| Â Personal Information Protection Policy |
|  Personal Information Protection Policy Union Global Enterprise Ltd o/a Go Local Shops  Personal Information Protection Policy  At Union Global Enterprise Ltd o/a Go Local Shops, we are committed to providing our clients, customers, and visitors with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, customers, and visitors, protecting their personal information is one of our highest priorities.  While we have always respected our clients, customers, and visitors 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 clients, customers, and visitors 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 clients’, customers’, and visitors’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’, customers’, and visitors’ personal information and allowing our clients, customers, and visitors to request access to, and correction of, their personal information. Scope of this Policy  This Personal Information Protection Policy applies to Union Global Enterprise Ltd o/a Go Local Shops and its subsidiaries, Go Local Shops. This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Union Global Enterprise Ltd o/a Go Local Shops.  Definitions  Personal Information –means information about an identifiable individual [OPTIONAL ADDITION: consider providing examples of personal information your organization collects. E.g., including name, age, home address and phone number, social insurance number, marital status, religion, income, credit history, medical information, education, employment information]. Personal information does not include contact information (described below).  Email address.First name and last namePhone number.Address, Country, State, Province, ZIP/Postal code, City.Cookies and Usage Data  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. Privacy Officer – means the individual designated responsibility for ensuring that Union Global Enterprise Ltd o/a Go Local Shops complies with this policy and PIPA.  Policy 1 – Collecting Personal Information 1.1 Unless the purposes for collecting personal information are obvious and the clients, customers, and visitors 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 clients, customers, and visitors information that is necessary to fulfill the following purposes: To verify identity;To open and manage an account;To deliver requested products and servicesTo process a business listing subscription;To enrol the client in a program;To ensure a high standard of service to our [clients, customers, and visitors]; To meet regulatory requirements; To collect and process subscriptions and other fees; To verify identity, we may collect name, home address, and home and mobile telephone number; Policy 2 – Consent2.1 We will obtain clients, customers, and visitors 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 electronically or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the clients, customers, and visitors voluntarily provides personal and business information for that purpose. 2.3 Consent may also be implied where a clients, customers, and visitors 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 clients, customers, and visitors 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), clients, customers, and visitors can withhold or withdraw their consent for Union Global Enterprise Ltd o/a Go Local Shops to use their personal information in certain ways. A client’s, customer’s, 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 clients, customers, and visitors in making the decision. 2.5 We may collect, use or disclose personal information without the client’s, customer’s, 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;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 Information3.1 We will only use or disclose clients, customers, and visitors personal information where necessary to fulfill the purposes identified at the time of collection [or for a purpose reasonably related to those purposes such as:  To conduct clients, customers, and visitors surveys in order to enhance the provision of our services;To contact our [clients, customers, and visitors] directly about products and services that may be of interest;] 3.2 We will not use or disclose clients, customers, and visitors personal information for any additional purpose unless we obtain consent to do so. 3.3 We will not sell clients, customers, and visitors lists or personal information to other parties [unless we have consent to do so].  Policy 4 – Retaining Personal Information 4.1 If we use clients, customers, and visitors personal information to make a decision that directly affects the client, customer, member, we will retain that personal information for at least one year so that the clients, customers, and visitors has a reasonable opportunity to request access to it. 4.2 Subject to policy 4.1, we will retain clients, customers, and visitors 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 clients, customers, and visitors personal information is accurate and complete where it may be used to make a decision about the clients, customers, and visitors or disclosed to another organization. 5.2 Clients, customers, and visitors 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.  [IF APPLICABLE: A request to correct personal information should be forwarded to the Privacy Officer. 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 clients’, customers’, and visitors’ correction request in the file.  Policy 6 – Securing Personal Information 6.1 We are committed to ensuring the security of clients, customers, and visitors 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 clients, customers, and visitors personal information is appropriately protected: Examples may include: the use of locked filing cabinets; physically securing offices where personal information is held; the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access; contractually requiring any service providers to provide comparable security measures]. 6.3 We will use appropriate security measures when destroying client’s, customer’s, member’s personal information such as shredding documents, deleting electronically stored 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 Clients, Customers, and Visitors Access to Personal Information  7.1 Clients, customers, and visitors have a right to access their personal information, subject to limited exceptions.  [OPTIONAL ADDITION: Fill in exceptions to access that might apply. A full listing of the exceptions to access can be found in section 23 of PIPA. Some examples include: solicitor-client privilege, disclosure would reveal personal information about another individual, legal requirement] 7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. [IF APPLICABLE: A request to access personal information should be forwarded to the Privacy Officer [or designated individual] 7.3 Upon request, we will also tell clients, customers, and visitors 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 clients, customers, and visitors of the cost and request further direction from the clients, customers, and visitors 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 clients, customers, and visitors in writing, providing the reasons for refusal and the recourse available to the client, customer, and visitor.  Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual 8.1 The Privacy Officer or designated individual is responsible for ensuring Union Global Enterprise Ltd o/a Go Local Shops’s compliance with this policy and the Personal Information Protection Act. 8.2 Clients, customers, and visitors should direct any complaints, concerns or questions regarding Union Global Enterprise Ltd o/a Go Local Shops’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the clients, customers, and visitors may also write to the Information and Privacy Commissioner of British Columbia. Contact information for Union Global Enterprise Ltd o/a Go Local Shops’ Privacy Officer or designated individual: info@golocalshops.com    |
