Personal Information Protection Policy
At Canada Aviation Academy, we are committed to providing our students and renters with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our students and renters, protecting their personal information is one of our highest priorities. We have a strong commitment to protecting students’ and renters’ personal information. This is done in reference to 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 information.
We will inform our students and renters 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 students and renters personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our students and renters personal information and allowing our students and renters to request access to, and correction of, their personal information.
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. Canada Aviation Academy complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
a) Unless the purposes for collecting personal information is obvious and the students and renters voluntarily provide 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.
b) We will only collect students’ and renters’ information that is necessary to fulfill the following purposes:
· To verify identity
· To verify creditworthiness
· To open and manage an account
· To deliver the requested products and services
· To enroll the client in a program
· To ensure a high standard of service to our clients
· To meet regulatory requirements
· To collect and process payments
Policy 2- Consent
a) We will obtain students’ and renters’ consents to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
b) Consent can be provided in writing or electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the student and renter voluntarily provides personal information for that purpose.
c) Consent may also be implied where a student and renter is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, and the student and renter does not opt-out.
d) Subject to certain exceptions (e.g., their personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), students and renters can withhold or withdraw their consent for Canada Aviation Academy to use their personal information in certain ways. A student’s and renter’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 students and renters in making the decision.
e) We may collect, use or disclose personal information without the students’ and renter’s knowledge or consent in the following limited circumstances:
· 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 the personal information is available from a public source
· 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.
Policy 3 – Using and Disclosing Personal Information
a) We will only use or disclose student’s and renter’s personal information where necessary to fulfill the purposes identified at the time of collection.
b) We will not use or disclose student’s and renter’s personal information for any additional purpose unless we obtain consent to do so.
c) We will not sell students and renters lists or personal information to other parties.
Policy 4 – Retaining Personal Information
a) If we use students’ and renters’ personal information to make a decision that directly affects them, we will retain that personal information for at least one year so that they have a reasonable opportunity to request access to it.
b) Subject to policy 4a), we will retain personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
a) We will make reasonable efforts to ensure that students’ and renters’ personal information is accurate and complete where it may be used to make a decision about the students and renters or disclosed to another organization.
b) Students and renters 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.
c) If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information in the previous year. If the correction is not made, we will note the student’s and renter’s correction request in the file.
Policy 6 – Securing Personal Information
a) We are committed to ensuring the security of students and renter’s personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
b) We will use appropriate security measures when destroying students and renter’s personal information such as shredding.
c) We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing students and renters Access to Personal Information
a) Students and renters have a right to access their personal information, subject to limited exceptions.
b) A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
c) Upon request, we will also tell students and renters how we use their personal information and to whom it has been disclosed if applicable.
d) 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.
e) A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the students and renters of the cost and request further direction from the students and renters on whether or not we should proceed with the request.
f) If a request is refused in full or in part, we will notify the students and renters in writing, providing the reasons for refusal and the recourse available to the students and renters.
Policy 8 – Questions and Complaints: The role of the Privacy Officer
a) The Accountable Executive is responsible for ensuring Canada Aviation Academy’s compliance with this policy and the Personal Information Protection Act.
b) Students and renters should direct any complaint, concerns or questions regarding Canada Aviation Academy’s compliance in writing to the Privacy Officer. If the Privacy officer is unable to resolve the concern, the students and renters may also write to the Information and Privacy Commissioner of British Columbia.