Personal Information Protection
Private Sector Privacy Legislation
Personal Information Protection Policy
Brim Lactation & Family Care
Personal Information Protection Policy
At Brim Lactation & Family Care, we are committed to providing our clients with exceptional service. As
providing this service involves the collection, use and disclosure of some personal information about our clients, protecting their personal information is one of our highest priorities.
While we have always respected our client’s privacy and safeguarded their 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 and not-for-profit organizations may collect, use and disclose personal information.
We will inform our clients 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 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 clients’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ personal information and allowing our clients to request access to, and correction of, their personal information.
Definitions
Personal Information – means information about an identifiable individual such as name, age, home address
and phone number, marital status, religion, medical information, employment information. 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 Brim Lactation & Family Care complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the client 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 information that is necessary to fulfill the following purposes:
● To verify identity;
● To identify client preferences;
● To deliver requested products and services;
● To provide counseling services;
● To enrol the client in a program;
● To ensure a high standard of service to our clients
● To meet regulatory requirements;
● To collect and process payments;
Policy 2 – Consent
2.1 We will obtain client 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 client
voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client 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 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), clients can
withhold or withdraw their consent for Brim Lactation & Family Care to use their personal information in
certain ways. A client'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 in making the decision.
2.5 We may collect, use or disclose personal information without the client’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
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose client 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 client, customer, member surveys in order to enhance the provision of our services;
● To contact our clients directly about products and services that may be of interest
3.2 We will not use or disclose client personal information for any additional purpose unless we obtain
consent to do so.
3.3 We will not sell client lists or personal information to other parties [unless we have consent to do so].
Policy 4 – Retaining Personal Information
4.1 If we use client personal information to make a decision that directly affects the client, we will retain that
personal information for at least one year so that the client has a reasonable opportunity to request
access to it.
4.2 Subject to policy 4.1, we will retain client 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 client personal information is accurate and complete
where it may be used to make a decision about the client or disclosed to another organization.
5.2 Clients 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.
A request to correct personal information should be forwarded to the Privacy Officer.
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 clients’
correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client 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 client personal information is appropriately
protected:
physically securing offices where personal information is held; the use of user IDs, passwords,
encryption, firewalls; restricting employee access to personal information as appropriate (i.e., only those
that need to know will have access; contractually requiring any service providers to provide comparable
security measures].
6.3 We will use appropriate security measures when destroying clients’ personal information such as
shredding documents, 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 Client Access to Personal Information
7.1 Clients 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 clients 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 client of the cost and request further direction from the client 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 client in writing, providing the reasons for refusal
and the recourse available to the client.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer is responsible for ensuring Brim Lactation & Family Care’s compliance with this
policy and the Personal Information Protection Act.
8.2 Clients should direct any complaints, concerns or questions regarding Brim Lactation & Family Care’s
compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the
client may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for Brim Lactation & Family Care’s Privacy Officer:
Pamela Tessmann
250-650-6655