Scope: All employees and volunteers

Policy:  SchoolAdvice is committed to the protection of the personal information of employees and volunteers  

Definitions:

“Collection”
The act of gathering or acquiring or obtaining personal Information from any source

“Contact Information”
Information that enables an individual to be contacted at a place of business, including his or her name, position, business telephone number, business address, business email and business fax number

“Disclose”
To make personal Information available to others outside of SchoolAdvice

“Personal Information”
For the purpose of this policy, personal information means any information about an identifiable individual, excluding contact information, work product information and any publicly available information as designated under applicable laws, such as information available from a public telephone directory or from a public registry

“Use”
The treatment and handling of personal information by and within the School

“Work Product Information”
Information related to an individual’s employment or business, prepared or collected as part of his or her employment or business responsibilities

Purpose:
This policy provides high-level principles regarding the collection, use and disclosure of personal information and the protection of personal information by SchoolAdvice. It also provides notice to employees and volunteers of the purpose of collection, use and disclosure of personal information.

SchoolAdvice will establish procedures to ensure that all personal information that is collected, used and disclosed is protected pursuant to this policy. All employees, volunteers or contractors must abide by the principles set out in this policy.

Accountability
SchoolAdvice is responsible for maintaining and protecting the personal information under its control or in its custody. In fulfilling this mandate, SchoolAdvice designates an individual who is accountable for the SchoolAdvice’s compliance with PIPEDA and with this policy. This individual is the privacy officer of SchoolAdvice. Employees and volunteers may contact the SchoolAdvice privacy officer, who is the Director, Human Resources.

Purposes of Collection, Use and Disclosure of Personal Information
Employees

SchoolAdvice collects, uses and discloses personal information about employees to establish, manage and terminate the employment relationship and for other purposes identified when the information is collected. Set out below are some examples of personal information about employees collected, used and disclosed by SchoolAdvice:

• Personal information collected, used and disclosed in the hiring process, including information on resumes and application forms (contact information, personal and professional history, qualifications, emergency contact information), results of criminal records checks, and information collected from references
• Payroll and related information, including social insurance number, rate of pay, hours of work, deductions, bank account information and any court orders 
• Benefits information, including social insurance number, premiums or contributions, coverage information, date of birth, marital status, dependant information and medical information
• Performance information, including work history, performance reviews, disciplinary and related notes and memoranda, documentation related to job qualifications (professional or technical qualifications) and internal competition information
• personal information gathered through workplace monitoring, such as monitoring of internet or computer usage and email, in accordance with SchoolAdvice’s computer, internet and/or email policies, access and egress through swipe cards, and collection through video surveillance on the premises
• Other personal information as required or permitted by law

Volunteers

SchoolAdvice collects, uses and discloses personal information about volunteers for the purposes of recruiting volunteers and establishing and managing an effective volunteer program and for other purposes identified when the information is collected. Below are some examples of personal information about volunteers that is collected, used and disclosed by the SchoolAdvice: 

• Personal information collected, used and disclosed in the recruiting process, including contact information, and personal and professional history 
• Personal information related to the volunteer’s services, including availability, schedule, duties, reviews and related notes and memoranda, and documentation related to volunteer qualifications (professional or technical qualifications) 
• Personal information collected in the operation and maintenance of computers and email in accordance with the School’s computer, internet and/or email policies

Personal information about employees and volunteers (including photographs and biographical information) may also be collected, used and disclosed in the course of SchoolAdvice’s activities, including in publications such as e-books and newsletters and on websites.

Consent
Requirements for the consent of the collection, use or disclosure of personal information vary depending on circumstances and on the type of personal information that is intended to be collected, used or disclosed. In determining whether consent is required and, if so, what form of consent is appropriate, SchoolAdvice will take into account both the sensitivity of the personal information and the purposes for which SchoolAdvice will use the information. Consent may be express or implied (including through the use of “opt-out” consent where appropriate).

Most personal information is collected, used and disclosed for the reasonable purposes of establishing, managing and terminating the employment or volunteer relationship; therefore, consent is not required. In other cases, consent will be sought where it is reasonable to do so.

From time to time, SchoolAdvice may notify employees and volunteers of other purposes for which it will collect, use or disclose personal information, in which case the School will, if appropriate, obtain consent for the collection, use or disclosure of that personal information.

There are circumstances under which SchoolAdvice may collect, use or disclose personal information without knowledge or consent of the individuals, such as conducting an investigation into breach of contract or law.

Limiting Collection, Use, Disclosure and Retention

SchoolAdvice  will limit the personal information collected to that information necessary for the purposes identified by the School.

SchoolAdvice  may use anonymous information, such as information collected through surveys or statistical information, about employees and volunteers to improve SchoolAdvice’s operations.

SchoolAdvice  may disclose an individual’s personal information to others in connection with the purpose for which it was collected, as consented to by the individual, or as required or permitted by law. Personal information about employees is disclosed to third parties for purposes related to the employment relationship, including:

• Government departments, bodies and agencies, such as the Canada Revenue Agency, WorksafeBC and any Provincial Ministry of Education
• Payroll outsourcers
• Financial institutions, for payroll-related purposes
• Insurance companies and benefits, group RRSP and pension plan administrators, for enrolment in and administration of benefits, plans and claims
• Teacher certification information
• Advisors to SchoolAdvice , including accountants, lawyers and consultants, and other-third party service suppliers
• SchoolAdvice  Foundation(s), as reasonably required by the operations of SchoolAdvice  and the SchoolAdvice Foundation(s)
• Instances when required or permitted by law

Personal information about volunteers may be disclosed for the purposes of establishing and managing an effective volunteer program and for other purposes identified when the information is collected. Personal information may also be disclosed when required or permitted by law.

Personal information will be retained only for the period of time required to fulfil the purpose for which it was collected. Once the personal information is no longer required to be retained to fulfil the purposes for which it was collected and is no longer required or permitted to be retained for legal or business purposes, it will be destroyed or made anonymous. Personal information will be retained for at least one year if it has been used to make a decision about an individual.

Accuracy
SchoolAdvice will take appropriate steps to ensure that personal information collected by SchoolAdvice is as accurate and complete as is reasonably required in connection with the purposes for which it was collected, used or disclosed. Employees and volunteers are responsible for providing up-to-date personal information to SchoolAdvice.

Safeguarding Personal Information
SchoolAdvice will protect personal information with security safeguards that are appropriate to the sensitivity level of the information. Employees and volunteers will be appropriately educated about the importance of privacy, and they are required to follow SchoolAdvice’s policies and procedures regarding the handling of personal information.

An employee’s failure to abide by SchoolAdvice policies may result in discipline, up to and including termination of employment. A volunteer’s failure to do so may result in termination of the volunteer relationship.

Employee files: Employee files are stored in secure filing cabinets. Access to personal information is restricted to authorized employees who have a legitimate reason for accessing it.

Electronic security: SchoolAdvice manages electronic files appropriately, with passwords and security measures that limit access by unauthorized personnel. SchoolAdvice’s security practices are reviewed periodically to ensure that the privacy of personal information is not compromised.

From time to time, personal information about employees and volunteers may be stored or accessed outside Canada, where it may be subject to the lawful access requirements of the applicable jurisdiction.

Openness
SchoolAdvice will make information available to individuals concerning the policies and practices that apply to the management of personal information. Individuals may direct any questions or inquiries about SchoolAdvice’s privacy policies or practices to the SchoolAdvice privacy officer.

Individual Access
SchoolAdvice will inform an individual, upon the individual’s written request, of the collection, use and disclosure of the individual’s personal information and shall give the individual access to it in accordance with the law. The written request must include details regarding the type of information and the reason for the request.

Complaint Process
Individuals may question compliance with the principles above. Questions, concerns and complaints about privacy, confidentiality and personal information handling policies and practices of SchoolAdvice should be directed to the SchoolAdvice privacy officer.