Legal & Privacy Policies
June 16, 2005
The Coaching and Leadership International Inc. Privacy Code sets out our privacy commitment to the protection of our employees, customers and client's personal information. This Privacy Code is built on the ten principles of the Canadian Standards Association (CSA) Model Code for the Protection of Personal Information which was published in March 1996 as a National Standard of Canada that have now been incorporated into both Federal and Provincial privacy laws.
"contact information" means information to enable an individual at a place of business or at a residence to be contacted and includes the name, position name or title, business telephone number, business address, business email or business fax number of the individual
"employee personal information" means personal information about an individual that is collected, used or disclosed solely for the purposes reasonably required to establish, manage or terminate an employment relationship between the organization and that individual, but does not include personal information that is not about an individual's employment.
"organization" means a person, an unincorporated association, a trade union, a trust or a not for profit organization, but does not include:
(a) an individual acting in a personal or domestic capacity or acting as an employee;
(b) a public body;
(c) the Provincial Court, the Supreme Court or the Court of Appeal;
"personal information" means information about an identifiable individual and includes employee personal information but does not include contact information or work product information.
"CLI" means Coaching and Leadership International Inc.
"work product information" means information prepared or collected by an individual or group of individuals as part of the individual's or group's responsibilities or activities related to the individual's or group's employment or business but does not include personal information about the individual who did not prepare or collect the personal information.
Coaching and Leadership International Inc. is a British Columbia company providing HR Research & Development, Proprietary Program Licensing, Executive & Whole-Life Coaching Services, Coaching Certification and Corporate Training. As a mutli-faceted Coaching and Training company focusing extensively on R&D and Licensing, privacy of personal information is a critical customer criteria and priority.
This Privacy Code is intended to set out our commitment to our customers regarding the protection of personal information provided by our employees and customer as reflected in the following principles, policies and procedures. It is also intended to set out the choices available for individuals regarding our collection, use or disclosure of their personal information.
The purpose of this Privacy Code is to articulate clearly our privacy practices respecting the management of personal information collected and used by our Company and to ensure compliance with the federal and provincial privacy laws. It is the intention of this Privacy Code to recognize the needs of our Company to collect, use or disclose personal information versus the right of individuals to protect their personal information. The standard for the collection of personal information by our Company is one of what a reasonable persona would consider appropriate in the circumstances.
CLI is further committed to a continual review and updating of our Privacy Code to ensure that we are keeping pace with changes in technology and industry practices and meets the on-going needs of our employees and customers.
The following ten principles are the basis of the CLI's Privacy Code and shall guide CLI's management of personal information and its privacy practices together with the statutory requirements of the BC Personal Information Protection Act.
1. Accountability - CLI is responsible for personal information under its control including personal information not in the custody of CLI. CLI shall designate one or more individuals to be responsible for ensuring that CLI complies with this Privacy Code and shall make the position name or title and contact information of each individual so designated.
2. Identifying Purposes for Collection of Personal Information - CLI shall identify the purposes for which personal information is collected or before personal information is collected.
3. Obtaining Consent for Collection, Use or Disclosure of Personal Information - CLI shall ensure that consent is obtained from each individual for the collection, use or disclosure of their personal information unless inappropriate. CLI shall recognize and act on any withdrawal of consent by an individual to collect their personal information.
4. Limiting Collection of Personal Information - CLI shall limit the collection of personal information to the purposes identified by CLI and shall only collect personal information using appropriate, fair and lawful means.
5. Limiting Use, Disclosure and Retention of Personal Information - CLI shall not use or disclose personal information for purposes other than for the purpose it was collected unless CLI has the consent of the individual or as provided by law. CLI shall retain personal information for only as long as necessary to meet the purposes of the collection of the personal information.
6. Accuracy of Personal Information - CLI shall ensure that personal information collected, used and disclosed shall be as accurate, complete and up-to date as possible for the purposes for which it has been collected, used and disclosed.
7. Security Safeguards - CLI shall take all appropriate steps to protect the personal information collected, used and disclosed and use security measures appropriate to sensitivity of the personal information.
8. Openness Concerning Policies and Practices - CLI shall ensure that information is made available to employees and customers regarding this Privacy Code and our privacy practices regarding personal information.
9. Customer and Employee Access to Personal Information - CLI shall inform an individual of the collection, use and disclosure of his/her personal information at the individual's request and shall grant access to the individual to such personal information. An individual shall be entitled to challenge the accuracy and completeness of the personal information collected, used or disclosed by CLI and have it amended and or corrected as necessary or appropriate.
10. Challenging Compliance - This Privacy Code and our privacy practices shall include a clear process for responding to complaints that may arise with respect to our handling and managing of personal information of customers and employees. A customer or employee may make a complaint regarding CLI's compliance with its privacy policies and practices to the designated individual in accordance with our complaint process.
Application of the Privacy Code
1.1 CLI meets the definition of organization for the purposes of the BC Personal Information Protection Act. Our Privacy Code is therefore subject to the requirements and regulations of the BC Personal Information Protection Act and our Code applies to personal information of our customers and employees collected, used and disclosed by CLI and to our practices in managing such personal information whether collected, used or disclosed orally, electronically or in writing.
1.2 This Privacy Code does not protect contact information or work product information as defined above.
1.3 There is certain personal information in which this Privacy Code does not apply to:
(a) personal information collected, used or disclosed for personal or domestic purposes,
(b) journalistic, artistic or literary purposes,
(c) for federal act purposes,
(d) for provincial Freedom of Information and Protection of Privacy Act purposes,
(e) personal information in a note, communication or draft decision of decision maker in an administrative proceedings or personal information that relates to the exercise of functions of member or officer of Legislature or Legislative Assembly,
(f) personal information from a document related to a prosecution if all proceedings related to the prosecution have not been completed,
(g) collection of personal information collected before BC Personal Information Protection Act.
2.1 In order to meet its responsibilities for personal information under its possession or control, CLI appoints the Vice President and or his/her designate to be accountable for CLI's compliance with this Privacy Code and its statutory requirements under the Personal Information Protection Act. The Vice President and or his/her designate may appoint one or more persons to act on their behalf with respect to the responsibility for day-to-day management, collection and processing of personal information.
2.2 The contact information of persons designated to be accountable for CLI's compliance shall be made known upon request.
2.3 CLI does not currently provide personal information to third parties. In the event, that CLI does provide personal information to third parties, CLI shall ensure that such third parties have policies and practices in place that provide similar or comparable protection for personal information as CLI.
2.4 CLI shall put in place procedures and practices to give effect to this Privacy Code and shall include:
126.96.36.199 Procedures and practices to protect personal information and to oversee compliance with this Privacy Code;
188.8.131.52 Procedures and practices to receive and respond to requests for personal information, inquiries and complaints
184.108.40.206 Methods and means for training and communicating our privacy procedures and practices to employees; and
220.127.116.11 Methods and means for communicating our privacy procedures and practices to our customers and the public.
Purposes of Collection
3.1 CLI shall only collect, use and disclose personal information of customers and employees for purposes that a reasonable person would consider appropriate in the circumstances and that fulfill the purposes that CLI has disclosed to the individual.
3.2 CLI shall identify and specify orally, electronically or in writing to the employee or customer the purposes for which personal information is collected, used and disclosed at or before the time the personal information is collected.
3.3 CLI collects, uses and discloses personal information only for the following purposes:
Completion of website transactions
Access to restricted website areas
Normal business operations
Other requirements that may appear from time to time
3.4 Designated persons collecting personal information on behalf of CLI shall upon request advise an individual of the purposes for such collection or refer the individual to the Vice President and or his/her designate to provide an explanation.
3.5 CLI shall not collect, disclose or use personal information for any purpose not identified or specified to an individual without obtaining their consent.
4.1 Subject to the exceptions in 2.2 and 2.3 above and 4.3 below, CLI will obtain consent from an individual when collecting, using or disclosing personal information from its customers or employees for the purposes outlined above.
4.2 Consent may be explicit (orally or in writing) or implied. Consent may be implied by CLI where at the time consent is deemed:
4.2.1 the purpose would be considered obvious to a reasonable person;
4.2.2 the individual has voluntarily provided the personal information for that purpose; or
4.2.3 CLI has given notice of the collection of personal information for a specified period in a form that can be reasonably understood of its intention to collect, use or disclose the personal information and the individual is given a reasonable period of time to decline and does not decline and it is reasonable to collect, use or disclose having regard to the sensitivity of the personal information.
4.3 Consent is not required for the following personal information which is permitted to be collected and used from an individual or from a source other than an individual without limitations:
4.3.1 is clearly in the interest of the individual and consent cannot be obtained in a timely way;
4.3.2 is necessary for medical treatment of the individual and individual is unable to give consent;
4.3.3 it is reasonable to expect that the collection or use with the consent of individual would compromise the availability or accuracy of the personal information and the collection is reasonable for an investigation or a proceeding;
4.3.4 where collection or use occurs by observation at a performance, a sports meet or a similar event at which individual voluntarily appears and is open to the public;
4.3.5 is necessary to determine individual's suitability to receive an honour, award or similar benefit such as honorary degree, scholarship or bursary or selected for an athletic or artistic purpose;
4.3.6 organization is credit reporting agency and collection is for a credit report and individual consents at the time the original collection occurs;
4.3.7 is required or authorized by law;
4.3.8 personal information is necessary to facilitate collection of debt owed or payment of debt to an organization; and
4.3.9 collection or use of employee personal information is reasonable for establishing, managing or terminating an employment relationship