Since January 1, 2004, all Canadian organizations engaged in commercial activities have been required to comply with the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) and the Canadian Standards Association Model Code for the Protection of Personal Information incorporated by reference into PIPEDA. These obligations extend to lawyers and law ﬁrms, including the legal staff of Seniors First BC.
In addition, a Personal Information Protection Act is in force since 2003 in British Columbia, and sets out rules regarding the collection, use and disclosure of personal information by non-governmental organizations within our province.
Lastly, as a provider of legal services, we have professional and ethical obligations to keep conﬁdential the information we receive in the context of a lawyer-client and legal advocate-client relationship.
Personal information is deﬁned in PIPEDA as information about an identiﬁable individual, but does not include the name, title or business address or telephone number of an employee of an organization. In other words, in terms of our staff, it does not include the information that one expects to ﬁnd on a business card.
Consent to Our Collection of Personal Information
In most cases, we obtain your consent to collect, use and disclose your personal information.
Usually, if you retain our organization, we assume that we have your implied consent to our collection and use of your personal information, however, at times we may ask for your express consent, either verbally or in writing. Generally, we collect your personal information directly from you at the start of or during the course of your retainer with our organization’s lawyers or legal advocate. Sometimes we may obtain information about you from other sources such as a government registry or other professionals who serve you.
Use of Personal Information at Seniors First BC
We use your personal information to provide legal advice and services to you, to issue invoices and to maintain our database of clients. In addition, if you apply for a position with Seniors First BC, we will use your personal information to assess your candidacy. Lastly, we may use your contact information (name, e-mail and postal address) so that we may communicate with you about recent developments in the law, keep you abreast of Seniors First BC news and invite you to our events.
You can access the BC CEAS website without disclosing your personal information, other than your IP address [see ‘Website Privacy’ below]. The only other personal information captured through our website is any information that you volunteer, such as if you complete one of our various online forms. We are committed to not disclosing or sharing any information that you do provide.
Withdrawal of Consent
You may withdraw your consent to our collection, use and disclosure of your personal information at any time, subject to legal and/or contractual restrictions and upon reasonable notice. Your withdrawal of consent to our collection, use and disclosure of your personal information may impact our ability to represent you and provide you with legal advice.
You can ask us not to send you communications by following the opt-out instructions in each communication or you may let us know by contacting our administrative staff at admin (a) bcceas.ca. [replace (a) with the ampersand symbol – @]
Disclosure of Personal Information
Generally, we do not disclose your personal information to third parties without your consent unless permitted or required by applicable laws or court orders. The following are some examples where we may disclose your personal information:
- such disclosure is necessary to collect fees or disbursements;
- we contract with a third party to provide us with certain services such as archival ﬁle storage or insurance. (In such cases, we will use contractual or other means to ensure the third party service provider is bound by obligations regarding privacy which are consistent with this policy); or,
- we engage expert witnesses or other law ﬁrms on your behalf.
Accuracy of Your Information
It is important that the information that we have on ﬁle be accurate and up-to-date. If, during the course of the retainer, any of your information changes, please inform us so that we can make any necessary changes. We may also ask you from time to time whether your personal information is up-to-date.
Seniors First BC uses various safeguards to ensure that your personal information is protected against loss, theft, misuse, unauthorized access, disclosure, copying or alteration. These include:
- security of our physical premises;
- our professional obligations;
- security software and ﬁrewalls to prevent unauthorized computer access or “hacking”; and
- internal passwords that restrict access to our electronic ﬁles.
Access to your Personal Information
You have a right to challenge the accuracy and completeness of your personal information and to have it amended, as appropriate. You also have a right to request access to your personal information and receive an accounting of how that information has been used and disclosed, subject to certain exceptions prescribed by law. For example, if the requested information would reveal personal information about another individual, your request for access may be limited or denied. If your request for access is denied, Seniors First BC will notify you in writing of the reason for the denial.
To request access or to amend your personal information, please contact the lawyer or legal advocate with whom you normally correspond or write to our Privacy Contact at the address below. Seniors First BC will respond within thirty (30) days of receipt of your written request.
Seniors First BC will respond to inquiries about its policies and practices relating to its handling of your personal information. Inquiries should be directed to Seniors First BC’ Privacy Contact using the contact information below. Seniors First BC will investigate all complaints and will respond within 30 days of receipt of a written inquiry. If the complaint is found to be justiﬁed, Seniors First BC will take appropriate measures to resolve it, including, if necessary, amending this Policy and its procedures.
Like most other commercial websites, we may monitor trafﬁc patterns, site usage and related site information to optimize your visit to our website. Our website server will automatically collect IP addresses in an IP log. We may view the IP log from time to time, for example, to maintain the security of our website. We do not link the IP addresses to other personally identiﬁable information. [IP addresses are specific to each computer, but do not provide personal information other than a digital address on the web]
Google Analytics and cookies
The Seniors First BC website uses a tool known as Google Analytics to help us understand how visitors use the site and to improve our web services. This tool uses ‘cookies’ to collect standard information (including your IP address) about visitors’ behavior in an anonymous form and stores this information on Google’s servers. ‘Cookies’ are small text files sent to your computer when your browser visits a website.
Seniors First BC will not (and will not allow any third party to) use Google Analytics to collect personally identifiable information of visitors to our site. Google will use the anonymous information collected for the purpose of tracking your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and Internet usage. For further information, you can refer to the Terms of Service of Google Analytics.
By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above. However, you can also choose to decline cookies from Google Analytics by selecting the appropriate settings on your browser.
If you have any questions or complaints about this Policy or the handling of your personal information, if you wish to withdraw your consent to our use of your personal information, or to request access to or update any information we have on ﬁle, please contact the lawyer or legal advocate with whom you are dealing, or contact:Maggie Verheyden,
BC Centre for Elder Advocacy and Support
#370-1199 West Pender Street,
Vancouver, BC V6E 2R1 Phone: 604688-1927 x 0
Toll Free [outside Lower Mainland]: -1-8-688-1927 x 0
If any complaint or inquiry is not handled to your complete satisfaction, you may contact:Office of the Information and Privacy Commissioner for British Columbia PO Box 9038 Stn. Prov. Govt.
Victoria B.C. V8W 9A4 Phone: (250) 387-5629 [Callers outside Victoria can contact the office toll-free by calling Enquiry BC requesting a transfer to (250) 387-5629. Contact Enquiry BC at: Vancouver: (604) 660-2421; elsewhere in BC: (800) 663-7867. Fax (250) 387-1696
ORPrivacy Commissioner of Canada
112 Kent Street Ottawa, Ontario K1A 1H3
Toll free: 1.800.282.1376.