Privacy Policy - Algonquin Students' Association

Privacy Policy

Privacy Policy

Responsible Authority: General Manager and CEO
Date Last Reviewed: 2021.09.10

Purpose

To provide access to public information held by The Students’ Association of The Algonquin College of Applied Arts and Technology Corporation (the “SA”) while protecting the privacy of personal information in compliance with applicable laws and regulations.

Scope

The contact for individuals to access their personal information held by the SA, except for information which is excluded by applicable law is:

Privacy Officer
E114 – 1385 Woodroffe Avenue
Ottawa, Ontario, K2G 1V8
saprivacy@algonquincollege.com
613.727.4723 x5321

Definitions

Word/Term Definition
Privacy Officer Person responsible for the coordination of activities related to the privacy of personal information. The role has been delegated by the General Manager and CEO to the Privacy Officer.
Record Any record of information however recorded, whether in printed form, on film, or by electronic means (see Appendix 1 for further details).
Personal information Any recorded information that can identify an individual. Information about individuals acting in their business or professional capacities such as name, title, work address, work telephone number, and email address is not considered personal information (see Appendix 1 for further details).
Complete request Request that contains all the information required by the SA to find the record.

Policy

  1. The SA will comply with all applicable privacy laws, including providing individuals with the right to access their personal information and establishes standards to ensure that this information is protected.
  2. Access to Information
    1. Every person has the right to access a record or part of a record in the custody or under the control of the SA unless the record or part of the record contains personal information or falls within one of the exemptions or exclusions listed below or provided for in FIPPA and the regulations.
    2. A person seeking access to a record shall:
      1. make a request in writing to the Privacy Officer;
      2. provide sufficient detail to identify the record; and
      3. pay the prescribed fee.
    3. The SA shall refuse to disclose personal information to any person other than the individual to whom the information relates except:
      1. upon the prior written request or consent of the individual; subject to the exemptions and exclusions permitted by applicable law or set out in this policy;
      2. in compelling circumstances affecting the health or safety of an individual; or
      3. in accordance with the provisions of applicable law and regulation.
    4. The SA shall refuse to disclose a record:
      1. where the disclosure could reasonably be expected to interfere with a law enforcement matter;
      2. that reveals a trade secret or scientific, technical, commercial, financial, or labour relations information belonging to a third party;
      3. that is subject to solicitor-client privilege; or
      4. in accordance with any of the other exemptions or exclusions under applicable law or regulation.
  3. Collection, Use and Disclosure of Personal Information
    1. Personal information shall not be collected unless it is expressly authorized by statute, used for purposes of law enforcement, or necessary to the proper administration of a lawfully authorized activity of the SA.
    2. The SA shall collect personal information necessary to accomplish the SA’s operational activities. The SA collects and uses personal information for the following purposes:
      1. recruitment, admission and registration, in non-academic programs, services and activities offered or administered by the SA from time to time
      2. review, evaluation and improvement of the foregoing
      3. financial assistance and awards
      4. alumni, development and marketing activities
      5. corporate planning, research and statistics
      6. reporting to government agencies and professional licensing bodies
      7. employment related matters
      8. safety and security
      9. promotion in its print electronic and internet publications.
    3. In order to facilitate these purposes and to develop, maintain and improve appropriate programs, policies and recruitment strategies, measure program performance, and evaluate future program needs, the SA may aggregate or link personal information in different databases over which it has custody or control.
    4. The SA remains accountable for personal information under its control, including personal information which is disclosed to third parties for processing. The SA will use contractual or other means to protect personal information that has been transferred to service providers for processing.
    5. Personal information collected by the SA may be collected, used and/or disclosed in other jurisdictions for processing, including in some cases to service providers located in the United States of America.
    6. Personal information shall only be collected by the SA directly from the individual to whom the information relates unless:
      1. the information is collected by a third party and disclosed to the SA with the consent of the individual if required and in accordance with that third party’s privacy policies
      2. the individual authorizes another manner of collection;
      3. the information is collected for the purpose of determining suitability for an honour or award to recognize outstanding achievement or distinguished service;
      4. the information is collected for the purpose of the conduct of a proceeding or a possible proceeding before a court of tribunal;
      5. the information is collected for the purpose of law enforcement; or
      6. otherwise in accordance with provisions of applicable law and regulation.
    7. Where personal information is collected, the SA shall inform the individual to whom the information relates of the following:
      1. the legal authority for the collection;
      2. the principal purpose(s) for which the information is intended to be used; and
      3. the address and telephone number of an employee who can answer questions about the collection.

      The SA provides the information required by this section in a variety of ways, including through this policy, through statements or notices posted on the SA’s website, on application or other forms.

    8. Individuals have a right to “opt out” or withdraw consent to some or all uses and/or disclosures of their personal information. Depending on the use or disclosure in question, opting out or withdrawing consent may impact the SA’s ability to provide services to the individual, and may even prevent the individual from continuing as a member or employee of the SA. The extent to which an opt-out request can be granted without impacting the SA’s ability to provide services to the individual will be assessed on a case by case basis. Inquiries regarding opt-out and withdrawal of consent should be addressed to the Privacy Officer.
    9. The SA shall not use personal information in its custody or under its control except:
      1. where the person to whom the information relates has identified that information in particular and consented to its use;
      2. for the purpose for which it was obtained or compiled or for a consistent purpose; or
      3. otherwise in accordance with provisions of applicable law and regulation.
    10. The SA shall not disclose personal information in its custody or under its control except:
      1. where the person to whom the information relates has identified that information in particular and consented to its disclosure;
      2. for the purpose for which it was obtained or compiled or for a consistent purpose;
      3. where the disclosure is made to a staff member, or consultant or agent engaged by the SA, who needs the record in the performance of his or her duties and where disclosure is necessary and proper in the normal course of business;
      4. in compassionate circumstances to facilitate contact with the spouse, a close relative or a friend of an individual who is injured, ill or deceased; or
      5. otherwise in accordance with provisions of applicable law and regulation.
    11. The SA shall provide any person with a right of access upon request to his or her own personal information in the SA’s possession, provided it can be described with sufficient specific information to make it reasonably retrievable by the SA. The right of access is subject to the exemptions and exclusions prescribed by applicable law and regulation.
    12. Every individual who is given access to personal information is entitled to:
      1. request correction of the personal information where the individual believes there is an error or omission therein; and
      2. require that a statement of disagreement be attached to the information reflecting any correction that was requested but not made.
    13. All reasonable steps shall be taken to protect the security and confidentiality of personal information during its collection, storage, transportation, handling and destruction. All reasonable steps shall be taken to ensure that when personal information is to be destroyed, it is destroyed in such a way that it cannot be reconstructed or retrieved.
    14. Information collected or created by the SA shall be maintained in accordance with legislative or other record retention requirements.
    15. The SA at its discretion may choose to destroy records it is no longer obliged to protect and retain.
    16. The SA will provide information about its privacy policies and practices when and where appropriate, including by use of the Privacy Statement attached as Appendix 3.
  4. Privacy Officer
    1. The Privacy Officer appointed by the General Manager and CEO shall be responsible for the coordination of activities related to privacy of Personal Information and Records relating thereto for the SA.
    2. The Privacy Officer shall be the contact person for all public inquiries regarding the foregoing matters. The Privacy Officer shall review all requests for access and rule on refusals, exemptions, transfers severance and third-party notification. The Privacy Officer will rely on his/her knowledge of applicable laws and regulation and seek legal counsel if necessary to ensure that the SA is in compliance with such legislation.
    3. The Privacy Officer will coordinate the search and the release of records.
    4. The Privacy Officer shall document information on all requests received, the rationale for decisions on access and the disposition of the requests. A tracking and recording system will be used to ensure that all requests are processed within the established time limits and to generate the statistics for annual reporting as required.
    5. The Privacy Officer shall require the assistance of the General Manager and CEO to monitor compliance with the privacy provisions and the notification requirements under applicable law and regulation and in this policy.

Supporting Documentation

Appendix 1 Selected Definitions
Appendix 2 SA Privacy Statement

Appendix 1

SELECTED DEFINITIONS

  1. “Personal information” means recorded information about an identifiable individual, including,
    1. information relating to the race, national or ethnic origin, colour, religion, age, sex, sexual orientation or marital or family status of the individual,
    2. information relating to the education or the medical, psychiatric, psychological, criminal or employment history of the individual or information relating to financial transactions in which the individual has been involved,
    3. any identifying number, symbol or other particular assigned to the individual,
    4. the address, telephone number, fingerprints, or blood type of the individual,
    5. the personal opinions or views of the individual except where they relate to another individual,
    6. correspondence sent to an institution by the individual that is implicitly or explicitly of a private or confidential nature, and replies to that correspondence that would reveal the contents of the original correspondence,
    7. the views or opinions of another individual about the individual, and
    8. the individual’s name where it appears with other personal information relating to the individual or where the disclosure of the name would reveal other personal information about the individual.
  2. “Record” means any record of information however recorded, whether in printed form, on film, by electronic means or otherwise, and includes,
    1. correspondence, a memorandum, a book, a plan, a map, a drawing, a diagram, a pictorial or graphic work, a photograph, a film, a microfilm, a sound recording, a videotape, a machine-readable record, any other documentary material, regardless of physical form or characteristics, and any copy thereof, and
    2. any record that is capable of being produced from a machine-readable record under the control of an institution by means of computer hardware and software or any other information storage equipment and technical expertise normally used by the institution; (“document”).
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