Personal Information Protection Policy
At McLean's Novels, we are committed to providing our members with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our members, protecting their personal information is one of our highest priorities.
While we have always respected our members 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 members 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 members' personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our members' personal information and allowing our members to request access to, and correction of, their personal information.
Scope of this Policy
This Personal Information Protection Policy applies to McLean's Novels. This policy also applies to any service providers collecting, using or disclosing personal information on behalf of McLean's Novels.
Personal Information –means information about an identifiable individual. 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 McLean's Novels complies with this policy and PIPA.
Policy 1 – Collecting Personal Information
1.1Unless the purposes for collecting personal information are obvious and the member 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.
1.2We will only collect member information that is necessary to fulfill the following purposes:
- To verify identity;
- To identify [member] preferences;
- To deliver requested products and services
- To ensure a high standard of service to our members.
Policy 2 – Consent
2.1We will obtain member consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2Consent can be provided orally, in writing, electronically, or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the member voluntarily provides personal information for that purpose.
2.3Consent may also be implied where a member is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products, and the member does not opt-out.
2.4Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), members can withhold or withdraw their consent for McLean's Novels to use their personal information in certain ways. A member's 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 member in making the decision.
2.5We may collect, use or disclose personal information without the member's 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);
- When we require legal advice from a lawyer;
- To protect ourselves from fraud.
Policy 3 – Using and Disclosing Personal Information
3.1We will only use or disclose member personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
- To conduct member surveys in order to enhance the provision of our services;
- To contact our members directly about products and services that may be of interest;]
3.2We will not use or disclose member personal information for any additional purpose unless we obtain consent to do so.
3.3We will not sell member lists or personal information to other parties unless we have consent to do so.
Policy 4 – Retaining Personal Information
4.1If we use member personal information to make a decision that directly affects the member, we will retain that personal information for at least one year so that the member has a reasonable opportunity to request access to it.
4.2Subject to policy 4.1, we will retain member personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1We will make reasonable efforts to ensure that member personal information is accurate and complete where it may be used to make a decision about the member or disclosed to another organization.
5.2Members 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.
5.3If 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. If the correction is not made, we will note the members' correction request in the file.
Policy 6 – Securing Personal Information
6.1We are committed to ensuring the security of member personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2The following security measures will be followed to ensure that member personal information is appropriately protected:
- The use of user IDs, passwords, encryption, firewalls.
6.3We will use appropriate security measures when destroying member's personal information such as deleting electronically stored information.
6.4We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Policy 7 – Providing Members Access to Personal Information
7.1Members have a right to access their personal information, subject to limited exceptions.
- Disclosure would reveal personal information about another individual
7.2A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3Upon request, we will also tell members how we use their personal information and to whom it has been disclosed if applicable.
7.4We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the member of the cost and request further direction from the member on whether or not we should proceed with the request.
7.6If a request is refused in full or in part, we will notify the member in writing, providing the reasons for refusal and the recourse available to the member.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1The Privacy Officer or designated individual is responsible for ensuring McLean's Novels’ compliance with this policy and the Personal Information Protection Act.
8.2Members should direct any complaints, concerns or questions regarding McLean's Novels’ compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the member may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for McLean's Novels’ Privacy Officer or designated individual: Jeremy@McLeansNovels.com