Dynamic Shift Consulting
Personal Information Protection Policy
At Dynamic Shift Consulting Inc., we are committed to providing our clients and community members with exceptional service.
As providing this service involves the collection, use and disclosure of some personal information about our clients and community members, protecting their personal information is one of our highest priorities.
While we have always respected our clients’ and community members’ 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 and community members 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 and community members personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ and community members’ personal information and allowing our clients and community members to request access to, and correction of, their personal information.
Means information about an identifiable individual. Personal information does not include contact information (described below).
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.
Means the individual designated responsibility for ensuring that Dynamic Shift Consulting Inc., 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 or community 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 client and community member information that is necessary to fulfill the following purposes:
- To deliver requested products and services;
- To ensure a high standard of service to our clients and community members; and
- To meet regulatory requirements.
POLICY 2 - CONSENT
2.1 We will obtain client and community 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 orally, in writing, or electronically, 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 client and community member voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client and community member 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 community 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), clients and community members can withhold or withdraw their consent for Dynamic Shift Consulting Inc., to use their personal information in certain ways. A clients’ or community 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 client and community member in making the decision.
2.5 We may collect, use or disclose personal information without the clients’ or community members’ 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;
- When we require legal advice from a lawyer; and
- For the purposes of collecting a debt.
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose client and community members’ 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 and community member surveys in order to enhance the provision of our services;
- To contact our client and community members directly about products and services that may be of interest.
Policy 4 – Retaining Personal Information
4.1 If we use client and community members’ personal information to make a decision that directly affects the client and community member we will retain that personal information for at least one year so that the client and community member has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client and community 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 client and community member personal information is accurate and complete where it may be used to make a decision about the client and community member or disclosed to another organization.
5.2 Clients and community members 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 clients’ and community members’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client and community 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 client and community member personal information is appropriately protected:
The use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate.
6.3 We will use appropriate security measures when destroying client and community member 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 Clients and Community Members Access to Personal Information
7.1 Clients and community members have a right to access their personal information, subject to limited exceptions, such as:
- Solicitor-client privilege;
- disclosure would reveal personal information about another individual; and
- health and safety concerns.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer is responsible for ensuring Dynamic Shift Consulting Inc.’s compliance with this policy and the Personal Information Protection Act.
8.2 Clients and community members should direct any complaints, concerns or questions regarding Dynamic Shift Consulting Inc.’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client or community member may also write to the Information and Privacy Commissioner of British Columbia.
CONTACT INFORMATION FOR DYNAMIC SHIFT CONSULTING INC.’S PRIVACY OFFICER: