The United Food and Commercial Workers, Local 247 Privacy Code
The United Food and Commercial Workers, Local 247 is committed to the highest level of integrity in our dealings with our members and their families. Our commitment extends to any personal information that we may possess or obtain about our members and their families.
We have developed a principles statement regarding the protection of personal information about our members and their families. We have also developed policies regarding our management, collection, use and disclosure of personal information that gives content to the principles statement.
The ten principles contained in this Privacy Code represent the basis of the Local's approach to privacy issues.
Principle 1 - Accountability
Each employee of the United Food and Commercial Workers, Local 247 is responsible for personal information under his or her control. The Local has designated an individual to be accountable for compliance with this Code. That person is Charles Pratt.
Principle 2 - Identifying Purposes
The purposes for which personal information is collected by the Local shall be identified orally or in writing before or at the time the information is collected. The general purposes for which most information is collected by the Local are described below.
Principle 3 - Obtaining Consent
Except as otherwise authorized by law, the prior knowledge and consent of the individual is required for the collection, use or disclosure of personal information by the Local.
Principle 4 - Limiting Collection of Personal Information
The collection of personal information by the Local shall be limited to that which is necessary for the purposes identified by the Local for the use of that personal information. Personal information will be collected by fair and lawful means.
Principle 5 - Limiting Use, Disclosure and Retention
Personal information will not be used or disclosed to others by the Local for purposes other than those for which the information was collected, except with the consent of the individual, or as permitted or required by law.
Further, the Local will not retain personal information for longer than the period of time required to fulfill the purposes for which the information was requested unless otherwise required by law.
Principle 6 - Accuracy of Personal Information
Personal information held by the Local will be as accurate, complete and current as is necessary for the identified purposes for which it is to be used.
Principle 7 - Safeguarding Personal Information
Safeguards appropriate to the sensitivity of the information are used by the Local in order to protect personal information.
Principle 8 - Openness
The United Food and Commercial Workers Local 247 will make readily available to its members specific information about our policies and procedures relating to the management of their members' personal information.
Principle 9 - Individual Access
Subject to certain limited exceptions authorized by law, an individual who so requests will be informed of the existence, use and disclosure of his or her personal information and will be given access to it. An individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Principle 10 - Complaints and Suggestions
Individuals can address any complaint or inquiry regarding our Personal Information Protection Policy's compliance with the above principles with our Privacy Officer.
United Food and Commercial Workers Local 247 Personal Information Protection Policy
The Local is governed by the British Columbia Personal Information Protection Act, [SBC 2003], c. 63 ("PIPA"). The purpose of PIPA is to govern the collection, use and disclosure of personal information by organizations in a manner that recognizes both the right of individuals to protect their personal information and the need of organizations to collect, use or disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances.
In order for the Local to operate effectively, the Local requires having knowledge of certain information about our members. Collecting personal information about you is essential to our ability to offer you the benefits of membership in the Local. For example, the administration of the Local requires having knowledge of your membership status and your employment status. We also collect, use, and share with our service provider partners personal information about our members in order to perform various other functions such as issuing income tax receipts for union dues and initiating persons into membership and participation in benefit plans available to members of the Local.
We are committed to protecting your personal information and we take great care to keep your personal information accurate, confidential and secure. Managing the information you provide to us is crucial to the operation and administration of a trade union. We can't operate without the use, collection and (where appropriate) disclosure of your personal information. We have a long history of protecting personal information in a professional and appropriate manner and will continue to do so.
To that end, we are pleased to share with you the following Policy, which reflects our Privacy Code and our commitment to safeguarding our members' personal information.
Our Policy sets high standards for collecting, using, disclosing and storing personal information and is complemented by our Privacy Code and our practices and procedures to manage your personal information. We collect, use or disclose personal information only to provide you with the services and to administer the Local and in compliance with PIPA.
PIPA provides the following definitions:
- "contact information" means information to enable an individual at a place of business to be contacted and includes the name, position name or title, business telephone number, business address, business email or business fax number of the individual;
- "employee personal information" means personal information about an individual that is collected, used or disclosed solely for the purposes reasonably required to establish, manage or terminate an employment relationship between the organization and that individual, but does not include personal information that is not about an individual's employment;
- "personal information"means information about an identifiable individual and includes employee personal information but does not include
- (a) contact information, or
- (b) work product information;
- "work product information" means information prepared or collected by an individual or group of individuals as a part of the individual's or group's responsibilities or activities related to the individual's or group's employment or business but does not include personal information about an individual who did not prepare or collect the personal information.
Collection and Use
- We keep your personal information and the communication you have with us in strict confidence.
- We obtain personal information about you lawfully and fairly.
- We indicate why we need to collect, use and disclose your personal information. Generally, we need to collect your personal information to:
- establish and maintain your membership in the Local;
- administer and adjudicate your rights under the Local's collective agreements;
- initiate your participation in various benefit and insurance plans and to enable our service partners to administer those plans; and
- meet statutory, international union or local union requirements relating to the administration of the Local and other related services provided to you by the Local.
- We will make sure you understand why we need the personal information and what we will use it for using clear, understandable language.
- We ask you for only the information we need and for the purposes we have identified to you. Our files are kept for the purposes of providing you membership in the Local, the benefits of membership in the Local, protecting your rights and the rights of other members under the Local's collective agreements and ensuring the integrity of the Local's administration.
- We do not sell your personal information.
- We do not disclose personal information without your permission except in limited circumstances as permitted or required by law. As further described below, we may share limited personal information with our actuaries, benefit plan administrators, employers, legal counsel, agents, consultants or others who provide or administer the services we offer to our members or in the administration of the affairs of the Local.
- In certain circumstances, personal information will be made available to certain employees of the Local or authorized agents or representative of third parties working in partnership with the Local to provide services or to assist in the Local's administration. Access to personal information in the possession of the Local will be limited to:
- Authorized representatives of our service partners with whom we exchange limited personal information in order to provide you with benefits and services;
- Authorized members of the Local's staff who require access in order to perform work related to the administration of the applicable collective agreements, the processing of various information relating to entitlements or claims for benefits and the general administration of the Local or the International Union;
- Authorized individuals employed by the benefit plan administrator, legal counsel, insurance companies, auditing firms, and other service providers that work together with the Local and who require access to personal information in order to perform work related to the processing or adjudication of claims, benefits and the general enforcement and application of the Local's collective agreements and benefit plans;
- Other authorized persons employed by the United Food and Commercial Workers Local 247 or the International who require access to personal information in order to determine the rights and obligations of members;
- In the case of matters contemplated by the Local's collective agreements very limited personal information may be required to be shared with employers;
- Individuals to whom the Local's members have granted access to their personal information; and
- Individuals authorized by law to have access to personal information.
- Where we do disclose information to other parties, such as the benefit plan administrator, we do so in accordance with applicable law and take all reasonable precautions regarding the practices employed by the third party to protect your personal information. We do not disclose more personal information than is necessary.
- We will obtain your consent to collect, use or share your personal information, except where we are we are legally authorized or required by law to do so without consent. Your consent or permission may be express or may be implied. You may give us permission or consent verbally, electronically, through your authorized representative or by requesting the Local to perform a service on your behalf where the purposes for the use, collection and/or disclosure of personal information are obvious and the use, collection and/or disclosure is necessary to perform the service.
- You may withdraw your permission for the Local to collect, use and disclose your personal information at any time, subject to legal and contractual restrictions and reasonable notice. We will honour your withdrawal of permission and will inform you if the withdrawal of your consent makes it impossible for the Local to continue providing you with a service or services so that you may make an informed decision about the consequence of withdrawing consent.
- You may not withdraw your consent if withdrawing the consent would frustrate the Local's performance of a legal obligation.
- Before we make information available to third parties, other than an agent or authorized service provider who needs it as contemplated by this Policy, we will tell you at the time we obtain your consent or before we make the information available, who those persons or organizations are, the kind of information we want to share with them and why we need to share it with them.
Storage and Retention
- We will limit how long we keep personal information. We will keep your personal information as long as it is necessary, or as long as may be required by law. We will keep personal information used to make a decision that directly affects individuals for at least one year after the decision is made.
- We will protect your personal information, including information transferred to a third party service provider or agent. All employees, agents and authorized service providers are required by the Local to protect the confidentiality of your personal information.
- We protect your information against accidental modification, unauthorized access, accidental disclosure, unauthorized copying or theft. We have developed and are continuing to enhance security procedures to safeguard and protect personal information against loss, theft, unauthorized disclosure, copying and unauthorized use or modification. We will maintain appropriate safeguards and security procedures that reflect the types of documents, including electronic or paper records, organizational measures including limiting access on a "need-to-know" basis, and technological measures such as the use of passwords and encryption for electronic information and physical security measures such as locks for paper records. While we endeavour to protect all information, the most sensitive information, such as medical information, receives the highest level of protection.
- When we destroy personal information, we will use reasonably secure safeguards to prevent unauthorized parties from gaining access to the information during the destruction process.
- We maintain appropriate procedures to ensure that personal information in our possession is accurate and, where necessary, kept up to date.
- If you believe any of the information we have collected about you is incorrect or incomplete, you have the right to ask us to change it. If you show that your personal information is inaccurate or incomplete, we will make the necessary changes. If you feel we have not dealt with your request to your satisfaction, you can follow our complaint resolution procedures by contacting our Privacy Officer.
- The Local will, as soon as is reasonably possible, send an individual's corrected information to every organization it was disclosed to during the year before it was corrected.
Openness and Access
- Access to your personal information is restricted to those employees of the Local and authorized service providers who need it to do their jobs.
- Subject to certain exceptions required by law, you have the right to ask whether we hold any personal information about you and to see that information, as provided by law. You also have the right to know:
- a. How we collected your personal information;
- b. How we are using it; and
- c. To whom it may have been disclosed.
- Requests to access your personal information should be made in writing to the Local. You may be asked prove your identity before you are allowed access. The requested information will be provided within 30 business days or you will receive written notice that the Local needs more time to respond.
- If the Local refuses to provide access to personal information that you have requested, it will tell you the reason for its refusal and will provide contact information for an individual who can answer questions about why your request was refused.
- The Local may charge you a minimal fee for access to personal information that is not employee personal information.
- You may register a privacy-related complaint by contacting the Local's Privacy Officer. We will explain our complaint procedure to you and investigate all complaints. If a complaint is justified, we will take all appropriate steps including amending our records of your personal information and, if necessary, changing our policies and practices.
- If the Local is unable to resolve your complaint, we will let you know what other complaint procedures may be available to you and will provide you with information about how you can make a complaint to the Office of the Information and Privacy Commissioner for British Columbia.
Our Privacy Officer
The United Food and Commercial Workers Local 247 has appointed a Privacy Officer responsible for ensuring that the Privacy Guidelines and Principles are followed. The Privacy Officer also ensures that the Local complies with its obligations under PIPA.
The Privacy Officer can also be contacted in writing at:
UFCW Local 247
#200 - 14936 32nd Avenue
Surrey BC V4P 3R5
Last Revised September 28, 2012