FIDDLER INDUSTRY DRIVING SOLUTIONS LTD.
Personal Information Privacy Protection Policy
At Fiddler Industry Driving Solutions (hereafter referred to as FIDS) we are committed to providing our clients with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, protecting their personal information is one of our highest priorities.
While we have always respected our clients’ 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’ 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’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ personal information and allowing our clients to request access to, and correction of, their personal information.
Personal Information –means information about an identifiable individual. This information may consist of: name, age, home and/or mailing address, e-mail address, phone number, drivers’ license class & number, ICBC testing scores, training dates, and details concerning each training session. 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 FIDS complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the client 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 information that is necessary to fulfill the following purposes:
- To verify identity;
- To open and manage an account;
- To assist our clients with employment referrals;
- To manage and schedule road test appointments with ICBC (Insurance Corporation of British Columbia)
- To collaborate with a non-profit Employment & Training organization that assists our client;
- To enrol the client in a program;
- To contact our clients in regard to employment or scheduling purposes;
- To ensure a high standard of service to our clients;
- To assess a clients’ eligibility to train/upgrade a license class;
- To collect and process tuition payments
Policy 2 – Consent
2.1 We will obtain client 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 orally, in writing, or electronically through an authorized representative, or it can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the client voluntarily provides personal information for that purpose.
2.3 Subject to certain exceptions (e.g., the personal information is necessary to provide training or the withdrawal of consent would frustrate the performance of a legal obligation), clients can withhold or withdraw their consent for FIDS to use their personal information in certain ways. A clients’ 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 in making the decision.
2.4 We may collect, use or disclose personal information without the clients’ 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 (e.g., a telephone directory);
- For the purposes of collecting a tuition payment;
- To protect FIDS and/or our client from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose client personal information where necessary to fulfill the purposes identified at the time of collection:
- To conduct client surveys or online website performance in order to enhance the provision of our services;
- To contact our clients directly about products and services that may be of interest;
- To facilitate transparency with the Insurance Corporation of British Columbia (ICBC) in regard to the legitimacy and legality of our client documentation
3.2 We will not use or disclose client personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell client lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use client personal information to make a decision that directly affects the client, we will retain that personal information for at least one year so that the client has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client personal information only as long as necessary to fulfill the identified purposes or for a necessary legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that client personal information is accurate and complete where it may be used to make a decision about the client or disclosed to another organization.
5.2 Clients 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.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client 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 personal information is appropriately protected:
- Password protected and external electronic data storage
- Locked paper filing systems
- Restricted employee access as appropriate to electronic and paper filing systems that contain the personal information for a FIDS client
6.3 We will use appropriate security measures when destroying client’s personal information such as shredding paper documents and/or 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.
Policy 7 – Providing Clients Access to Personal Information
7.1 Clients have a right to access their personal information, subject to limited exceptions, such as:
- Client disclosure that would reveal personal information about another client
- Health and safety concerns
7.2 A request to access personal information must be made in writing or in-person to the appropriate FIDS Privacy Officer or Office Administrator and must provide indisputable proof of identity to gain access to the clients’ personal information.
7.3 Upon request, we will also tell clients how we use their personal information and to whom it has been disclosed if applicable (via Student Contract or verbally on an as required basis at certain stages of the driver training program).
7.4 We will make the requested information available within 5 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.6 If a request is refused in full or in part, we will notify the client in writing or verbally in-person, providing the reasons for refusal and the recourse available to the client.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or Office Administrator
8.1 The Privacy Officer or Office Administrator is responsible for ensuring FIDS compliance with this policy and the Personal Information Protection Act.
8.2 Clients should direct any complaints, concerns or questions regarding FIDS compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for FIDS Privacy Officer or Office Administrator:
- (778) 349-5073
- P.O. Box 21135 Spruceland RPO
- Prince George, BC V2M 7E8