Purpose of the Policy
Fanshawe College Student Union (“FSU” or “we/us”) may collect personal information in the course of its activities. FSU is a non-share capital corporation governed by the Ontario Not-for-profit Corporations Act, 2010.
FSU is committed to ensuring compliance with the Canada Personal Information Protection and Electronic Documents Act (“PIPEDA”) and all other applicable privacy legislation.
The purpose of this Privacy Policy is to establish rules that govern the collection, use, disclosure, and retention of personal information by FSU in a manner that recognizes the need to balance an individual’s right of privacy with respect to personal information and FSU’s need to collect, use, and/or disclose that information in order to fulfill its purposes.
This Policy is expected to change as the body of knowledge in this area grows and as the environment within which FSU operates evolves. FSU will post and explain any changes to this Privacy Policy as soon as they go into effect.
By providing us with your Personal Information, you are consenting to the collection, use, disclosure, and retention, by us, of your Personal Information, as set out in this Policy.
Scope
All employees, members, directors, officers, representatives, consultants, contractors, agents, and other persons who act or provide services on behalf of FSU shall be subject to this Policy.
Definitions
Personal Information – Personal information is any factual or subjective information, recorded or not, about an identifiable person (e.g. age, name, address, income, phone number, etc.). Personal information does not include the name, title, or business address or telephone number of an employee of an organization.
Personal information could be obtained by interacting with FSU websites (and affiliated websites), databases, applications, Application Programming Interfaces (APIs), employees, and contractors.
Policy
While interacting or communicating with us, you do not need to provide any information about yourself. However, if you choose to provide Personal Information to us, we will take the necessary steps to safeguard it to the furthest extent possible.
FSU is committed to ensuring that all personal information gathered by FSU is kept confidential and is treated in a manner that a reasonable person would consider appropriate in the circumstances.
All personal information under the control or custody of FSU shall be regarded as confidential and available only to authorized users. Subject to specific limitations and exceptions, individuals (or their legal representatives) may access their own personal information contained in records under the custody or control of FSU following the process outline in this Policy.
FSU’s websites were not designed and are not directed to children sixteen (16) years of age or younger. Committed to protecting children’s privacy in an on-line environment, we do not intentionally collect or maintain Personal Information provided by children.
The following are FSU’s key privacy principles, based on Schedule 1 of PIPEDA:
1. Accountability for Personal Information
FSU shall be responsible for the personal information in its custody or control, including information that has been transferred to a third party for processing. FSU shall use contractual or other means to ensure the protection of any information in the possession of a third party. FSU’s employees and agents shall be responsible for any personal information that they have in their possession at all times.
FSU has a Privacy Officer that is committed to ensuring FSU’s compliance with PIPEDA, to the extent that such Act applies to FSU.
2. Identifying Purposes for Collecting Personal Information
FSU shall collect your personal information for the primary purposes of:
- providing services or programs;
- processing a payment or fulfilling other administrative duties;
- creating internal reports and statistical analyses on web usage levels; and/or
- complying with any other legal obligations owing by us to you.
When personal information is required to be collected from an individual, FSU will identify and document the purpose for which it is being collected, will explain how it will be used, and will obtain the individual’s consent to collect, use, and disclose it. FSU will use reasonable efforts to ensure that the individual reasonably understands how the information will be used and disclosed.
If personal information that has been collected is required to be used for a different purpose than originally disclosed, the new purpose will be identified to the relevant individual prior to use. Unless the new purpose is required or permitted by law, such individual’s consent will be obtained before the information is used for that new purpose.
3. Consent for Collection, Use, and Disclosure of Personal Information
Consent is required for the collection of personal information and the use and disclosure of such information. FSU shall seek consent for the use and disclosure of personal information either prior to or at the time of collection.
In determining the form of consent to collect, use, or disclose personal information (implied/express, verbal/written), FSU will take into account the sensitivity of the information and applicable legal requirements. Regardless of the form of consent given, FSU will ensure that the consent is knowledgeable, voluntary, related to the information in question, and given by the relevant individual.
Consent may be withdrawn at any time, subject to legal restrictions and reasonable notice. If an individual would like to withdraw consent to FSU’s use of such individual’s personal information, such individual can do so by contacting the FSU Privacy Officer at 519-452-4109 x16311. A withdrawal of consent will not apply to a collection, use, or disclosure that had occurred prior to receiving the notice of withdrawal.
4. Limiting Collection of Personal Information
The collection, use, and disclosure of personal information will be limited to that which is necessary to fulfill the purposes identified.
5. Limiting Use, Disclosure, and Retention of Personal Information
FSU will only use personal information for the purposes for which consent has been given.
FSU may provide personal information to other parties:
- when consent to do so has been provided; and/or
- when FSU is required or permitted to do so by law.
Personal information will be kept until the stated purpose is complete and the relevant individual has exhausted any legal recourse regarding an access request. At such time, or at the end of the legislatively required retention period, whichever is longer, the personal information will be disposed of by means of shredding or another secure disposal method, with care taken to prevent unauthorized parties from gaining access to the information.
6. Ensuring Accuracy
While FSU will use reasonable efforts to ensure that an individual’s personal information is as accurate, complete, and up-to-date as necessary for the purposes for which FSU uses the information, ultimately, an individual will be responsible for ensuring that FSU has such individual’s current and complete personal information in FSU’s records. FSU will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the information was collected.
7. Use of Safeguards to Protect Information
FSU will use appropriate procedures and security measures to protect personal information in its custody or control against theft, loss, and unauthorized use, disclosure, modification, or disposal, regardless of the format in which the information is held.
The methods of protection may include the following:
- locked filing cabinets;
- restricted access to offices;
- alarm system;
- confidentiality agreements with staff and volunteers; and/or
- use of passwords, access controls, and encryption.
The personal information collected by FSU may be shared, stored, or accessed in Canada or in other countries where FSU maintains an office, conducts business, and/or has internet facilities.
If personal information is stolen, lost, or accessed by an unauthorized person, FSU will notify the relevant individual(s) and/or other third parties (such as the Privacy Commissioner) at the first reasonable opportunity, if required to do so by applicable law.
FSU does not sell, rent, or lease personal information to third parties.
8. Openness About Privacy Policy
This Privacy Policy will be available on the main FSU website at www.fsu.ca
9. Individual Access to Personal Information
Upon written request, and proof of identification, FSU will inform an individual whether or not it holds personal information about the individual. FSU will allow the individual to access this information in accordance with applicable legislation. Certain situations will prevent FSU from providing access to personal information, including for legal, confidentiality, or security reasons; in such situations, FSU will give a written notice to the individual that states that the request for access is being refused, provides reasons for the refusal, and informs the individual that such individual is entitled to make a complaint about the refusal to the Information and Privacy Commissioner of Ontario (if the request relates to personal health information) or to the Office of the Privacy Commissioner of Canada (if the request relates to non-health personal information). FSU will respond to a request for access within thirty (30) calendar days of receipt of the request, unless extensions are permitted under law and FSU has informed the individual of the length and reason for the extension.
If an individual informs FSU about the inaccuracy or incompleteness of such individual’s personal information, FSU will respond to the correction request, with the amendments, within thirty (30) days of receiving the request, unless extensions are permitted under law and FSU has informed the individual of the length and reason for the extension.
In certain circumstances, FSU will not correct a record of personal information, if prohibited from doing so under law. For example, clinical opinions will not be deleted or amended. If a correction is refused, FSU will inform the individual of the refusal, the reasons for the refusal, the individual’s right to file a complaint regarding the refusal to the Information and Privacy Commissioner of Ontario (if personal health information is involved) or to the Office of the Privacy Commissioner of Canada (if non-health personal information is involved), and the right of the individual to attach a statement of disagreement to FSU’s records (so that any other organization that has access to the Information can view the statement).
10. Challenging Compliance
FSU’s Privacy Officer can be contacted at:
John Riddell, Executive Director
Fanshawe Student Union
1001 Fanshawe College Boulevard
London, ON N5Y 5R6
j_riddell2@nullfanshawec.ca
519.452.4109 x16311
FSU’s Privacy Officer is available to answer any questions an individual may have about FSU’s collection, use, disclosure, and retention of personal information, or to register a complaint. An individual whose personal information is held by FSU has several other avenues of recourse, including registering a complaint with the Information and Privacy Commissioner of Ontario (personal health information) or with the Office of the Privacy Commissioner of Canada (non-health personal information). FSU is committed to investigating all complaints and taking appropriate action.
11. Websites
The following FSU websites will be governed by this Privacy Policy:
While providing links to third-party websites, FSU does not guarantee, and is not responsible for, the information collection and privacy practices of such third-party websites, which may differ from our site’s policies. Please review FSU’s Website Terms and Conditions available at https://www.fsu.ca/terms-conditions
