Privacy Statement

This policy applies to personal information about our employees, members, suppliers, third parties, agents, contractors and affiliated entities that is collected, used or disclosed by us.

Vancouver Lawn will collect and use information about its employees, members and contractors if it is reasonable to do so for the purpose of establishing, managing and/or terminating an employment or membership relationship between the organization and the individual.

Vancouver Lawn will also collect and use personal information for archival or historical purposes in accordance with the guidelines of the Act.

Vancouver Lawn will disclose personal information within the guidelines of the Act solely for the operation of the Club.

Personal employee or member information that is published, posted, printed, mailed or e-mailed by the Club is private. Employees or members shall use such information for Club purposes only. Employees or members shall not copy or distribute such information or use it for any purpose except as authorized by the Board of Directors of Vancouver Lawn.

Vancouver Lawn will make a reasonable effort to ensure that personal information collected by or on behalf of the organization is accurate and complete, and will protect personal information in its custody or under its control.

The ten principles addressed in our privacy policy are as follows:

Principle 1 - Be Accountable
Principle 2 - Identify the Purpose
Principle 3 - Obtain Consent
Principle 4 - Limit Collection
Principle 5 - Limit Use, Disclosure and Retention
Principle 6 - Be Accurate
Principle 7 - Use Appropriate Safeguards
Principle 8 - Be Open
Principle 9 - Give Individuals Access
Principle 10 - Provide Recourse

1.01

Vancouver Lawn has adopted this Personal Information Protection Policy in compliance with the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and/or the provincial privacy law Personal Information Protection Act (PIPA) (if applicable).

1.02

The protection of your personal information is important to us. We are committed to protecting the privacy of our employees and members. This policy sets out how we collect, use and disclose the personal information of our employees and members, including applicants applying for a job or membership to the Club. Our commitment is to maintain the confidentiality of your personal information and to preserve your right to privacy.

1.03

Employees and members are obligated to ensure that personal information, to which they may have access remains confidential, is only used for the purposes for which it was collected, is not disclosed without authorization or used for personal gain.

1.04

Employees and members are required to follow all procedures regarding the collection, use and disclosure of personal information as set out in this policy.

2.01

The purpose of this policy is to preserve the privacy of employees, members, contractors and tradespersons by outlining employee and member obligations and the procedures for dealing with personal, privileged and/or confidential information.

2.02

All Vancouver Lawn employees and members who at one time or another receive personal, privileged and/or confidential information which may concern other employees, members, Club operations or contractors/tradespersons; and who collect, maintain and/or use personal information of employees or members, are responsible for ensuring that the collection, use and disclosure of this information is carried out in accordance with this policy and relevant procedures.

2.03

In certain circumstances, personal information may be collected, used or disclosed without the knowledge and consent of the individual. Exemptions include, but are not limited to, personal information gathered for:

• legal, medical or security reasons, 
• detection and prevention of fraud or for law enforcement, 
• journalistic, artistic or literary purposes if its use is confined to those purposes.

3.01

This policy describes the minimum requirements for the protection of employee and member personal information. Any applicable legislation must be considered in implementing these requirements.

3.02

This policy applies to personal information relation to employees, members and/or applicants who apply for employment or membership at the Club.

3.03

This policy applies to all employees, members or anyone else who is granted access to personal, privileged and/or confidential employee and/or member information.

The term "personal information" is defined as factual or subjective information, recorded or not, about an identifiable individual, but does not include the name, title or business address or telephone number of an employee or member of an organization.

4.01

"Personal Information" means recorded information about an identifiable individual which includes, but is not limited to home addresses and telephone numbers, age, sex, marital or family status, identifying numbers such as social insurance number and/or driver's licence, race, national or ethnic origin, colour, religious or political beliefs or associations, educational history, medical history, disabilities, blood type, employment history, financial history, criminal history, anyone else's opinions about an individual, an individual's personal views or opinions, and name, address and phone number of parent, guardian, spouse or next of kin.

4.02

"Collection" means the act of gathering, acquiring or obtaining personal information from any source, including third parties, by any means.

4.03

"Consent" means a voluntary agreement with what is being done or proposed.

Consent can either be express, or implied. Express consent is given explicitly, either orally, or in writing. Express consent is unequivocal and does not require any inference on the part of the Club seeking consent. Implied consent arises where consent may be reasonably inferred from the action, or inaction, of the individual.

4.04

"Disclosure" means making personal information available to others inside and/or outside the Club.

4.05

"Use" means the treatment and handling of personal information by, and within the Club.

4.06

"Financial history" means information about income, employee's finances, assets, salaries, wages, monetary incentives, beneficiaries, insurance, benefits, financial transactions, credit worthiness and debts.

4.07

"Employment history" means personal recommendations or evaluations, character references or personnel evaluations, letters of discipline and reprimand and reasons for termination.

4.08

"Medical history" means health care history relating to medical, psychiatric, or psychological diagnosis, condition, treatment, or evaluation.

4.09

"Personal health information" means information about an identifiable individual that relates to the physical or mental health of the individual, the provision of health care to the individual, the individual's entitlement to payment for health care, the individual's health care number, the identity of providers of health care to the individual or the identity of substitute decision-makers on behalf of the individual.

4.10

"Law enforcement" means disciplinary investigations or proceedings that lead or could lead to a penalty or sanction being imposed and policing.

4.11

"Third Party" means individuals or organizations other than the subject of the records or representatives of Van Lawn. Note that in certain circumstances, the Club may be entitled to provide personal information to an external party acting as an agent of Vancouver Lawn.

5.01

Employees and members are responsible for:

• Keeping their own files current regarding their personal information; 
• Being familiar with and following policies and procedures regarding personal, privileged and/or confidential information; 
• Obtaining the proper consents and authorizations prior to disclosure of personal, privileged and/or confidential information; 
• Immediately reporting any breeches of confidentiality to Privacy Officer; 
• Keeping private passwords and access to personal information privileged and confidential; 
• Explaining this policy to clients, suppliers and third parties accessing the Club and referring them to the Privacy Officer, if necessary; 
• Relinquishing any personal, privileged and/or confidential information in their possession before, or immediately upon, termination of employment or membership. 

5.02

Supervisors, human resources, payroll and/or marketing personnel are responsible for:

• Obtaining consent for the collection and use of personal information from employees or members and ensuring that appropriate consents have been obtained from employees or members with respect to the collection and use of personal information; 
• Ensuring policies and procedures regarding collection, use and disclosure of personal information are consistently adhered to; 
• Maintaining systems and procedures to ensure employee or member records are kept private; 
• Responding to requests for disclosure after the proper release is obtained; 
• Obtaining proper consents and authorizations prior to disclosure of information contained in employee or member records; 
• Responding to employee or member requests for access to their files; 
• Ensuring proper disposal of unnecessary files/information; 
• Cooperating with the Privacy Officer to investigate complaints or breaches of policy; 
• Obtaining from employees or members prior to their termination any personal, privileged, confidential information in their possession; 
• Ensuring that disclosure of personal information or personal health information to a third party is done with the approval of the Privacy Officer in order to minimize risk of non-compliance with applicable legislative or regulatory regimes; 
• Maintaining separate files to ensure that personal health or other sensitive data is protected. 

5.03

The Privacy Officer is responsible for:

• Internal compliance with applicable policies or legislation; 
• Cooperating with supervisors, human resources, payroll and/or marketing personnel in developing internal policies for the collection, use and disclosure of personal information, personal health information and other confidential data of employees, members and clients; 
• Monitoring and responding to Third Party requests for personal information or other personal/confidential information; 
• Ensuring appropriate consents are obtained for the collection, use and disclosure of personal and other confidential information; 
• Where collection, use or disclosure is permitted without prior consent, notifying individuals of the collection, use and disclosure of personal information and/or other personal confidential information after such occurrence.

6.01

Accountability
Vancouver Lawn is responsible for personal information under its control and shall designate a Privacy Officer to be accountable for Van Lawn's compliance with the Act and all privacy requirements.

6.02

Identity Purposes
The purposes for which personal information is collected shall be identified by Vancouver Lawn at or before the time the information is collected.

6.03

Consent
The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information.

6.04

Limiting Collection
The collection of personal information shall be limited to that which is necessary for the purposes identified by Vancouver Lawn.

6.05

Limiting Use, Disclosure and Retention
Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

6.06

Accuracy
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

6.07

Safeguards
Personal information shall be protected be security safeguards appropriate to the sensitivity of the information.

6.08

Openness
Vancouver Lawn shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.

6.09

Individual Access
Upon request, an individual shall be informed of the existence, use, disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

6.10

Challenging Compliance
An individual shall be able to address a challenge concerning compliance with the above principles to the Privacy Officer accountable for Van Lawn's compliance.

7.01

This Personal Information Protection Policy addresses two broad issues:
The way in which the Club collects, uses, discloses and protects personal information as well as privileged and confidential information;
The right of an employee, member or third party to have access to personal information, and if necessary, to correct the information.

7.02

Collecting, Using and Disclosing Information
Information Collected
Vancouver Lawn collects, uses and discloses employee or member personal information in order to establish, manage or terminate an employment or membership relationship. Personal, privileged and/or confidential information about customers/clients may only be collected, used, disclosed and retained for the purposes identified by Vancouver Lawn as necessary.

Providing Consent
When becoming an employee or member of the Club, your personal information is obtained and used only with your consent. The consent you provide at this time allows us to administer all aspects of your relationship with the Club. In order to provide you with benefits with the group benefit plan, it may be necessary for you to provide us with additional personal information at a future time. We will require you to provide express consent at that time. Your consent can be either express or implied. Where practical, we will obtain your express consent. For example, when you sign an application form you are giving us express consent to use your personal information to conduct a reference check for a job or membership. The applicant's written authorization is obtained and the authorization specifies who can be contacted for a reference. We will continue to use and disclose your personal information previously collected in accordance with our current privacy policy, unless you inform us otherwise. We will infer that consent has been obtained for the continued use or disclosure of your personal information by the continuation of your employment or membership with the Club. 

Withdrawal of Consent
You may withdraw your consent subject to legal or contractual obligations and on reasonable notice. If you want to withdraw your consent, you should first contact the Privacy Officer at Vancouver Lawn to understand the implications of such withdrawal, and then if you choose to proceed, to give the requisite notice. 

Protecting Your Privacy
Your personal information is kept in strict confidence. We protect your personal information from error, loss and unauthorized access. 

Access to Personal Information
Our employees or members who have access to your personal information are made aware of how to keep it confidential. Employee or member access to confidential personal information about applicants, employees or former employees, including others paid through the Club payroll or membership system where the Club has custody or control of the information will be allowed if the information is necessary for the performance of the duties and responsibilities of the employee or member. All employees and members of Vancouver Lawn are bound by this policy and a Confidentiality Policy. Specific employees, management, human resources, accounting and payroll personnel shall have access to employee and member records containing personal information. The Privacy Officer is responsible for identifying the individuals able to have access, the level of access given and when such access is permissible and necessary. Employees or members may obtain a copy of any document in their file which they have previously signed. No material contained in an employee or member file may be removed. A representative of the Club will be present during viewing of the file. There may be situations in which we are legally prohibited from allowing you access to your personal information. For example, we would be so prohibited if allowing you access to your personal information would likely reveal personal information about another person or other confidential information. If this is the case, we will advise you why, subject to any legal restrictions. Other exceptions are as follows:

• Evaluating information collected in a reference check if the disclosure reveals the identity of the information source, and the source expected that his or her identity would be held in confidence (this information is retained in another file rather than in the employee file); and information that would disclose personal information about another party. 
• The right of access does not extend to information exempted from disclosure under PIPEDA and/or PIPA, but if that information can reasonably be severed from a record an applicant has the right of access to the remainder of the record. 

Correcting Personal Information
You have a right to submit a written request to access your personal information that is in our possession and make corrections to it. An employee or member can request correction of his or her personal information if there is an error or omission or, alternatively, he or she may require that a statement of disagreement is attached. We will amend personal information that is demonstrated to be inaccurate or incomplete. An employee or member may provide written notice of correction related to any data contained in their file. The notice of correction shall be provided to the Privacy Officer. Client information is only to be accessed by employees or members with appropriate authorization. 

Disclosure
The Club will not disclose personal information about applicants, employees or members to any third party, unless it is otherwise provided for by employee/member explicit consent or by law. Employees and members must ensure that no personal, privileged and/or confidential information of clients is disclosed without the client's consent and then only if security procedures are satisfied. Access to Third Party Personal Information by Employees/Members or About Employees/Members We do not make any employee or member personal information available to other organizations without your express consent, except under the following circumstances:

• If the employee or member has given consent 
• If the information is required for the purpose for which it was obtained 
• If required by such as reporting an employee accident to the Worker's Compensation Board of British Columbia or to a law enforcement agency 
• In compelling circumstances under which a delay in obtaining information may be injurious to an individual's health and safety; and 
• In compassionate circumstances in order to facilitate contact with next-of-kin or a friend of an individual who is injured, ill or deceased. 

Employee or member requests for disclosure of their own personal information to third parties must be accompanied by a completed, signed and dated Authorization to Release Information form. This form should be used in dealing with insurance companies with respect to employee benefits and to provide confirmation of earnings to financial institutions for lending purposes. If an organization contacts the Club for reference information on a current or former employee or member of the Club, the information is only disclosed if the organization has the written authorization of the employee or member. Requests regarding third party access to employee personal information will be handled by the Privacy Officer and must be in writing. Access will be administered according to those specific policies and procedures, which may be established from time to time by the Club to apply to the personal information of employees or members.

7.03
Information Protection Measures
We have developed and continue to enhance security procedures to safeguard and protect personal information against loss, theft, unauthorized disclosure, copying, and unauthorized use or modification. We maintain appropriate safeguards and security procedures that reflect the types of documents, including electronic or paper records. Organizational measures taken include security clearances and limiting access on a "need-to-know" basis. Technological measures include the use of passwords and encryption. 

7.04
Retention/Destruction of Personal Information
We keep your personal information only so long as we need to administer the employment or membership relationship and services, and for a reasonable time thereafter, or to meet any legal, regulatory, or tax requirements. Unless retention of personal information is specified by law for certain time periods, personal information that is no longer required to fulfill the identified purposes shall be destroyed, erased or made anonymous within 7 years after its use. We destroy your personal information when it is no longer needed, or we remove your name from the information. Notwithstanding the above, personal information that is the subject of a request by an individual or a Privacy Commissioner shall be retained as long as necessary to allow individuals to exhaust any recourse they may have under federal and/or privacy legislation.

8.01

If you need further information about our Personal Information Protection Policy or have a question, complaint regarding our privacy policies or procedures, please contact the Privacy Officer who is accountable for our personal information protection compliance. If you make an inquiry or ledge a compliant, and are not satisfied with the outcome of that, you may challenge that outcome by writing a letter to our Chief Executive Officer requesting reconsideration of your matter with the Board. The Club's commitment is to promptly open a dialogue with you. If your concern remains unresolved to your satisfaction, you may address your concerns to:

Office of the Privacy Commissioner of British Columbia
P.O. Box 9038, Stn. Prov. Govt.
Victoria, B.C. V8W 9A4
Telephone: (250) 387-5629 

8.02
Whistleblowing
No employee or member shall be disadvantaged or denied any benefit of employment or membership by reason that Vancouver Lawn believes that an employee or member will do anything referred to below or by reason that an employee, acting in good faith and on the basis of reasonable belief, has disclosed to the Privacy Commissioner that Vancouver Lawn or any other person has contravened or intends to contravene a provision of any privacy legislation related to the protection of personal information; has refused or stated the intention of refusing to do anything that is in contravention of a provision of any privacy legislation related to the protection of personal information; has done or stated an intention of doing anything that is required to be done in order that a provision of any privacy legislation related to the protection of personal information not be contravened. 

8.03
Breach of Club Policy
An employee or member who is found to be in breach of this policy will be subject to discipline up to and including discharge for cause.