INTRODUCTION
ASPECT is an association of community-based trainers that represents and
promotes the interests and activities of members to strengthen their capacity to
provide services to people with barriers to employment.
This Privacy Code sets out our privacy commitment to the protection of personal
information of our employees, and personal information obtained through
contractual arrangements with service providers and with the Province of British
Columbia.
This Privacy Code is intended to assist us to meet our obligations under the
Freedom of Information and Protection of Privacy Act(.FOI.) arising from our
contractual agreements with the Province of British Columbia as well as our
obligations respecting the personal information of our employees and service
providers regarding the new Personal Information Protection Act (.PIPA.).1
The Privacy Code is also intended to provide open and transparent principles,
policies, practices and procedures by which ASPECT can meet its privacy
commitment to the protection of personal information of its employees and for
personal information received from our service providers and the Province of
British Columbia. It is also intended to set out the choices available for
individuals regarding our collection, use or disclosure of their personal
information.
The purpose of this Privacy Code is to articulate clearly our privacy practices
respecting the management of personal information collected and used by
ASPECT and to ensure compliance with the federal and provincial privacy laws.
At the same time, it recognizes the needs of ASPECT to collect, use or disclose
personal information versus the right of individuals to protect their personal
information. The standard for the collection of personal information by ASPECT
is one of what a reasonable person would consider appropriate in the
circumstances.
1 This Privacy Code is built on the ten principles of the Canadian Standards Association (CSA)
Model Code for the Protection of Personal Information which was published in March 1996 as a
National Standard of Canada Federal and these principles are now incorporated in both the
federal Personal Information Protection and Electronic Documents Act and the British Columbia
Personal Information Protection Act
2
DEFINITIONS
The following definitions under FOI and PIPA are intended to provide clarity
regarding the breadth and scope personal information protected by our privacy
policies and practices.
FOI Definitions
.personal information. means recorded information about an identifiable
individual.
PIPA Definitions
.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 email or business fax number of
the individual
.employee personal information. means personal information about an
individual that is collected, used or disclosed solely for the purposes reasonably
required to establish, manage or terminate an employment relationship between
the organization and that individual, but does not include personal information
that is not about an individual.s employment.
.organization. means a person, an unincorporated association, a trade union, a
trust or a not for profit organization, but does not include:
(a) an individual acting in a personal or domestic capacity or acting as an
employee;
(b) a public body;
(c) the Provincial Court, the Supreme Court or the Court of Appeal;
(d) the Nisga.a Government, as defined in the Nisga.a Final Agreement or
(e) private trust for the benefit of one or more designated individuals who
are friends or members of the family of the settlor.
.personal information. means information about an identifiable individual and
includes employee personal information but does not include contact information
or work product information.
.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 the individual who did
not prepare or collect the personal information.
3
GUIDING PRINCIPLES
The following ten principles are the basis of ASPECT Privacy Code and shall
guide ASPECT.s management of personal information and its privacy practices
together with the statutory requirements of the FOI and PIPA.
1. Accountability . ASPECT is responsible for personal information under its
control including personal information not in the custody of ASPECT. ASPECT
shall designate one or more individuals to be responsible for ensuring that
ASPECT complies with this Privacy Code and shall make the position name or
title and contact information of each individual so designated.
2. Identifying Purposes for Collection of Personal Information . ASPECT
shall identify the purposes for which personal information is collected or before
personal information is collected.
3. Obtaining Consent for Collection, Use or Disclosure of Personal
Information . ASPECT shall ensure that consent is obtained from each individual
for the collection, use or disclosure of their personal information unless
inappropriate. ASPECT shall recognize and act on any withdrawal of consent by
an individual to collect their personal information.
4. Limiting Collection of Personal Information . ASPECT shall limit the
collection of personal information to the purposes identified by ASPECT and shall
only collect personal information using appropriate, fair and lawful means.
5. Limiting Use, Disclosure and Retention o f Personal Information . ASPECT
shall not use or disclose personal information for purposes other than for the
purpose it was collected unless ASPECT has the consent of the individual or as
provided by law. ASPECT shall retain personal information for only as long as
necessary to meet the purposes of the collection of the personal information.
6. Accuracy of Personal Information . ASPECT shall ensure that personal
information collected, used and disclosed shall be as accurate, complete and upto
date as possible for the purposes for which it has been collected used and
disclosed.
7. Security Safeguards . ASPECT shall take all appropriate steps to protect
the personal information collected, used and disclosed and use security
measures appropriate to sensitivity of the personal information.
8. Openness Concerning Policies and Practices .ASPECT shall ensure that
information is made available to employees and customers regarding this Privacy
Code and our privacy practices regarding personal information.
4
9. Customer and Employee Access to Personal Information . ASPECT shall
inform an individual of the collection, use and disclosure of his/her personal
information at the individual.s request and shall grant access to the individual to
such personal information. An individual shall be entitled to challenge the
accuracy and completeness of the personal information collected, used or
disclosed by ASPECT and have it amended and or corrected as necessary or
appropriate.
10. Challenging Compliance - This Privacy Code and our privacy practices
shall include a clear process for responding to complaints that may arise with
respect to our handling and managing of personal information of customers and
employees. A customer or employee may make a complaint regarding
ASPECT.s compliance with its privacy policies and practices to the designated
individual in accordance with our complaint process.
APPLICATION OF THE PRIVACY CODE
1.1 Although ASPECT is not a local public body or a public body listed under
FOI, under the terms of its contractual agreement(s) with the Province of British
Columbia, ASPECT is required to comply with FOI with respect to personal
information of individuals collected or provided to ASPECT in the course of the
provision of services. This means that ASPECT is required to assist the
Province of British Columbia to comply with its statutory obligations under FOI in
accordance with the terms and conditions of its agreement with the Province of
British Columbia.
1.2 Where ASPECT is required to collect, use and disclose personal
information in accordance with FOI, the following specific practices and
procedures of this Privacy Code as set out in Schedule A shall apply and shall
form part of this Privacy Code.
1.3 ASPECT also meets the definition of organization for the purposes of the
PIPA and therefore this Privacy Code sets out ASPECT.s policies and practices
for managing personal information of individuals being collected, used and
disclosed from our employees and services providers whether collected, used or
disclosed orally, electronically or in writing in compliance with PIPA.
1.4 This Privacy Code does not apply to the following prescribed sources of
public information:
(a) an individual.s name, address, telephone number and other
personal information that appears in a telephone director or is
available through Directory Assistance provided the directory or
directory assistance is available to the public and the individual can
refuse to have their personal information included the directory or
made available by directory assistance;
5
(b) an individual.s personal information that appears in a professional
or business directory, listing or notice available to the public and the
individual can refuse to have such personal information included in
the directory;
(c) an individual.s personal information appearing in a registry in which
the public has access provided such personal information is
collected by an appropriate authority in accordance with municipal,
provincial or federal laws;
(d) an individual.s personal information appearing in a printed or
electronic publication available to the public, such as a magazine,
book or newspaper in printed or electronic form.
PRIVACY POLICIES AND PRACTICES
Accountability
2.1 All personal information received from the Province of British Columbia or
its service providers arising from its contractual agreement(s) is subject to
compliance with the FOI provisions of this Privacy Code. Schedule A of the
Privacy Code sets out ASPECT.s specific practices and procedures regarding
personal information that is subject to FOI.
2.2 In order to meet its responsibilities for personal information under its
possession or control, ASPECT appoints the Projects' Director and or his/her
designate to be accountable for ASPECT.s compliance with this Privacy Code
and its statutory requirements under PIPA. The Projects' Director and or his/her
designate may appoint one or more persons to act on their behalf with respect to
the responsibility for day-to-day management, collection and processing of
personal information.
2.3 The contact information of persons designated to be accountable for
ASPECT.s compliance with the Privacy Code shall be made known upon
request.
2.4 ASPECT does not currently provide any other personal information to third
parties as set out in PIPA. In the event, that ASPECT does provide personal
information to third parties, ASPECT shall ensure that such third parties have
policies and practices in place that provide similar or comparable protection for
personal information as ASPECT.
2.5 ASPECT shall put in place procedures and practices to give effect to this
Privacy Code and shall include:
6
2.5.1 Procedures and practices to protect personal information and to
oversee compliance with this Privacy Code;
2.5.2 Procedures and practices to receive and respond to requests for
personal information, inquiries and complaints under FOI and PIPA;
2.5.3 Methods and means for training and communicating our privacy
procedures and practices to employees; and
2.5.4 Methods and means for communicating our privacy procedures and
practices to our service providers and the public.
2.6 ASPECT shall continue to update and enhance its privacy policies and
practices on an as and when basis.
Purposes of Collection
3.1 ASPECT collects, uses and discloses personal information from
individuals, members, employees and subcontractors only for the following
purposes:
3.1.1 To perform its contractual obligations to the Province of British
Columbia for the term of the agreement(s) such as keeping records
of program participants for meeting reporting requirements;
3.1.2 To meet, maintain, monitor and regulate contractual obligations
with subcontractors for the term of such agreement(s) such as
paying milestone payments to subcontractors;
3.1.3 To meet terms, conditions and obligations of employment to our
employees such as for benefit and payroll administration; and
3.1.4 To promote ASPECT programs to its members and the public.
3.2 In using and disclosing personal information as part of its contractual
agreement(s) with the Province of British Columbia, such personal information
shall only be collected, used and disclosed as necessary for the performance of
ASPECT.s contractual obligations to the Province of British Columbia in
accordance with FOI requirements set by the Province of British Columbia.
3.3 ASPECT also collects uses and discloses personal information of its
employees or services providers but such personal information shall only be
collected, used and disclosed for purposes that a reasonable person would
consider appropriate in the circumstances and that fulfill the purposes that
ASPECT has disclosed to the individual in accordance with PIPA.
3.4 ASPECT shall identify and specify orally, electronically or in writing to the
employee or service provider the purposes for which personal information is
collected, used and disclosed at or before the time the personal information is
collected.
7
3.5 Designated persons collecting personal information on behalf of ASPECT
shall upon request advise an individual of the purposes for such collection or
refer the individual to the Projects' Director and or his/her designate to provide an
explanation.
3.6 ASPECT shall not collect, disclose or use personal information for any
purpose not identified or specified to an individual without obtaining their consent.
Consent
4.1 Subject to the specific provisions of Schedule A for personal information
collected pursuant to FOI, 1.4 above and 4.3 below, ASPECT will obtain consent
from an individual when collecting, using or disclosing personal information of its
individuals, employees, members and subcontractors for the purposes outlined
above.
4.2 Consent may be explicit (orally or in writing) or implied. Consent may be
implied by ASPECT where at the time consent is deemed as follows:
4.2.1 the purpose would be considered obvious to a reasonable person;
4.2.2 the individual has voluntarily provided the personal information for that
purpose; or
4.2.3 ASPECT has given notice of the collection of personal information for a
specified period in a form that can be reasonably understood of its
intention to collect, use or disclose the personal information and the
individual is given a reasonable period of time to decline and does not
decline and it is reasonable to collect, use or disclose provided you
assess that the sensitivity of the information is such that implied
consent will suffice.
4.3 Consent is not required for the following personal information which is
permitted to be collected and used from an individual or from a source other than
an individual without limitations:
4.3.1 is clearly in the interest of the individual and consent cannot be
obtained in a timely way;
4.3.2 is necessary for medical treatment of the individual and individual is
unable to give consent;
4.3.3 it is reasonable to expect that the collection or use with the consent of
individual would compromise the availability or accuracy of the
personal information and the collection is reasonable for an
investigation or a proceeding;
4.3.4 where collection or use occurs by observation at a performance, a
sports meet or a similar event at which individual voluntarily appears
and is open to the public;
8
4.3.5 is necessary to determine individual.s suitability to receive an honour,
award or similar benefit such as honorary degree, scholarship or
bursary or selected for an athletic or artistic purpose;
4.3.6 organization is credit reporting agency and collection is for a credit
report and individual consents at the time the original collection occurs;
4.3.7 is required or authorized by law;
4.3.8 personal information is necessary to facilitate collection of debt owed
or payment of debt to an organization; and
4.3.9 collection or use of employee personal information is reasonable for
establishing, managing or terminating an employment relationship
4.4 With respect to the disclosure o f personal information, ASPECT shall
obtain consent from the individual, with the exception of the following personal
information which is permitted to be disclosed from an individual or from a source
other than an individual without limitations:
4.4.1 is clearly in the interest of the individual and consent cannot be
obtained in a timely way;
4.4.2 is necessary for medical treatment of the individual and individual is
unable to give consent;
4.4.3 it is reasonable to expect that the disclosure with the consent of
individual would compromise the availability or accuracy of the
personal information and the collection is reasonable for an
investigation or a proceeding;
4.4.4 where disclosure occurs by observation at a performance, a sports
meet or a similar event at which individual voluntarily appears and is
open to the public;
4.4.5 is necessary to determine individual.s suitability to receive an honour,
award or similar benefit such as honorary degree, scholarship or
bursary or selected for an athletic or artistic purpose;
4.4.6 organization is credit reporting agency and disclosure is for a credit
report and individual consents at the time the original collection occurs;
4.4.7 is required or authorized by law;
4.4.8 personal information is necessary to facilitate collection of debt owed
or payment of debt to an organization;
4.4.9 personal information is disclosed in accordance with a provision of a
treaty that authorizes or requires its disclosure or is made under an
enactment of BC or Canada;
4.4.10 disclosure is for the purpose of complying with a subpoena, warrant or
order issued or made by a court, person or body with jurisdiction to
compel the production of personal information;
4.4.11 the disclosure is to a public body or a law enforcement agency in
Canada, concerning an offence under the laws of Canada or a
province, to assist in an investigation, or in the making of a decision to
undertake an investigation;
9
4.4.12 there are reasonable grounds to believe that compelling circumstances
exist that affect the health and safety of any individual and if notice of
disclosure is mailed to the last known address of the individual to who
the personal information relates;
4.4.13 the disclosure is for the purpose of contacting next of kin or a friend of
an injured, ill or deceased individual;
4.4.14 the disclosure is to a lawyer who is representing the organization;
4.4.15 the disclosure is to an archival institution if the collection of personal
information is reasonable for research or archival purposes; and
4.4.16 disclosure of employee personal information is reasonable for
establishing, managing or terminating an employment relationship.
4.5 When obtaining consent from an individual, employee or service provider,
ASPECT shall use reasonable efforts to ensure that the individual is advised and
reasonably understands the purpose for which the personal information is being
collected, used or disclosed.
4.6 Wherever possible, ASPECT shall seek consent to collect, use or disclose
personal information from an individual, employee or service provider at the time
in which the personal information is collected. In the event that this is not
possible, ASPECT will seek consent after the personal information is collected
but prior to it being used or disclosed for a different purpose that has not been
identified or specified.
4.7 When determining whether express or implied consent is required,
ASPECT shall take into account the sensitivity of the personal information and
the reasonable expectations of the individual, employee or service provider.
4.8 ASPECT will, generally, imply consent to collect, use or disclose personal
information for its purposes, where an employee accepts employment or receives
benefits.
4.9 When seeking consent for the collection of personal information from an
individual, employee or service provider, ASPECT shall set out the choices
available to individuals regarding ASPECT. collection, use or disclosure of the
personal information at the time of collection or prior to the use or disclosure of
such personal information.
4.10 Upon obtaining consent, ASPECT shall record such consent such as via
phone, by mail, the Internet, a note to file, copy of an email, copy of a check off
box or entry in database field.
Withdrawal of Consent
5.1 ASPECT will honour a request of an individual to withdraw its consent to
the collection, use or disclosure of personal information where it receives
10
reasonable notice and stop collecting, using or disclosing that personal
information unless it meets one of the exceptions noted above or would frustrate
the performance of a legal obligation or consent was given to a credit reporting
agency.
Limiting Collection of Personal Information
6.1 When collecting personal information of an individual, employee, member
or subcontractor, ASPECT shall disclose to the individual verbally or in writing,
the purposes for the collection of the personal information and shall limit the
collection to the identified and specified purposes.
6.2 ASPECT shall only collect personal information by reasonable, fair and
lawful means.
6.3 ASPECT, generally, collects personal information from the Province, its
employees or service providers although in certain circumstances, ASPECT may
collect personal information from third parties, such as credit bureaus, employers
or personal references but only from those third parties that represent that they
have a right to disclose such personal information.
Limiting Use, Disclosure and Retention of Personal Information
7.1 Other than where ASPECT has consent of the individual or by operation of
law, ASPECT shall not use or disclose personal information for purposes other
than those identified and specified.
7.2 ASPECT shall only retain personal information of an individual for the
period necessary to fulfill the purposes identified and specified, by operation of
law or where making a decision regarding employees or subcontractors as long
as is reasonable to give individuals, members, employees or subcontractors the
opportunity to access the personal information concerning the making of the
decision.
7.3 ASPECT shall limit the access of its employees to personal information to
those who are participating in the collection, use or disclosure of personal
information as part of their duties or to those who have a need to know within
ASPECT.
7.4 ASPECT shall maintain the means via reasonable controls, systems and
practices whereby personal information that no longer is necessary to retain is
destroyed, erased or rendered anonymous.
Accuracy and Security of Personal Information
11
8.1 ASPECT shall make all reasonable effort to ensure that personal
information collected is accurate and complete for the purposes in which it is
collected particularly where the personal information is likely going to affect the
individual to who the personal information relates or is likely to be disclosed to
another organization.
8.2 All personal information used by ASPECT shall be as accurate and
complete as possible and where such personal information is being used to
make a decision that directly affects an individual, such personal information
shall be retained by ASPECT for one year in order to provide a reasonable
opportunity for access by the individual.
8.3 ASPECT shall take reasonable security arrangements to prevent the
unauthorized access, collection, use, disclosure, copying, modification or
disposal of personal information in its custody and control in whatever form it is
held. Such security arrangements shall include protection from loss or theft and
physical measures, such as locking filing cabinets, restricting access to offices
and alarm systems, technological tools, such as passwords, encryption, firewalls
and anonymizing software, and organizational tools, such as security clearances,
limiting access on a need to know basis, staff training and confidentiality
agreements.
8.4 ASPECT shall destroy its documents containing personal information or
remove the means by which personal information can be associated with the
individual as soon as the purpose for which the personal information was
collected is no longer being served by its retention or retention is no longer
necessary for legal or business purposes.
8.5 ASPECT shall not use deceptive or coercive means to collect personal
information and shall not dispose of personal information with intent to evade a
request for access to personal information.
8.6 ASPECT shall protect personal information by ensuring that confidentiality
provisions bind both third parties in which personal information is disclosed and
employees who have access to personal information.
8.7 ASPECT shall regularly review and update security measures for personal
information where applicable.
Access to and Correction of Personal Information
9.1 Where ASPECT has personal information in its control or custody arising
from its contractual obligations to the Province of British Columbia, an individual
shall have the right to access and correct their personal information in
accordance with the provisions of Schedule A.
12
9.2 Where ASPECT has collected, used or disclosed personal information of
an individual that is within the statutory authority of PIPA, an individual shall have
the right to access and correct their personal information in accordance with the
following access and correction procedure:
9.2.1 the individual may, in writing, make a request to the Projects'
Director of ASPECT or his/her designate concerning his or her
personal information under the control of ASPECT;
9.2.2 ASPECT shall provide information concerning the ways in which
personal information of the individual has been and is being
used by ASPECT or has been disclosed by ASPECT;
9.2.3 the names of individuals and organizations to whom the
personal information has been requested;
9.2.4 With the exception of the following personal information,
ASPECT will provide access to an individual.s personal
information:
(i) personal information is protected by solicitor-client privilege;
(ii) disclosure would reveal confidential commercial information
that if disclosed could in the reasonable opinion of a reasonable
person harm the competitive position of ASPECT;
(iii) personal
information was collected where consent is not required for the
purposes of an investigation or where proceedings have not
been completed;
(iv) where personal information was collected
by a credit organization 12 months prior to the request from the
individual;
(v) where the disclosure would threaten the safety,
physical or mental health of an individual, cause immediate or
grave harm to the safety or physical or mental health of an
individual, or would reveal personal information about another
individual;
9.2.5 having reviewed the personal information requested, the
individual may request ASPECT to correct an error or omission
in that personal information that is:
(i) about the individual and
(ii) is under the control of ASPECT;
9.2.6 ASPECT shall respond to an individual.s request no later than
30 days from the date of an individual.s request unless the
individual has not given sufficient detail to enable ASPECT to
identify the personal information being requested or more time
is needed given the large volume of personal information being
requested which would unreasonably interfere with ASPECT.
operation or there is a need for more time to consult with
another organization or public body to determine whether to
give access to the requested document. In those
circumstances, ASPECT may extend the time an additional 30
days or seek a longer period of time to respond from the privacy
commissioner and will advise the individual of the extension in
13
time, the time period of the extension and the rights of the
individual to complain about the extension;
9.2.7 In responding to an individual.s request, ASPECT shall advise
the individual when access to personal information in whole or
in part is being refused, the reasons for the refusal and the
contact information of the officer or employee of ASPECT who
can answer the individual.s questions concerning the refusal;
9.2.8 ASPECT shall make a reasonable effort to assist each applicant
to respond accurately and completely as is reasonably possible
to their request;
9.2.9 ASPECT shall make the correction as soon as reasonably
possible or send the corrected personal information to each
organization which the personal information was disclosed
during the year prior to the date the correction was made, where
ASPECT is satisfied that there are reasonable grounds for the
request;
9.2.10 Where ASPECT does not make a correction it shall annotate
the personal information under its control that a request was
made but the request was not implemented.
Challenging Compliance
10.1 With the exception of the application of Schedule A to personal
information that is subject to FOI, ASPECT shall maintain a process for
addressing and responding to complaints or inquiries regarding its compliance
with this Privacy Code including where appropriate a process for seeking
external advice prior to responding to individual complaints or inquiries.
10.2 An individual, employee, member or subcontractor may make a complaint
or inquiry regarding ASPECT.s compliance with this Privacy Code as follows:
10.2.1 An individual shall file a written complaint or inquiry to the Projects'
Director of ASPECT and or his/her designate outlining the failure of
ASPECT to comply with this Privacy Code and the specified section
and or principle.
10.2.2 ASPECT shall investigate all written complaints or inquiries
regarding its compliance with this Privacy Code.
10.2.3 Where an investigation determines that a complaint is justified or
action is required regarding an inquiry, ASPECT shall take all
appropriate steps to resolve the complaint or take appropriate
action to address the inquiry including where applicable amending
the policies, practices and procedures of this Privacy Code.
10.2.4 Wherever possible, ASPECT shall respond to a written complaint
within 30 days provided the written complaint or inquiry provides
sufficient information to respond to. This response shall include
14
details regarding the outcome of the investigation and individual.s
complaint or inquiry.
10.2.5 In the event that ASPECT seeks external advice, the period to
respond may be extended for a reasonable period necessary to
obtain such external advice.
10.3 In the event that an individual is not satisfied with handling of its complaint
by ASPECT, the individual may seek the assistance of the BC Privacy
Commissioner. The contact information for the Privacy Commissioner may be
found at: www.mser.gov.bc.ca/foi_pop/
Transparency of Privacy Policies, Practices and Procedures
11.1 ASPECT shall make its privacy policies, practices and procedures
available on its website and readily available to individuals in person, in writing,
by telephone or as applicable in ASPECT publications.
11.2 ASPECT shall also make its policies, practices and procedures
understandable for its individuals, members, employees, subcontractors and the
public by identifying who within ASPECT is responsible for compliance with this
Privacy Code, how personal information can be accessed by individuals, what
personal information is held by ASPECT and how it is used.
The contact information for the Project Director of ASPECT is as follows:
Sandra Glass, Project Director
sglass@aspect.bc.ca
(250) 382-9675
Current contact information can also be found on ASPECT.s website at
www.aspect.bc.ca.
For further information on ASPECT. Privacy Code, practices and procedures,
contact (Sandra Glass) (250) 382-9675. To review the BC Freedom of
Information and Protection of Privacy Act and Personal Information Protection
Act, access to the Act can be found at www.mser.gov.bc.ca/foi_pop/
15
SCHEDULE A . SPECIFIC PRACTICES AND PROCEDURES UNDER FOI
ASPECT, as a contractor for the Province of British Columbia has a contractual
obligation to comply with the provisions of the Freedom of Information and
Protection of Privacy Act (.FOI.) when collecting, using or disclosing personal
information in accordance with the terms of its agreement(s) with the Province of
British Columbia.
In order to comply with these requirements, ASPECT has incorporated the
following specific practices and procedures as part of its Privacy Code and shall
adhere to these specific practices and procedures when collecting, using and
disclosing personal information as a result of the performance of their contractual
obligations to the Province of British Columbia:
Collection of Persona Information
1. Unless otherwise specified or directed in writing by the Province of British
Columbia, ASPECT shall only collect, use or disclose personal information of
individuals that is necessary to perform their obligations or exercise their rights
under the agreement(s) with the Province of British Columbia.
2. Unless otherwise specified or directed in writing by the Province of British
Columbia, ASPECT shall collect personal information directly from the individual.
3. Unless otherwise specified or directed in writing by the Province of British
Columbia, when collecting personal information from an individual pursuant to
their contractual obligations with the Province of British Columbia, ASPECT shall
advise the individual of the purpose of collection, the legal authority for collecting
it and the title, business address, and business telephone of the person
designated by the Province of British Columbia to answer questions regarding
ASPECT.s collection of the individual.s personal information.
Accuracy of Personal Information
4. ASPECT shall make every reasonable effort to ensure the accuracy and
completeness of any personal information used by ASPECT in the performance
of their contractual obligations with the Province of British Columbia to make a
decision that directly affects the individual that the personal information is about.
Access to Personal Information
5. Unless the agreement(s) with the Province expressly provides otherwise,
in the event that ASPECT receives a request for access to personal information
from a individual other than the Province of British Columbia, ASPECT shall
promptly advise the individual to make the request to the Province and where the
16
Province has provided the appropriate title and contact information the official
responsible for handling such requests, ASPECT shall also provide such contact
information to the individual.
Correction of Personal Information
6. Upon receiving written direction from the Province, ASPECT shall correct
or annotate the personal information of an individual in accordance with the
written direction within 5 business days of receiving the direction.
7. Upon receiving written direction from the Province to correct and annotate
personal information, within one year after correcting or annotating such personal
information, ASPECT shall provide the corrected or annotated information to any
party to whom ASPECT disclosed the personal information that was corrected or
annotated.
8. In the event that ASPECT receives a request for correction of personal
information from a individual other than the Province of British Columbia,
ASPECT shall promptly advise the individual to make the request to the Province
and where the Province has provided the appropriate title and contact
information the official responsible for handling such requests, ASPECT shall
also provide such contact information to the individual.
Protection of Personal Information
9. ASPECT shall protect personal information collected, used and disclosed
as a result of their contractual obligations with the Province of British Columbia
by making reasonable security arrangements against such risks as unauthorized
access, collection, use, disclosure or disposal.
Retention of Personal Information
10. ASPECT shall retain personal information collected, used and disclosed
as a result of their contractual obligations with the Province of British Columbia
until directed in writing by the Province of British Columbia to dispose of it or
deliver it as specified in writing by the Province of British Columbia.
Use of Personal Information
11. ASPECT shall only use collected, used and disclosed as a result of their
contractual obligations with the Province of British Columbia for the performance
of its obligations or exercise of its rights under its agreement(s) with the Province
of British Columbia.
