Vancouver College Limited (VCL)
OUR COMMITMENT TO PRIVACY
The purpose of this Policy is to provide you with information about how VCL collects, uses and discloses personal information about you, how VCL secures your personal information, and when we may disclose your personal information to third parties, and when we may transfer your personal information outside of Canada. This Policy also describes your rights regarding the personal information that we hold about you and how you can access and correct the personal information
that VCL holds about you.
SCOPE OF POLICY
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. Consent can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious to a reasonable person, and you voluntarily provide personal information for that purpose. Consent may also be implied where you are given notice and a reasonable opportunity to opt out of your personal information being used or disclosed, and you do not opt out.
"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 excludes anonymous or de-identified data that is not associated with a particular 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.
"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.
“Vancouver College Alumni Association” or “VCAA” is a registered society that is led by a volunteer board of Vancouver College alumni that work to foster the social environment of the Vancouver College community, particularly amongst alumni.
“Vancouver College Foundation” or “VCF” is a registered charity and foundation that manages bequests and donations to Vancouver College donated prior to the establishment of the VCMF.
“Vancouver College Millennium Foundation” or “VCMF” is a registered charity and foundation that manages bequests and donations to Vancouver College.
“Vancouver College Parents Association” or “VCPA” is a non-profit association intended to support Vancouver College’s administration through a variety of initiatives and fundraising events, including to encourage participation in Vancouver College activities by students’ parents and guardians. All parents and guardians of Vancouver College students are VCPA members.
VCL is accountable and responsible for personal information under its control.
VCL has designated a privacy officer, under the direction of the President (or Principal, when there is no President) to ensure compliance with this Policy. 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.
2. PURPOSES FOR COLLECTION AND USE OF YOUR PERSONAL INFORMATION
VCL may collect, store and use your personal information for the following purposes:
a. to assess applications for admission to or continued enrolment in Vancouver College by prospective students or students through their parents or guardians (e.g. report cards, baptismal certificates, letters of reference);
b. to determine the financial status (including through credit reports) of parents or guardians for admission or continued enrolment of students;
c. to determine citizenship and residency status of prospective students through their parents or guardians (e.g. birth certificate, copy of utility bill);
d. to provide and administer services through Vancouver College, including the delivery of educational and health services, social services, and other support services such as special education;
e. to protect VCL, you and others from fraud and error and to safeguard the interests of VCL and its students, staff and representatives;
f. to authenticate your identity;
g. to process tuition and other payments owed to VCL by you (e.g. VCL collects bank account information and credit card information to process such payments);
h. to collect debts owed by you to VCL;
i. to ensure staff and contractors comply with their agreements and legal obligations to VCL;
j. to provide educational products, or procure from suppliers requested products and services related to the educational, health and social programs VCL provides;
k. 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;
l. for any other purpose directly or indirectly related to establishment or operation of Vancouver College Limited and Vancouver College Millennium Foundation;
m. to solicit and manage donations and for other purposes related to the advancement of Vancouver College;
n. to recruit VCL Board members, student mentors, and volunteers;
o. to directly or indirectly collect and use 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;
p. to create and update your student record;
q. to contact you regarding your education or your child’s education, as applicable;
r. to communicate with you regarding school news, including via our newsletter;
s. to contact you regarding special events, open houses, games, performances, surveys, fundraising and other matters in which VCL is involved, directly or indirectly, from time to time;
t. to comply with any legal or regulatory requirements; and
u. for any other purposes which VCL may identify to you at the time of collection.
Generally, VCL will collect personal information directly from you. However, VCL does sometimes collect or receive personal information about parents, guardians, students and others from third parties, for example, in connection with a credit check, subject to your consent where required by law.
3. DISCLOSURE OF YOUR PERSONAL INFORMATION
Except as described in this Policy or in other situations where we have provided you with prior notice, have obtained your consent, or are obligated or permitted by law, VCL will not share your personal information with third parties. We may disclose personal information that we collect or you provide as described in this Policy.
VCL may disclose your personal information to the following third parties:
a. the VCPA, to enable it to coordinate its activities, which are directly or indirectly beneficial to Vancouver College (e.g. VCL shares parent and guardian contact information with the VCPA to allow it to contact parents about participating in VCPA events such as Mayfair, and to administer the VCPA Parent Participation Program);
b. the VCMF (e.g. VCL shares information about prospective donors and donors with VCMF);
c. the VCAA (e.g. VCL provides VCAA with personal information regarding parents and guardians of Vancouver College students, so those parents and guardians can participate in VCAA events. VCL also provides VCAA with personal information about current and former Vancouver College students to enroll them in the VCAA upon graduation from Vancouver
d. the BC Ministry of Education (e.g. student grades); and
e. where a student has requested, to colleges and universities (e.g. student grades).
VCL may disclose certain personal information to its third party service providers, with whom it has contracted to provide certain services on behalf of VCL. Currently, VCL uses the third party service providers set out below:
The third party service providers will have access to personal information needed to perform their functions, but are only provided the limited amount of information required to perform their services. Several of the third-party service providers identified in this Policy are located in the United States. The United States has different privacy laws that may or may not be as comprehensive as Canadian privacy law. Your personal information may be stored, accessed or used in the United States and may be subject to the laws and access by government, courts, law enforcement, or regulatory
organizations in that jurisdiction.
If you have any questions about VCL’s policies and practices with respect to service providers, including the transferring or processing of your personal information in the United States, you can contact VCL’s privacy officer at the contact information listed in Section 11 below.
VCL may also disclose your personal information where authorized or required by law. For example, we may disclose your personal information:
• to comply with a subpoena, in response to a law enforcement body with the lawful authority to obtain the information;
• pursuant to an investigation into the breach of a law;
• to our legal counsel; and
• if a business transfer or change in ownership occurs, so the information may continue to be used or disclosed in accordance with this policy.
The above collections, uses and disclosures are a reasonably necessary part of your relationship with VCL. In some cases, VCL may seek your consent for the use and disclosure of your personal information after it has been collected, but before it has been used or disclosed (e.g. where we want to use your personal information for a purpose not previously identified to you). We will not use or disclose your personal information for any new purpose without first identifying the new purpose and providing notice to you or obtaining your consent (as applicable), unless otherwise permitted by law.
Except where otherwise permitted by law, VCL will obtain your consent to collect, use or disclose personal information. If you are under the age of majority, your consent is obtained from a parent or guardian.
In determining the appropriate form of consent, VCL will consider the sensitivity of the personal information and the reasonable expectations of the individual. 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.
5. LIMITS ON COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
VCL will only collect, use and disclose your personal information in accordance with this Policy, unless otherwise permitted or required by applicable laws. VCL will not collect personal information indiscriminately and will take reasonable steps to ensure that we limit the amount and type of personal information that we collect from you.
6. RETENTION AND DISPOSAL OF PERSONAL INFORMATION
Except as otherwise permitted or required by applicable law, VCL will only retain your personal information for as long as necessary to fulfill the purposes for which it was collected, including for the purposes of satisfying any legal, accounting, or reporting requirements.
If VCL uses your personal information to make a decision that directly affects you, it will keep that personal information for at least one year after using it to make a decision, so that you have a reasonable opportunity to obtain access to it.
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 holds about you 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. Please keep VCL informed of changes to your personal information.
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.
If you want to correct your personal information, please contact the VCL privacy officer in writing.
8. 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 by you 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 or electronically. However, to ensure the integrity of our security procedures and business methods, VCL will not disclose sensitive information about its policies and procedures.
10. PROVIDING ACCESS
You have a right to access your personal information held by VCL. Typically, parents and guardians will be able to access personal information about their minor children who are VCL students.
Upon written request and authentication of identity, VCL will provide you with the requested personal information under its control, requested 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 fulfill the request.
In some situations, applicable law may allow or require VCL to refuse to provide you with access to some or all of the personal information that we hold about you. 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. In some situations, we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot provide you with access to your personal information, we will inform you of the reasons, subject to any legal restrictions.
Any inquiry, complaint or question regarding this Policy must be directed in writing to the VCL privacy officer.
Vancouver College Limited
5401 Hudson Street
Vancouver, BC V6M 0C5
Phone: (604) 261-4285
Fax: (604) 261-2284
VCL takes any complaint about its privacy practices seriously. If VCL finds a complaint justified, it will take the necessary steps to resolve it. If you are not satisfied with VCL’s response to a complaint, you may have options to exercise various complaint procedures, including with the B.C. Information and Privacy Commissioner or other applicable regulatory authority.
VCL reserves the right to update this Policy at any time. VCL’s collection, use, disclosure, and retention of your personal information will be governed by the version of the Policy in effect at that time. We suggest that you review this Policy periodically.