As of 28 March 2020

Coquitlam Place des Arts Society (“Place des Arts”) provides services to its clients which may involve the collection, use and disclosure of personal information belonging to those clients.  Place des Arts makes its best efforts to comply with British Columbia’s Personal Information Protection Act (PIPA) and other applicable privacy laws with regard to these activities.

We will inform our clients why and how we collect, use and disclose their personal information, obtain their consent where required, and only process their personal information in a manner that a reasonable person would consider appropriate in the circumstances. Further, we will make our best efforts to ensure the accuracy, confidentiality, and security of our clients’ personal information.  Additionally, we allow our clients to request access to, and correction of, their personal information.

This Privacy Statement (Statement) outlines the principles and practices we follow in collecting, using and disclosing our clients’ personal information.

• “Personal Information” is information about an identified or identifiable individual including name, date of birth, home address and phone number, email address, mobile number, health concerns, special needs. Personal information does not include contact information.
• “Contact information” is information that would enable an individual to be contacted at a place of business and includes name, business telephone number and business fax number. Contact information is not covered by this Statement or PIPA.
• “Privacy Officer” is the individual responsible for ensuring that Place des Arts complies with this Statement and other applicable privacy laws. At Place des Arts, the Facilities and Administrative Coordinator is the Privacy Officer.
• “Client” means an individual who receives services from Place des Arts or an individual who pays so that another individual can receive services from Place des Arts, as well as others such as contractors, faculty, employees, volunteers, Members of the Board of Directors, exhibitors (including artisan shop participants), performers and entertainers.

Collecting Personal Information

Unless the purposes for collecting client personal information are obvious and the client voluntarily provides personal information for those purposes, we will communicate the purposes for which such client personal information is being collected, either orally or in writing, before or at the time of collection.

We will only collect client personal information that is necessary to fulfill the following purposes:

• To communicate with the client generally;
• To verify identity;
• To identify client preferences;
• To deliver requested products and services;
• To administer a client’s enrollment in a program, e.g. registration, amendments, cancellations;
• To notify clients of Place des Arts programs, services, events, open houses, exhibitions, performances, fundraising initiatives and related information;
• To collect and process payments;
• To protect against fraud, error or similar activity; or
• To solicit information for potential media profile.

Consent

For any purposes other than those listed above, we will obtain client’s consent to collect, use or disclose personal information unless we are authorized to collect, use or disclose such information without client’s consent.

Consent 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 client voluntarily provides personal information for that purpose.

Consent may also be implied where a client is given a reasonable opportunity to opt-out of the use of his or her personal information for mailings, marketing, or fundraising purposes and the client does not opt-out.

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), client can withhold or withdraw consent for Place des Arts to use his or her personal information in certain ways. A client’s decision to withhold or withdraw 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 client to make the decision.

We may collect, use or disclose personal information without the client’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 advice from a lawyer, accountant or similar professional;
• For the purposes of collecting a debt;
• To protect ourselves from fraud or similar activity; or
• To investigate an anticipated or completed breach of an agreement or a contravention of law.

Using and Disclosing Personal Information

We will only use or disclose client personal information where necessary to fulfill the purposes identified at the time of collection.  We will not use or disclose client personal information for any additional purpose unless we obtain client’s consent to do so.

We will not sell client personal information to other parties, nor do we exchange such personal information with other parties.

Retaining Personal Information

If we use client personal information to make a decision that directly affects that client, we will retain that personal information for at least one year.  Otherwise, we will retain client personal information for the period required by applicable law and business purposes.

Ensuring Accuracy of Personal Information

We will make reasonable efforts to ensure that client personal information is accurate and complete.  Client may request correction to his or her personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made with sufficient detail to identify the inaccurate personal information and the correction being sought, and should be forwarded to the Privacy Officer.

If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required.

Securing Personal Information

We are committed to ensuring the security of client personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

The following security measures will be followed to ensure that client personal information is appropriately protected:

• Physically securing offices where personal information is held;
• Secured server and network including use of user IDs and passwords;
• Restricting employee access to personal information only as necessary;
• Contractually requiring any service providers to provide comparable security measures

We will use appropriate security measures when destroying client’s personal information.

As technology changes, we will continually review and update our security policies and controls to ensure ongoing personal information security.

Providing Client Access to Personal Information

Clients have a right to access their personal information, subject to limited exceptions.  A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer.  We 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.  A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the client of the cost, and request further direction from the client on whether or not we should proceed with the request.

Upon request, we will also tell clients how we use their personal information and, if applicable, to whom it has been disclosed.

Collection, Use and Disclosure of Client’s Personal Information by Third Parties

We use software provided by The Active Network Ltd.  The Active Network Ltd. separately collects, uses and discloses client’s personal information.  The Active Network Ltd.’s collection, use and disclosure of a client’s personal information is controlled by the Privacy Policy posted on the website of The Active Network Ltd.  A client should regularly review that Privacy Policy in order to be aware of the activities of The Active Network Ltd. related to client’s personal information.

Any clients who engage in online instruction are encouraged to make themselves familiar with the personal data collection practices of the platforms so used.

Questions and Complaints: The Role of the Privacy Officer

Clients should direct any complaints, concerns or questions regarding Place des Arts’ privacy practices in writing to the Privacy Officer c/o Place des Arts, 1120 Brunette Avenue, Coquitlam, British Columbia, V3K 1G2 or info@placedesarts.ca. If the Privacy Officer is unable to resolve the concern, the client may also contact the Information and Privacy Commissioner of British Columbia.