Personal Information Protection Private Sector Privacy Legislation

At Community Marine Concepts, we are committed to providing our clients and members with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients and members, protecting their personal information is one of our highest priorities.

While we have always respected our clients and members privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our clients and members of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients’ and members’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ and members’ personal information and allowing our clients and members to request access to, and correction of, their personal information.

This Personal Information Protection Policy applies to Community Marine Concepts Ltd. and its subsidiaries, Victoria International Marina. This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Victoria International Marina.

Personal Information – means information about an identifiable individual. Personal information does not include contact information (described below).

Contact information – means information that would enable an individual to be contacted at a place of business
and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.

Privacy Officer – means the individual designated responsibility for ensuring that Community Marine Concepts complies with this policy and PIPA.

1.1 Unless the purposes for collecting personal information are obvious and the client and member voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2 We will only collect client and member information that is necessary to fulfill the following purposes:

• To verify identity;
• To verify creditworthiness;
• To identify client and member preferences;
• To open and manage an account;
• To deliver requested products and services;
• To guarantee a reservation;
• To send out association membership information;
• To ensure a high standard of service to our clients and members;
• To meet regulatory requirements;
• To assess suitability for tenancy;
• To collect and process rent payments;

2.1 We will obtain client and member consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2 Consent can be provided or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client or member voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a client or member is given notice and a reasonable opportunity to opt-out of his or her personal information being used for marketing and the client or member does not opt-out.

2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients and members can withhold or withdraw their consent for Community Marine Concepts to use their personal information in certain ways. A client’s or member’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. If so, we will explain the situation to assist the client or member in making the decision.

2.5 We may collect, use or disclose personal information without the client’s or member’s knowledge or consent in the following limited circumstances:

[Fill in the situations that may be applicable to your organization. A full listing of such circumstances can be found in sections 12, 15, and 18 of PIPA. Some examples include:]

• When the collection, use or disclosure of personal information is permitted or required by law;
• In an emergency that threatens an individual’s life, health, or personal security;
• When we require legal advice from a lawyer;
• For the purposes of collecting a debt;
• To protect ourselves from fraud;
• To investigate an anticipated breach of an agreement or a contravention of law

3.1 We will only use or disclose client and member personal information where necessary to fulfill the purposes identified at the time of collection

• To conduct client and member surveys in order to enhance the provision of our services;
• To contact our clients and members directly about products and services that may be of interest;

3.2 We will not use or disclose client or member personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell client and member lists or personal information to other parties

4.1 If we use client and member personal information to make a decision that directly affects the client or member, we will retain that personal information for at least one year so that the client or member has a reasonable opportunity to request access to it.

4.2 Subject to policy 4.1, we will retain client and member personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

5.1 We will make reasonable efforts to ensure that client and member personal information is accurate and complete where it may be used to make a decision about the client and member or disclosed to another organization.

5.2 Clients and Members may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.

5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’ and members’ correction request in the file.

6.1 We are committed to ensuring the security of client and member personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2 The following security measures will be followed to ensure that client and member personal information is appropriately protected.

6.3 We will use appropriate security measures when destroying client’s and member’s personal information such as shredding documents and deleting electronically stored information.

6.4 We will continually review and update our security policies and controls as technology changes to
ensure ongoing personal information security.

7.1 Clients and Members have a right to access their personal information, subject to limited exceptions.

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.

7.3 Upon request, we will also tell clients and members how we use their personal information and to whom it has been disclosed if applicable.

7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client and member of the cost and request further direction from the client and member on whether or not we should proceed with the request.

7.6 If a request is refused in full or in part, we will notify the client or member in writing, providing the reasons for refusal and the recourse available to the client and member.

8.1 The Privacy Officer or designated individual is responsible for ensuring Community Marine Concepts Ltd.’s compliance with this policy and the Personal Information Protection Act.

8.2 Clients and Members should direct any complaints, concerns or questions regarding Community Marine Concepts Ltd.’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client or member may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for Community Marine Concepts Ltd.’s Privacy Officer or designated individual: 778-432-0477  – info@vimarina.ca