The Winnipeg Chamber of Commerce Privacy Policy January 1, 2004
Introduction
We, The Winnipeg Chamber of Commerce, have created this Privacy Policy in order to demonstrate our commitment to the privacy of our members.It explains our practices regarding the collection, use, retention and disclosure of personal information.
For the purposes of this Privacy Policy, the term “personal information” means information about an identifiable individual, but does not include the name, title, business address or telephone number of an employee of an organization.This term do not include information that does not identify specific individuals, such as aggregate statistics or anonymous data.
This Privacy Policy does not apply to publicly available information, nor does it apply to our corporate clients or corporate members.For instance, the company name, contacts, title, business address, telephone number, fax number, email and website addresses of our corporate members are not considered to be personal information, and are therefore not protected by this Privacy Policy.However, such information may be protected by other Winnipeg Chamber of Commerce policies or through contractual arrangements.
We will conduct periodic reviews of this Privacy Policy to make sure that it remains current with evolving client and member expectations, technologies and laws.
Accountability
Our Director of Information Technology has been designated as our Privacy Officer.She is responsible for our organization’s compliance with applicable privacy legislation, including Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”).
When a company or individual joins The Winnipeg Chamber of Commerce, we require and collect the following information:
company name;
main contact for the company and their title;
mailing address;
telephone number;
fax number;
email address;
website address; and
any other contacts within the company that the member chooses to identify.
We require the member to choose their preferred method of communication (i.e., fax, mail or email).We require our business members to provide the number of employees in their organization so that we can identify their dues level.We require our business members to provide us with their industry/business sector for appropriate listing in our Membership Directory and Online Business Directory.
On occasion, we also collect credit card information to process membership dues and event payments, if requested by the member.
The information listed above is collected for the following purposes:
qTo fulfill our agreements with our clients and members;
qTo enable us to communicate on a regular basis with our membership and provide information on our activities in the area of policy and advocacy, event information, new products, new services/programs or special promotions;
qFor internal purposes, such as invoicing for events or other services and for annual membership dues and to respond to member requests;
qFor publication in our annual Membership Directory, which is available only to Chamber members.Information published in the Membership Directory includes:Company Name; Contacts, Titles, Address, City, Province, Postal Code, Telephone, Fax, Email and URL and Business Sector.We will refrain from publishing any or all of the above information at the request of the member;
qFor publication in our Online Business Directory, which is available to the public at large at www.winnipeg-chamber.com.Information published in the Online Business Directory includes:Company Name; Address, City, Province, Postal Code, Telephone, Fax, Email and URL and Business Sector.Contact information for individuals within the business are not published unless the member requests it.We will refrain from publishing any or all of the above information at the request of the member; and
qFor any other purpose to which the member consents.
We do not sell, rent or authorize access to any personal information collected about or from our members to third parties, except in accordance with Schedule 1 (attached).
Consent
We collect, use, retain and disclose personal information about our clients and members only with their consent, except in the limited circumstances outlined in this Privacy Policy or in applicable legislation.The type of consent required will vary according to the sensitivity of the information.
When a business or individual joins The Winnipeg Chamber of Commerce, they voluntarily provide us with information as outlined in Section 2 on the membership application form.
However, The Winnipeg Chamber of Commerce may collect or use personal information without knowledge or consent if it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is seriously ill or mentally incapacitated.
We may collect, use or disclose personal information without knowledge or consent if seeking the consent of the individual might defeat the purpose of collecting, using or disclosing the information, such as in the investigation of a breach of an agreement or a contravention of a law.
We may also collect, use or disclose personal information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened.
We may use or disclose personal information without knowledge or consent to a lawyer representing The Winnipeg Chamber of Commerce, to collect a debt, to comply with a subpoena, warrant or other court order, or as may be otherwise required or authorized by law.
Limiting Collection
Collection of personal information is limited to that which is required to fulfill the purposes outlined in Section 2 above, which we may change from time to time.However, personal information will not be used for such new purposes without the individual’s consent.
Limiting Use, Disclosure and Retention
We will only retain personal information for as long as is reasonably necessary.Generally, the Winnipeg Chamber of Commerce retains personal information aboutmembers until they cancel their membership, at which time the personal information is deleted from our database as well as from the Online Business Directory.However, this retention period may extend beyond the end of a member's relationship with us when it is required by law, or when it is reasonably necessary for us to have personal information to respond to any issues arising out of our relationship that may need to be addressed at a later date.
We may provide personal information to other persons only:
§when we have an individual's consent, whether express or implied;
§to the suppliers or agents who assist us, and whom we can reasonably trust to respect privacy; or
§when we are required or permitted by law to do so, or when we need to disclose the information to protect our interests in the context of a legal or administrative proceeding.
Accuracy
We make reasonable efforts to keep personal information accurate, complete and up-to-date.If you find any errors in the personal information we have about you, let us know and we will make the appropriate corrections and make sure they are conveyed to anyone we may have misinformed.For personal information that remains in dispute, we will make a note of your opinion in our records.
On an annual basis, prior to publishing the Membership Directory, our members are requested to check their data for accuracy as well as deletions or additions of contact information.This is done via email.
At any time, members can inform our office, in writing, of changes to their membership information.It is the responsibility of the Information Coordinator to ensure that these changes are made in our database, which subsequently is used to update our Online Business Directory.The Online Business Directory is updated on a weekly basis.
7.Safeguards
We protect personal information with appropriate safeguards and security measures to protect against unauthorized access and use.As well, all our suppliers and agents, as part of their contracts with The Winnipeg Chamber of Commerce, are bound to maintain confidentiality and may not use personal information for any unauthorized purpose.Also, when we provide personal information in response to a legal enquiry or order, we ensure that the order is valid and we disclose only the information that is legally required.
All staff have access to general information about our membership through our database software program, Membership Manager Enterprise Edition 4.5.This general information includes that which is provided on the membership application, the member’s participation on committees and event attendance.
Access to a member’s financial information, which includes their payment history, is restricted to the following persons:Director of Finance and Operations; Accounting and Administration Coordinator, Information Coordinator, Director of Information Technology and Program Coordinator.
Access to credit card information provided by the member is restricted to the Director of Finance and Operations and the Accounting and Administration Coordinator.Online protection of this information is outlined in Schedule 2 (attached).Paper copies of this information are kept in a locked filing cabinet.
All employees are aware of our security and privacy practices.
Computer servers that store personal information are kept in a secure environment.
Openness
Our Privacy Policy is available on our website.A printed copy can be obtained by contacting The Winnipeg Chamber of Commerce office – (204) 944-8484 or info@winnipeg-chamber.com.
Questions regarding our Privacy Policy can be directed to our Privacy Officer:
All membership information is stored in our database software program, Membership Manager Enterprise Edition 4.5. Membership applications are stored in locked filing cabinets.
Membership information is available in our online Business Directory as well as in our Membership Directory, which is published annually and made available to all Chamber members.
Please contact our offices if you wish to have access to any personal information we may have about you.We will advise you in advance if a minimal charge is required for us to conduct a search of our records for personal information about you, and will respond to your request within 30 days.
Please note that we may not be able to provide personal information about you from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to The Winnipeg Chamber of Commerce or cannot be disclosed for other legal reasons.
For More Information
If you have any concerns or questions about privacy and confidentiality - or any concerns about the way a request for personal information was handled – please direct your complaints or inquiries to our Privacy Officer:
The Winnipeg Chamber of Commerce Privacy Officer has the decision-making authority to resolve most privacy-related concerns.However, if you are not satisfied with the way in which a complaint was resolved or if you have further questions about the protection of personal information in Canada, we recommend that you contact the federal Privacy Commissioner:
