Privacy and Personal Information Protection Policy

(This Personal Information Protection Policy complies with British Columbia’s Personal Information Protection Act)

GrowthPoints is committed to providing clients with exceptional service.  To serve clients, we must collect, use and sometimes disclose Personal Information about them.  Protecting a client’s Personal Information is one of our highest priorities.

Definitions

In this policy:

Contact Information – means information that would enable an individual to be contacted at a place of business and includes name, position, and business phone number, business fax number, business address or business email. 

Personal Information – means information about an identifiable individual.  Examples of Personal Information includes name, home address and phone number, credit card information, and confidential computer data.

Personal Information does not include Contact Information.

Collecting Personal Information

1.   Unless a client voluntarily provides Personal Information for an obvious purpose, we will communicate the purposes for which Personal Information is being collected before or at the time of collection.

2.     We will only collect Personal Information necessary to:

·         open and manage a client’s file;

·         contact a client;

·         identify a client’s needs;

·         deliver requested services or goods;

·         send out information relevant to the services regularly requested by the client and delivered by us to the client;

·         ensure a high standard of service for a client;

·         collect and process payments on account.

Client Consent to Collect Personal Information

3.     In most circumstances we will obtain a client’s consent to collect, use or disclose their Personal Information.   The client’s consent can be given orally, electronically, or in writing. 

4.      Where our purpose for collecting, using or disclosing a client’s Personal Information is obvious and a client voluntarily provides the Personal Information, the consent is implied.

5.     The consent is also implied, where a client is given notice and a reasonable chance to opt-out of Personal Information being used for e-mail-outs, mail-outs, or the marketing of our new services or products, and the client does not opt out.

6.     A client’s decision to withhold or withdraw their consent to certain uses of Personal Information may restrict our ability to provide a particular service or product. 

7.     We may collect, use or disclose Personal Information without a client’s knowledge or consent in limited circumstances including:

·         when we are permitted or required by law to do so;

·         when the Personal Information is available from a public source (e.g., a public database);

·         when we require legal advice from a lawyer;

·         to collect a debt;

·         to protect ourselves from fraud;

·         to investigate an anticipated breach of an agreement or a contravention of law

Using and Disclosing Personal Information

8.     We will only use or disclose client Personal Information for the purposes identified at the time of collection.

9.     We will not use or disclose client Personal Information for any additional purpose unless we obtain consent to do so.

Retaining Personal Information

10.  We will keep client Personal Information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Ensuring Accuracy of Personal Information

11.  We will use our best efforts to ensure that client Personal Information collected, used, or disclosed, is accurate and complete.

12.  Clients may request corrections to their Personal Information to ensure its accuracy and completeness. 

13.  When necessary, inaccurate or incomplete Personal Information will be corrected, and the corrected information forwarded to any relevant parties.

Securing Personal Information

14.  We will guard against unauthorized access, collection, use, disclosure, copying, modification or disposal of a client’s Personal Information, and review and update our security processes as technology changes.

15.  Presently, our security measures to ensure that client Personal Information is appropriately protected include:

·         the use of locked filing cabinets;

·         the use of office security systems;

·         the use of passwords and firewalls; and

·         the restriction of employee access to Personal Information as appropriate.

16.  Presently, our destruction measures to ensure the timely destruction of a client’s Personal Information include:

·         destruction date diarising;

·         document shredding; and

·         the deletion of electronically stored information.

Client Access to Personal Information

17.  Except in very limited circumstances, clients have a right to access their Personal Information.   Such requests should be in writing directed to our Privacy Officer and should detail the information sought.

18.  Upon request by a client, we use our best efforts to make the client’s Personal Information available within 30 business days.  A minimal fee may be charged for this service.

19.  If a request is refused in full or in part, we will notify the client in writing, providing the reasons for refusal.

Privacy Officer

20.  Our Privacy Officer ensures Kate Fagan Taylor Consulting Ltd (doing business as GrowthPoints) complies with this policy and British Columbia’s Personal Information Protection Act.  

Our Privacy Officer is:

             Name:              Kate Fagan Taylor

             Title:                Principal

             Address:          kate.ft@outlook.com

21.  Clients may, in writing, direct complaints, concerns or questions about GrowthPoints’ compliance with this policy to the Privacy Officer.

22.  If the Privacy Officer is unable to resolve the issue, a client may also write to the Information and Privacy Commissioner of British Columbia.