SCOPE OF THIS PERSONAL INFORMATION PROTECTION POLICY
This Personal Information Protection Policy sets out the principles which The Greater Vancouver Convention and Visitors Tourism Vancouver ("Tourism Vancouver") observes regarding the collection, use and disclosure of personal information about Tourism Vancouver's employees and volunteers.
This Personal Information Protection Policy does not apply to personal information which is collected, used or disclosed in relation to employees or volunteers in their capacity as members or customers of Tourism Vancouver. Member and customer personal information is governed by the Tourism Vancouver Member and Customer Personal Information Protection Policy.
This Personal Information Protection Policy is subject to all applicable laws. If personal information is made anonymous by removing details so that an individual is not identifiable to the user or recipient of that information, it is not governed by this Policy but will still be treated with appropriate safeguards.
For the purposes of this Personal Information Protection Policy:
"Contact information" means information to enable an individual at a place of business to be contacted and includes the name, position name or title, business telephone number, business address, business e-mail or business fax number of the individual.
"Employees" and "volunteers" means any current, past or prospective employee or volunteer, including trainees and temporary employees or volunteers; other workers and independent contractors; and current, past or prospective officers or directors.
"Personal information" means any information about an identifiable individual, whether it was collected before or after this Policy was first published, including but not limited to the individual's name, address, age, gender, identification numbers (including social insurance number), income, employment, assets, liabilities, payment records, personal references, health records, credit card numbers, and other finance-related information. "Personal information" may also include a physical description, habits, personality, character, marital history, immigration status, travel or movement details, lifestyle, leisure activities, court/tribunal/inquiry proceedings, qualifications and skills, student records, career history, insurance policies or claims, professional or trade union memberships, and licenses and permits held. Personal information does not include contact information or work product information. With respect to any specific individual, Tourism Vancouver may or may not have personal information within these enumerated categories.
"work product information" means information prepared or collected by an individual or group of individuals as part of the individual's or group's responsibilities or activities related to the individual's or group's employment or business but does not include personal information about an individual who did not prepare or collect the personal information.
PRINCIPLE 1 - TOURISM VANCOUVER'S ACCOUNTABILITY
Tourism Vancouver is responsible for all personal information under its control. The Tourism Vancouver Privacy Officer (the "Privacy Officer") is accountable for Tourism Vancouver's compliance with the principles described in this Policy, and may be contacted at:
The Privacy Officer
Suite 210-200 Burrard Street
Vancouver, BC V6C 3L6
Tourism Vancouver has established and implemented: (a) procedures to protect personal information; (b) procedures to receive and respond to complaints and inquiries; (c) employee and volunteer training and information programs to explain this Policy and related personal information protection procedures and practices; and (d) practices to ensure that clients and other individuals who contact Tourism Vancouver have access to this Policy and to other literature explaining Tourism Vancouver's related personal information protection practices and procedures.
PRINCIPLE 2 - THE PURPOSES FOR (AND THE MANNER IN WHICH) TOURISM VANCOUVER MAY COLLECT, USE OR DISCLOSE PERSONAL INFORMATION
Subject to applicable law, Tourism Vancouver will identify the purposes for which personal information is collected, used or disclosed before that information is collected, used or disclosed, as the case may be.
Applications for employment and volunteer positions
When a potential employee applies for employment, or a volunteering position, Tourism Vancouver collects personal information for the purpose of evaluating the applicant's suitability for the position with Tourism Vancouver.
Tourism Vancouver may undertake a background check of an applicant, in order to verify the accuracy of the information provided by the applicant and to obtain any relevant information not provided by the applicant. The background check will ordinarily include consulting previous employers or other personal references.
Tourism Vancouver may also require an applicant to undertake aptitude, vocational, technical, psychological or other tests, and the results of those tests may be collected and used by Tourism Vancouver.
Information is collected for the purpose of considering your employment with Tourism Vancouver. All information will be kept confidential and access to this information is limited, in accordance to the Personal Information Protection Act.
Unsolicited resumes and/or applications include resumes and/or applications submitted by e-mail, fax, in-person, and by any other means for the consideration of employment of non-advertised positions. Resumes received by Tourism Vancouver for non-advertised positions will not be retained. All resume copies will be permanently destroyed - electronic documents will be deleted and paper copies shredded.
Solicited applications and resumes received by Tourism Vancouver will be retained on file for a period of one (1) year from the date it was received. Subsequently, resumes retained after that period will be permanently destroyed - all electronic documents will be deleted and paper copies shredded. Due to the large volume of resumes received, only qualified applicants will be contacted should they be considered for an interview.
General Employment and Volunteer Purposes
Tourism Vancouver engages in many activities which require the collection of personal information from employees and volunteers, including payroll administration, general personnel record keeping, recruitment, selection and vacancy monitoring, employee appraisal, employee development and training, salary and benefit administration, leave of absence requests, employing and deployment, performance monitoring, data capture, health and safety administration and audit, security and access control, employee survey processing, and contingency planning.
Monitoring during employment
Tourism Vancouver may engage in the supervision of employees including: (a) the automated or discretionary electronic monitoring of e-mail, voice-mail messages, telephone communications, and other communications at the workplace; (b) the use of closed circuit television; (c) physical searches of Tourism Vancouver's premises, including offices, desks, filing cabinets, and other physical facilities; (d) surveillance or review of Internet use; and (e) inspection and review of all other recording and storage of communications occurring in the workplace.
E-mail: Employees should have no expectation of privacy in anything they create, store, send or receive by e-mail if they use computer facilities owned or provided by Tourism Vancouver. Employees are provided access to the computer network to assist them in the performance of their responsibilities. Accordingly, employees should not create, store, send or receive personal information by e-mail unless they wish it to be collected and used by Tourism Vancouver, which reserves the right to review and collect all information contained in e-mails, whether or not stored solely in personal folders on the computer operated by employee or volunteer. E-mail facilities are provided solely for business purposes.
Internet activity: Employees should have no expectation of privacy in their Internet activity if they employ computer facilities owned or provided by Tourism Vancouver, which reserves the right to examine all mechanisms including the browser disk cache, history log and cookies text files, which record use of the Internet. Employees are provided access to the computer network to assist them in the performance of their responsibilities. Tourism Vancouver may monitor chat and newsgroups, file downloads, and all communications sent and received by employees. Internet facilities are provided solely for business purposes.
Voice-mail messages: Employees should have no expectation of privacy in voice-mail messages left on facilities owned or provided by Tourism Vancouver. Recording and temporary or permanent electronic storage of voice mail messages are integral elements of the voice messaging system.
Other electronic recording and storage: The rapid evolution of new information technologies means Tourism Vancouver is likely to employ new electronic monitoring, recording and storage facilities from time to time. As a general rule, employees should not have an expectation of personal privacy in their use of such new technology if it is owned, operated or made available by Tourism Vancouver for their use in the workplace.
Disclosure to Affiliates, Agencies and Service Providers
Tourism Vancouver may transfer personal information to a third party for processing or to provide services, including third parties for whom Tourism Vancouver acts as a booking or reservations agent, but will use contractual or other means to provide a comparable level of protection while the information is in the custody of that third party.
From time to time, Tourism Vancouver may wish to use or disclose personal information for a purpose other than that for which it was initially collected. Tourism Vancouver will ensure that personal information is not used or disclosed for that new purpose unless the individual is informed of the new purpose and gives his or her consent.
PRINCIPLE 3 - CONSENT OR NOTICE
Subject to applicable legal exceptions, Tourism Vancouver makes a reasonable effort to ensure that employees and volunteers are advised in advance of the purposes for which their personal information will be collected, used or disclosed. To the extent required by applicable law, consent may be express or implied. Where consent is required and has been obtained, an employee or volunteer may withdraw his or her consent to collection, use or disclosure at any time, subject to legal or contractual restrictions and the provision of reasonable notice to Tourism Vancouver.
Tourism Vancouver obtains the consent of former employees and volunteers before providing personal references to potential or future employers those persons, except where Tourism Vancouver is required by law to make such disclosure without consent.
PRINCIPLE 4 - LIMITING COLLECTION
Tourism Vancouver limits the amount and type of personal information collected to that which is necessary for the purposes identified by Tourism Vancouver.
PRINCIPLE 5 - LIMITING USE, DISCLOSURE AND RETENTION
Tourism Vancouver does not use or disclose personal information of its employees or volunteers for purposes other than those for which it was collected, absent the provision of prior notice to the employees or volunteers, or as required or permitted by law. Personal information is retained only as long as necessary for the fulfillment of those purposes. Personal information that has been used by Tourism Vancouver to make a decision about an employee or volunteer will be retained long enough to allow the employee access to the information after the decision has been made. Tourism Vancouver has developed and implemented guidelines to govern the destruction of personal information, which is retained only as long as necessary for the identified purposes or as required by law.
PRINCIPLE 6 - ACCURACY
Tourism Vancouver aims to keep personal information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. However, Tourism Vancouver does not routinely update personal information, unless such updating is necessary to fulfill the purposes for which the information was collected. Tourism Vancouver generally relies upon employees and volunteers to provide updated information, such as changes to addresses and other contact information, and changed financial information.
If an employee or volunteer successfully demonstrates to Tourism Vancouver that personal information is inaccurate, incomplete, out of date, or irrelevant, Tourism Vancouver will revise the personal information. If necessary, Tourism Vancouver will disclose the revised personal information to third parties which were provided with the wrong information to permit them to revise their records as well.
PRINCIPLE 7 - SAFEGUARDS
Security safeguards are employed to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. The nature of the safeguards varies depending on the sensitivity of the personal information that has been collected; the amount, distribution, and format of the information; and the method of storage. More sensitive personal information is safeguarded at a higher level of protection. The methods of protection employed by Tourism Vancouver include: (a) physical measures, including locked filing cabinets and restricted access to offices; (b) organizational measures, such as security clearances and limiting access on a "need to know" basis; and (c) technological measures, such as the use of passwords and encryption. Tourism Vancouver uses care in the disposal or destruction of personal information, to prevent unauthorized parties from gaining access to the information.
PRINCIPLE 8 - OPENNESS
Tourism Vancouver strives to be open about its policies and procedures with respect to management of personal information. Tourism Vancouver makes this information available in a form that is generally understandable.
PRINCIPLE 9 - EMPLOYEE AND VOLUNTEER ACCESS
Upon receiving a request in writing from an employee or volunteer, Tourism Vancouver will inform that person of the existence, use, and disclosure of his or her personal information and that person will be given access to that information, except where the law requires or permits Tourism Vancouver to deny access. Tourism Vancouver may require the employee or volunteer to provide sufficient information to permit Tourism Vancouver to provide an account of the existence, use, and disclosure of personal information.
Tourism Vancouver will respond diligently to a proper request and in any case not later than 30 days after receipt of the request, unless that time is extended according to applicable law. As permitted by applicable law, certain charges may be applicable in respect of certain requests.
PRINCIPLE 10 - CHALLENGING COMPLIANCE
An employee or volunteer may direct a challenge concerning compliance with this Personal Information Protection Policy to the Tourism Vancouver Privacy Officer. Tourism Vancouver has established procedures to receive and to respond to complaints or inquiries about Tourism Vancouver's policies and practices relating to the handling of personal information. The complaint procedure will be easily accessible and simple to use.
Tourism Vancouver will investigate all complaints. If Tourism Vancouver finds that a complaint is justified, Tourism Vancouver will take appropriate measures, including, if necessary, amending its policies and practices.