Personal Information Protection Policy
At Hannah Hicks Art™, we are committed to providing our members and customers with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our members and customers, protecting their personal information is one of our highest priorities.
Our commitment to safeguard our customers’ and members’ privacy and personal information is in accordance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA). PIPEDA sets out the ground rules for how Canadian businesses may collect, use and disclose personal information.
We will inform our customers and 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 PIPEDA, outlines the principles and practices we will follow in protecting customers’ and members’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our customers’ and members’ personal information and allowing our customers and members to request access to, and correction of, their personal information.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the customer or 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.
1.2 We will only collect customer and member information that is necessary to fulfill the following purposes:
2.1 We will obtain customer and member consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided by email, by joining the Hannah Hicks Art™ mailing list, or by purchasing a product from Hannah Hicks Art™ or it can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the customer or member voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a customer or 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.
2.4 Subject 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), a customer or member can withhold or withdraw their consent for Hannah Hicks Art™ to use their personal information in certain ways. A customers’ or 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.
2.5 We may collect, use or disclose personal information without the customer’s and member’s knowledge or consent in the following limited circumstances:
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose customer and member personal information where necessary to fulfill the purposes identified at the time of collection such as:
3.3 We will not sell customer or member lists or personal information to other parties.
3.4 Users or members of the Hannah Hicks Art™ website may choose to disclose personal information in a public forum such as in comments on the blog. Any user or member who chooses to disclose his or her personal information in a public forum associated with Hannah Hicks Art™ acknowledges that information can be seen by anyone, and that any identifying details, posts, images, etc. they choose to share are not subject to privacy protection.
Policy 4 – Retaining Personal Information
4.1 If we use customer or member personal information to make a decision that directly affects the customer or member, we will retain that personal information for at least one year so that the customer or member has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain customer or 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
5.1 We will make reasonable efforts to ensure that customer or member personal information is accurate and complete where it may be used to make a decision about the member or disclosed to another organization.
5.2 Customers and members 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.
5.3 If 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 customers’ or members’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We 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.
6.2 The following security measures will be followed to ensure that member personal information is appropriately protected:
Policy 7 – Providing Customers and Members Access to Personal Information
7.1 Customers and members have a right to access their personal information, subject to limited exceptions such as if disclosure would reveal personal information about another individual.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will tell customers and members how we use their personal information and to whom it has been disclosed if applicable.
7.4 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the customer or member of the cost and request further direction from him or her on whether or not we should proceed with the request.
7.5 If a request is refused in full or in part, we will notify the customer or member in writing, providing the reasons for refusal and the recourse available to the customer or member.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer
8.1 The Privacy Officer is responsible for ensuring Hannah Hicks Art’s™ compliance with this policy and the Personal Information Protection and Electronic Documents Act (PIPEDA).
8.2 Customers or members should direct any complaints, concerns or questions regarding Hannah Hicks Art’s™ compliance in writing to the Privacy Officer.
Contact information for Hannah Hicks Art™, Privacy Officer, Jill Hicks:
103-287 Lacewood Drive, Suite 210, Halifax NS B3M 3Y7
Our commitment to safeguard our customers’ and members’ privacy and personal information is in accordance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA). PIPEDA sets out the ground rules for how Canadian businesses may collect, use and disclose personal information.
We will inform our customers and 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 PIPEDA, outlines the principles and practices we will follow in protecting customers’ and members’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our customers’ and members’ personal information and allowing our customers and members to request access to, and correction of, their personal information.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the customer or 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.
1.2 We will only collect customer and member information that is necessary to fulfill the following purposes:
- To verify identity;
- To identify member preferences;
- To open and manage a membership account;
- To deliver requested products and services;
- To send out membership information;
- To complete membership surveys;
- To contact our members for fundraising;
- To ensure a high standard of service to our members;
- To meet regulatory requirements;
2.1 We will obtain customer and member consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided by email, by joining the Hannah Hicks Art™ mailing list, or by purchasing a product from Hannah Hicks Art™ or it can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the customer or member voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a customer or 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.
2.4 Subject 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), a customer or member can withhold or withdraw their consent for Hannah Hicks Art™ to use their personal information in certain ways. A customers’ or 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.
2.5 We may collect, use or disclose personal information without the customer’s and 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;
- When the personal information is available from a public source (e.g., a telephone directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose customer and member personal information where necessary to fulfill the purposes identified at the time of collection such as:
- To register members, to add clients to our mailing list, to provide products or services;
- To conduct customer or member surveys in order to enhance the provision of our services;
- To contact our customers and members directly about products and services that may be of interest;
3.3 We will not sell customer or member lists or personal information to other parties.
3.4 Users or members of the Hannah Hicks Art™ website may choose to disclose personal information in a public forum such as in comments on the blog. Any user or member who chooses to disclose his or her personal information in a public forum associated with Hannah Hicks Art™ acknowledges that information can be seen by anyone, and that any identifying details, posts, images, etc. they choose to share are not subject to privacy protection.
Policy 4 – Retaining Personal Information
4.1 If we use customer or member personal information to make a decision that directly affects the customer or member, we will retain that personal information for at least one year so that the customer or member has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain customer or 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
5.1 We will make reasonable efforts to ensure that customer or member personal information is accurate and complete where it may be used to make a decision about the member or disclosed to another organization.
5.2 Customers and members 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.
5.3 If 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 customers’ or members’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We 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.
6.2 The following security measures will be followed to ensure that member personal information is appropriately protected:
- Member accounts will be password protected by a password of the member’s choice;
- Personal information will be stored on a computer with a firewall;
- Employee access to personal information will be restricted to employees who need to access such information for customer service
Policy 7 – Providing Customers and Members Access to Personal Information
7.1 Customers and members have a right to access their personal information, subject to limited exceptions such as if disclosure would reveal personal information about another individual.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will tell customers and members how we use their personal information and to whom it has been disclosed if applicable.
7.4 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the customer or member of the cost and request further direction from him or her on whether or not we should proceed with the request.
7.5 If a request is refused in full or in part, we will notify the customer or member in writing, providing the reasons for refusal and the recourse available to the customer or member.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer
8.1 The Privacy Officer is responsible for ensuring Hannah Hicks Art’s™ compliance with this policy and the Personal Information Protection and Electronic Documents Act (PIPEDA).
8.2 Customers or members should direct any complaints, concerns or questions regarding Hannah Hicks Art’s™ compliance in writing to the Privacy Officer.
Contact information for Hannah Hicks Art™, Privacy Officer, Jill Hicks:
103-287 Lacewood Drive, Suite 210, Halifax NS B3M 3Y7
