Vancouver College Limited (VCL)
OUR COMMITMENT TO PRIVACY
SCOPE OF POLICY
This Policy addresses personal information about individuals only; it does not apply to information collected, used or disclosed with respect to corporate or commercial entities. However, corporate and commercial information is protected by other VCL policies and practices and through contractual arrangements.
This Policy does not impose any limits on the collection, use or disclosure of the following information by VCL:
In this Policy:
"business contact information" means information to contact an individual at a place of business, including the individual's name, position, business telephone number, business address, business e-mail address and business fax number.
"collection" means the act of gathering, acquiring, or obtaining personal information from any source, including third parties, by any means.
"consent" means voluntary agreement to the collection, use and disclosure of personal information for specified purposes. Consent may be express or implied. Express consent may be given orally or in writing, if it is unequivocal and does not require any inference on the part of VCL. Implied consent exists when VCL can reasonably infer consent based upon your action or inaction.
"disclosure" means making personal information available to a third party.
"personal information" means information about an identifiable individual but does not include his or her business contact information. Personal information does not include information concerning corporate or commercial entities. It also does not include information that cannot be associated with a specific individual.
"privacy officer" means an individual designated by VCL who is accountable for compliance with this Policy by VCL and whose name and contact particulars are set forth at the end of this Policy.
"third party" means an individual or organization other than VCL and you.
"use" means the treatment and handling of personal information by and within VCL.
"Vancouver College" means the private Catholic school for boys which operates classes from kindergarten to grade 12 inclusive at 5401 Hudson Street, Vancouver, BC.
VCL is accountable and responsible for personal information under its control. VCL has designated a privacy officer to ensure compliance with this Policy.
Ultimate accountability for VCL compliance rests with the VCL's Board of Directors who delegates day-to-day accountability to the privacy officer. Other individuals within VCL may be accountable for the day-to-day collection and processing of personal information or may act on behalf of the privacy officer.
VCL will adopt procedures to protect personal information, receive and respond to complaints and inquiries, train staff regarding privacy policies and procedures and communicate policies and procedures to you.
When collecting information, VCL will state the purpose of collection and will provide, on request, contact information for the privacy officer who can answer questions about the collection.
VCL may collect your personal information for the following purposes: The above collections, uses and disclosures are a reasonably necessary part of your relationship with VCL. When your personal information is to be used for a purpose not previously identified, the new purpose will be disclosed to you prior to such use, and your consent will be sought unless the use is authorized or required by PIPA or other law.
a. to assess applications for admission to (or continued enrolment in) Vancouver College by prospective students or students through their parents or guardians;
b. to determine the financial status (including through credit reports) of parents or guardians for admission or continued enrolment of students;
c. to provide and administer services through Vancouver College;
d. to disclose to the Vancouver College Parents' Association for the purpose of coordinating their activities from time to time, which are directly or indirectly beneficial to Vancouver College;
e. to disclose to the those administering the Parent Participation Program for the purposes of such Program from time to time;
f. to disclose grades, as required, to the BC Ministry of Education;
g. to disclose grades (with permission from the student) to the Ministry of Education for disclosure to prospective universities;
h. to disclose information requested by third parties (with permission of Parents/Guardians);
i. to protect VCL, you and others from fraud and error and to safeguard the interests of VCL and its students, staff and representatives;
j. to authenticate your identity;
k. to collect debts owed by you to VCL;
l. to ensure staff and contractors comply with their agreements and legal obligations to VCL;
m. to manage or transfer assets or liabilities of VCL, for example in the case of an acquisition or merger, the provision of security for a credit facility or the change of a supplier of products;
n. to administer relations with the BC Ministry of Education, the Federation of Independent Schools of BC, the Catholic Independent Schools of Greater Vancouver and other educational organizations with whom VCL has relations from time to time;
o. to use and disclose for any other purpose directly or indirectly related to establishment or operation of Vancouver College Limited and Vancouver College Millennium Foundation.
p. to directly or indirectly collect photographs and/or video recordings of students (in print and in electronic format), for the purposes reasonably related to VCL operations including communicating school news including through social media platforms, for making and communicating promotional videos, and for inclusion on the VCL website. This also covers any such photographs or videos taken by television or print media in respect of the coverage of VCL related events.
q. VCL may use your personal information to contact you regarding special events, fundraising and other matters in which it is involved, directly or indirectly, from time to time.
r. to comply with any legal or regulatory requirement; and
s. VCL may share your personal information with the Vancouver College Alumni Association, so that they may solicit your membership or assistance.
VCL will obtain your consent to collect, use or disclose personal information except where VCL is authorized or required by law to do so without consent. For example, VCL may collect, use or disclose personal information without your knowledge or consent where: Your consent may be express or implied, or given through an authorized representative such as a lawyer, agent or broker. If you are under the age of majority, your consent may be obtained from a parent or guardian.
Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify VCL that you do not wish your personal information collected/used/disclosed for optional purposes following reasonable notice to you) or otherwise. For example, oral consent could be expressed over the telephone when information is being collected; electronically when submitting an agreement, application or other information; or in writing when signing an agreement or application.
You may withdraw your consent at any time, subject to legal or contractual restrictions, provided reasonable written notice of withdrawal of consent is given by you to VCL. Upon receipt of your written notice, VCL will inform you of the likely consequences of the withdrawal, which may include the inability of VCL to provide certain products or services for which the delivery of that information is a prerequisite.
VCL is collecting or paying a debt;
VCL is obtaining legal advice; or
VCL reasonably expects that obtaining consent would compromise an investigation or proceeding.
4. LIMITS ON COLLECTION OF PERSONAL INFORMATION
VCL will not collect personal information indiscriminately and will limit its collection of your personal information to what is reasonably necessary to provide a product or service either directly or indirectly and which is reasonably necessary for the purposes which you consented to. VCL may also collect information as authorized by law.
5. LIMITS FOR USING, DISCLOSING AND RETAINING PERSONAL INFORMATION
Your personal information will only be used or disclosed for the purposes set out above and as authorized by law. VCL will keep personal information used to make a decision affecting an individual for at least one year after using it to make the decision.
VCL will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes.
VCL will take due care when destroying personal information to prevent unauthorized access to such information.
VCL will make a reasonable effort to ensure that personal information it is using or disclosing is accurate and complete. In most cases, VCL will rely on you to ensure that certain information, such as your street address, e-mail address or telephone number, is current, complete and accurate.
If you demonstrate the inaccuracy or incompleteness of personal information, VCL will amend the information as required. If appropriate, VCL will send the amended information to third parties to whom the information has been disclosed.
When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, VCL will annotate the personal information under its control with a note that a correction was requested but not made.
7. SAFEGUARDING PERSONAL INFORMATION
VCL protects the personal information in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks.
VCL will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by its suppliers and agents who assist in providing products and services to you.
Please note that confidentiality and security are not assured when information is transmitted through e-mail or other wireless communication. VCL will not be responsible for any loss or damage suffered as a result of a breach of security or confidentiality when you transmit information to VCL by e-mail or other wireless communication or when VCL transmits such information by such means.
VCL is open about the policies and procedures it uses to protect your personal information. Disclosure of our policies and procedures will be made available in writing and electronically. However, to ensure the integrity of our security procedures and business methods, VCL will not disclose sensitive information about its policies and procedures.
VCL will make available a description of the type of personal information held by VCL, and a general description of its use and disclosure.
9. PROVIDING ACCESS
You have a right to access your personal information held by VCL.
Upon written request and authentication of identity, VCL will provide you with your other personal information under its control, information about the ways in which that information is being used and a description of the individuals and organizations to which such information has been disclosed.
VCL may charge a reasonable fee for providing personal information in response to an access request and will provide an estimate of any such fee upon receiving a written access to personal information request. VCL may require a deposit for all or part of the fee. VCL will make personal information available within 30 days or provide written notice where additional time is required to fulfil the request.
In some situations, VCL may not be able to provide access to certain personal information. This may be the case where, for example, disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purpose of an investigation or where disclosure of the information would reveal confidential commercial information that, if disclosed, could harm the competitive position of VCL. VCL may also be prevented by law from providing access to certain personal information.
Where an access request is refused in whole or in part, VCL will notify you in writing, giving the reason for refusal and outlining further steps which are available to you.
VCL will, on request, provide information regarding its complaint response procedure.
Vancouver College Limited
5401 Hudson Street
Vancouver, BC V6M 0C5