Our Commitment to Privacy
Scope of Policy
This Policy addresses personal information about individuals and does not apply to the information collected, used or disclosed with respect to corporate or commercial entities. This Policy does not impose any limits on the collection, use or disclosure of the following information by the Council: your business contact information; and certain publicly available information.
The Council has designated the Membership Chair as the Privacy Officer who is responsible for the Council’s compliance with this Policy. The Privacy Officer may be contacted as described below.
When collecting information, the Council will state the purpose of collection and will provide, on request, contact information for the Privacy Officer who can answer questions about the collection. If you are applying for membership in the Council, the Council collects, uses and discloses your personal information for the purpose of evaluating and considering your membership application. If you are a member of the Council, the Council collects, uses and discloses your personal information for the following purposes:
- to allow the Council to communicate with you;
- to protect the Council and its members from fraud, theft and similar risks;
- to administer and enforce the Council’s Articles of Association and (if applicable) standards of professional conduct;
- to conduct investigations into your professional conduct and to discipline you as permitted by the Council’s Articles of Association;
- to manage your membership in the Council;
- to process and collect membership dues and other fees;
- to organize and invite you to Council meetings and events;
- to include your personal information in the Council’s membership directory (a copy of which is distributed to all members);
- to facilitate the ongoing administration of the Council (e.g., to allow your participation in committees, elections and other governance activities); and
- to comply with the Council’s obligations at law and under the Council’s Articles of Association.
Subject to legal and contractual restrictions, you may instruct the Council to refrain from using or sharing information in some of the ways described above by providing written notification to the Council’s Privacy Officer. If you do so, the Council will inform you of the likely consequences of your instructions.
When personal information that has been collected is to be used for a purpose not previously identified, Council will notify you of the purpose and obtain your consent as described below.
The Council will obtain your consent to collect, use or disclose personal information except where the Council is authorized or required by law to do so without consent. For example, the Council may collect, use or disclose personal information without your knowledge or consent where:
- the information is publicly available, as defined by statute or regulation;
- the Council is obtaining legal advice; or
- the Council reasonably expects that obtaining consent would compromise an investigation or proceeding.
Other exceptions may apply. Your consent can be express, implied or given through an authorized representative such as a lawyer, agent or broker.
Consent may be provided orally, in writing, electronically, through inaction (such as when you fail to notify the Council that you do not wish your personal information collected, used or disclosed for various purposes after you have received notice of those purposes) or otherwise.
The Council will destroy, erase or make anonymous documents or other records containing personal information as soon as it is reasonable to assume that the original purpose is no longer being served by retention of the information and retention is no longer necessary for legal or business purposes.
The Council will take due care when destroying personal information to prevent unauthorized access to the information.
The Council will make a reasonable effort to ensure that personal information it is using or disclosing is accurate and complete. If you demonstrate the inaccuracy or incompleteness of personal information, the Council will amend the information as required. If appropriate, the Council will send the amended information to third parties to whom the information has been disclosed. When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, the Council will annotate the personal information under its control with a note that the correction was requested but not made.
Safeguarding Personal Information
The Council protects the personal information in its custody or control by making reasonable security arrangements to prevent unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks. The Council will take reasonable steps, through contractual or other reasonable means, to ensure that a comparable level of personal information protection is implemented by the suppliers and agents who assist in providing services. Some specific safeguards may include:
- physical measures such as locked filing cabinets;
- organizational measures such as restricting employee access to files and databases as appropriate;
- electronic measures such as passwords and firewalls; and
- investigative measures where the Council has reasonable grounds to believe that personal information is being inappropriately collected, used or disclosed.
When a challenge regarding the accuracy of personal information is not resolved to your satisfaction, the Council will annotate the personal information under its control with a note that the correction was requested but not made.
Where an access request is refused, the Council will notify you in writing, document the reasons for refusal and outline further steps which are available to you.
On request, the Council will provide information regarding its complaint procedures.
Any inquiries, complaints or questions regarding this Policy should be directed in writing to the Council’s Privacy Officer, who is also the Council’s Membership Chair. For contact information please refer to the Council’s Membership Directory, as the holder of that office changes annually.