NOVA SCOTIA FIREFIGHTERS BURN TREATMENT SOCIETY (NSFFBTS)

 PRIVACY POLICY

       
Purpose of this Policy      
1.    Privacy of personal information is governed by the Personal Information Protection and Electronics Documents Act ("PIPEDA").  This policy describes the way that NSFFBTS collects, uses, retains, safeguards, discloses and disposes of personal information, and states its commitment to collecting, using and disclosing personal information responsibly.   This policy is based on the standards required by PIPEDA, and interpretation of these responsibilities.
       
       
Background      
2 .   Our organization, (NSFFBTS), is the governing body for the Camp Connect and provides these services to members and the public:
  NSFFBTS is the governing body whose purpose is to initiate, regulate, manage and communicate the programs, services and event that promote participation and excellence in Camp Connect , Burn and Fire Fighter related activities.
       
       
Personal Information      
3.    Personal information is information about an identifiable individual.  Personal information includes information that relates to their personal characteristics (e.g., gender, age, income, home address or health services received by them) or their activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual).  Personal information, however, does not include business information (e.g., an individual's business address and telephone number), which is not protected by privacy legislation.
       
       
Accountability      
4.    Nora-Gene Goodwin is the Privacy Officer and is responsible for monitoring information collection and data responsibilities.  The Privacy Officer also handles personal information access requests and complaints.  The Privacy Officer may be contacted at the following address:
       
    Privacy Officer
Post Office Box 481
Dartmouth Main
Dartmouth, Nova Scotia
B2Y 3Y8
 
       
       
Purpose      
5.    Personal information will only be collected by Camp Connect to meet and maintain the highest standard of organizing and programming.  Camp Connect collects personal information from prospective members, campers, councilors, firefighter participants, nursing managers and volunteers for purposes that include, but are not limited to the following:
               
    a) Name, address, phone number, cell phone number, fax number and e-mail address for purpose of communicating about Camp Connect programs, events and activities.
               
    b) Education, resumes and experience for database entry at the councilor level. To determine level of certification and qualifications.
       
    c) Credit card information for registration at conferences, travel administration, and purchasing equipment, manuals and other products and resources.
       
    e) Criminal records check, resume, NSFFBTS, Camp Connect for insurance
       
    f) Criminal records check and related personal reference information for the purpose of implementing NSFFBTS volunteer screening program.
       
    g) Personal health information including provincial health card numbers, allergies, emergency contact and past medical history for use in the case of medical emergency.
       
    h) Information including height, weight, size, feedback from parents and teachers and performance results for registration forms
       
    i) Whereabouts information including discipline, camp dates and locations, travel plans and disability, if applicable.
       
    j) Body weight.
       
    k) Passport numbers and Aeroplan/frequent flyer numbers for the purposes of arranging travel.
       
    l) Name, address, phone number, cell phone number, fax number and e-mail address for the purpose of providing insurance coverage, managing insurance claims and conducting insurance investigations.
       
6.    If a purpose has not been identified herein, NSFFBTS will seek consent from individuals when personal information is used for a purpose not already consented to.   This consent will be documented as to when and how it was received.
       
       
Consent      
7.    Consent is required to be obtained by lawful means from individuals at the time of collection, prior to the use or disclosure of the personal information.  If the consent to the collection, use or disclosure was not obtained upon receipt of the information, consent will be obtained prior to the use or disclosure of that information.  NSFFBTS may collect personal information without consent where reasonable to do so and where permitted by law.
   
 8.     By providing personal information to NSFFBTS, individuals are consenting to the use of the information for the purposes identified in this policy.
   
9.     NSFFBTS will not, as a condition of a product or service, require an individual to consent to the collection, use or disclosure of information beyond that required to fulfill the specified purpose.
   
10.   An individual may withdraw consent to the collection, use or disclosure of personal information at any time, subject to legal or contractual restriction, provided the individual gives notice of such withdrawal to NSFFBTS.  The Privacy Officer will work with the individual to ensure withdrawal.
   
   
Limiting Collection  
11.   All personal information will be collected fairly, by lawful means and for the purposes as specified in this policy.  NSFFBTS will not use any form of deception to obtain personal information.
   
   
Limiting Use, Disclosure and Retention  
12.   Personal information will not be used or disclosed by NSFFBTS for purposes other than those for which it was collected as described herein, except with the consent of the individual or as required by law
   
13.   Personal Information will be retained for certain periods of time in accordance with the following:
    
    a) Registration data and camper information will be retained for a period of three years after an individual has left a program of NSFFBTS, in the event that the individual chooses to return to the program;
       
    b) Parental/family information will be retained for a period of three years after an individual has left a program of NSFFBTS, in the event that the individual chooses to return to the program;
       
    c) Information collected by NSFFBTS will be retained for a period of three years after an individual has left a program of NSFFBTS, in the event that the individual chooses to return to the program.
       
    d) Employee information will be retained for a period of seven years in accordance with Canada Customs and Revenue Agency requirements.
       
    e) Personal health information will be retained for a period of 3 years  when an individual chooses to leave a program of NSFFBTS.
       
    f) Marketing information will be immediately destroyed upon compilation and analysis of collected information.
       
    g) As otherwise may be stipulated in federal or provincial legislation.
       
14.   Personal information that is used to make a decision about an individual will be maintained for a minimum of one year of time to allow the individual access to the information after the decision has been made.
   
15.   NSFFBTS may disclose personal information to a government authority that has asserted its lawful authority to obtain the information or where NSFFBTS has reasonable grounds to believe the information could be useful in the investigation of an unlawful activity, or to comply with a subpoena or warrant or an order made by the court or otherwise as permitted by applicable law.
   
16.   Documents will be destroyed by way of shredding and electronic files will be deleted in there entirely.  When hardware is discarded, NSFFBTS will ensure that the hard drive is physically destroyed.
   
   
Accuracy  
17.   NSFFBTS will use accurate and up-to-date information as is necessary for the purposes for which it is to be used, to minimize the possibility that inappropriate information may be used to make a decision about an individual.
   
   
Safeguards  
18.   Personal information is protected by security safeguards appropriate to the sensitivity of the information against loss or theft, unauthorized access, disclosure, copying, use or modification.
   
19.  

Methods of protection and safeguards include, but are not limited to, locked filing cabinets, restricted access to offices, security clearances, need-to-know access and technological measures including the use of passwords, encryption and firewalls.

   
20.   The following steps will be taken to ensure security:
       
    a) Paper information is either under supervision or secured in a locked or restricted area.
       
    b) Electronic hardware is either under supervision or secured in a locked or restricted area at all times.  In addition, passwords are used on computers.
       
    c) Paper information is transmitted through sealed, addressed envelopes or in boxes by reputable courier/delivery companies
       
    d) Electronic information is transmitted either through a direct line or is encrypted.
       
    e) Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with this policy.
       
    f) External consultants and agencies with access to personal information will provide NSFFBTS will appropriate privacy assurances.
   
   
Openness  
21.   NSFFBTS will publicize information about its policies and practices relating to the management of personal information.  This information is available through this policy, on NSFFBTS.
   
22.    The information available to the public includes:
       
    a) The name or title, address and telephone number of NSFFBTS's Privacy Officer.
       
    b) The forms that may be used to access personal information or change information.
       
    c) A description of the type of personal information held by NSFFBTS, including a general statement of its approved uses.
   
    
Individual Access  
23.   Upon written request, and with assistance from NSFFBTS, an individual may be informed of the existence, use and disclosure of his or her personal information and will be given access to that information.  As well, an individual is entitled to be informed of the source of the personal information along with an account of third parties to whom the information has been disclosed.
   
24.   Requested information will be disclosed to the individual within 30 days of receipt of the written request at no cost to the individual, or at nominal cost relating to photocopying expenses, unless there are reasonable grounds to extend the time limit.
   
25.   If personal information is inaccurate or incomplete, it will be amended as required.
   
26.   An individual may be denied access to his or her personal information if:
       
    a) This information is prohibitively costly to provide;
       
    b) The information contains references to other individuals;
       
    c) The information cannot be disclosed for legal, security or commercial proprietary purposes;
       
    d) The information is subject to solicitor-client or litigation privilege
   
27.   Upon refusal, NSFFBTS will inform the individual the reasons for the refusal and the associated provisions of PIPEDA.
   
   
Challenging Compliance  
28.   An individual my challenge NSFFBTS compliance with this policy and PIPEDA, by submitting a challenge in writing.
   
29.   Upon receipt of a written complaint, NSFFBTS will:
       
    a) Record the date the complaint is received;
       
    b) Notify the Privacy Officer who will serve in a neutral, unbiased capacity to resolve the complaint;
       
    c) Acknowledge receipt of the complaint by way of telephone conversation and clarify the nature of the complaint within three days of receipt of the complaint;
       
    d) Appoint an investigator using NSFFBTS personnel or an independent investigator, who will have the skills necessary to conduct a fair and impartial investigation, and who will have unfettered access to all files and personnel, with ten days of receipt of the complaint.
       
    e) Upon completion of the investigation and within 25 days of receipt of the complaint, the investigator will submit a written report to NSFFBTS.
       
    f) Notify the complainant of the outcome of the investigation and any relevant steps taken to rectify the complaint, including any amendments to policies and procedures, within 30 days of receipt of the complaint.