While we have always respected customer privacy and safeguarded personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses may collect, use and disclose personal information.
As a result, we will continue to inform customers of why and how we collect, use and disclose personal information, obtain consent where required, and only handle personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of personal information and allowing customers to request access to and correction of personal information.
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 PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that Van Isle Marina complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the customer 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 client and customer information that is necessary to fulfil the following purposes: To verify identity; to verify credit worthiness; to identify customer preferences; to understand the [financial, banking, insurance] needs of customers; to open and manage an account; to deliver requested products and services; to send out association membership information; to ensure a high standard of service to customers; to meet regulatory requirements; to assess suitability for tenancy; to collect and process moorage payments.
Policy 2 – Consent
2.1 We will obtain customer 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 through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the customer voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a customer is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products and the client or customer 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), customers can withhold or withdraw their consent for Van Isle Marina to use their personal information in certain ways. A customer’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 client or customer in making the decision.
2.5 We may collect, use or disclose personal information without the customer’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 the personal information is available from a public source (e.g., a telephone directory); when we require legal advice from a lawyer; for the purposes of collecting a debt; to protect ourselves from fraud; to investigate an anticipated breach of an agreement or a contravention of law; the collection is clearly in the interests of the individual and consent cannot be obtained in a timely way.
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose personal information where necessary to fulfil the purposes identified at the time of collection [or for a purpose reasonably related to those purposes such as: to conduct customer surveys in order to enhance the provision of our products and services; to contact customers directly about products and services that may be of interest.
3.2 We will not use or disclose personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell personal information to other parties [unless we have consent to do so].
Policy 4 – Retaining Personal Information
4.1 If we use personal information to make a decision that directly affects the customer we will retain that personal information for at least one year so that the customer has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain personal information only as long as necessary to fulfil 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 personal information is accurate and complete where it may be used to make a decision about the customer or disclosed to another organization.
5.2 Customers 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 correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of 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 personal information is appropriately protected: locked filing cabinets; encryption and Firewall protection; passwords and user I.D.; restricting employee access.
6.3 We will use appropriate security measures when destroying personal information such as: shredding; deleting electronic files.
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 Access to Personal Information
7.1 Customers 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. All requests to personal information should be forwarded to the Van Isle Marina Privacy Officer.
7.3 Upon request, we will also tell customers 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 fulfil 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 of the cost and request further direction from the customer 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 in writing, providing the reasons for refusal and the recourse available to the customer.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or Designated Individual
8.1 The Privacy Officer or designated individual is responsible for ensuring Van Isle Marina’s compliance with this policy and the Personal Information Protection Act.
8.2 Customers should direct any complaints, concerns or questions regarding Van Isle Marina’s compliance in writing to the Van Isle Marina Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer may also write to the Information and Privacy Commissioner of British Columbia.