At Eastfield, we are committed to
providing our guests with exceptional service.
As providing this service involves the collection, use and disclosure of
some personal information about our guests, protecting their personal
information is one of our highest priorities.
While we have always respected our
guest’s 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 guests 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 guests’ personal information. Our
privacy commitment includes ensuring the accuracy, confidentiality, and
security of our guests’
personal information and allowing our guests to request access to, and
correction of, their personal information.
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.
Policy
1 – Collecting Personal
Information
1.1 Unless the purposes for collecting personal
information are obvious and the guest 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.
2.4 We will only collect guest information that is
necessary to fulfill the following purposes:
·
To
verify identity;
·
To
verify creditworthiness;
·
To
guarantee a reservation;
·
To
meet regulatory requirements;
Policy 2 – Consent
2.1 We will obtain guest 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 or it can be implied
where the purpose for collecting using or disclosing the personal information
would be considered obvious and the guest voluntarily provides personal
information for that purpose.
2.3 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),
guests can withhold or withdraw their consent for Eastfield to use their
personal information in certain ways. A
guest’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 guest in making the decision.
2.4 We may collect, use or
disclose personal information without the guest’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;
·
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 guest personal
information where necessary to fulfill the purposes identified at the time of
collection.
3.2 We will not use or disclose guest personal
information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell guest lists or personal information
to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use guest personal information to make
a decision that directly affects the guest, we will retain that personal
information for at least one year so that the guest has a reasonable
opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain guest
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 guest personal information is accurate and complete where it may be used
to make a decision about the guest or disclosed to another organization.
5.2 Guests 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 guests’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of
guest personal information in order to protect it from unauthorized access,
collection, use, disclosure, copying, modification or disposal or similar
risks.
6.2 We will use appropriate security measures to
ensure that guest personal information is properly protected:
6.3 We will use appropriate security measures
when destroying guests personal information.
6.4 We will continually review and update our
security policies and controls as technology changes to ensure ongoing personal
information security.
Policy 7 – Providing Guests Access to Personal Information
7.1
Guests have a right to access their personal information, subject to
limited exceptions.
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 also tell guests how
we use their personal information and to whom it has been disclosed if
applicable.
7.4 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.
7.5 A minimal fee may be charged for providing
access to personal information. Where a
fee may apply, we will inform the guest of the cost and request further
direction from the guest on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part,
we will notify the guest in writing, providing the reasons for refusal and the
recourse available to the guest.
Policy 8 – Questions and Complaints:
8.1 Guests should direct any complaints, concerns or questions regarding Eastfield’s compliance in writing. If we are unable to resolve the concern, the guest may also write to the Information and Privacy Commissioner of British Columbia.