Privacy Policy

West Point Grey Academy (“WPGA”) Privacy Policy
 
WPGA is committed to safeguarding personal information of students, parents, employees, and volunteers in accordance with the privacy standards established by British Columbia’s Personal Information Protection Act (PIPA) and any other applicable legislation.  The Privacy Policy describes the practices of WPGA regarding the collection, use and disclosure of personal information about students, parents, employees and volunteers, including the steps the Academy has taken to ensure personal and financial information is handled appropriately and securely. WPGA may modify this Policy, or adjust the procedures and practices, when it is appropriate or required to do so.  
 
Purpose
WPGA operates in accordance with the privacy standards established by British Columbia’s Personal Information Protection Act (PIPA) and any other applicable legislation.
 
WPGA is committed to protecting personal information from unauthorized access, collection, use, disclosure or disposal as outlined in the Act.  Individuals have a right to access any record containing personal information about themselves except in cases where the information is exempted from disclosure under the specified sections of the Act.
 
Personal information is information about an identifiable individual, but it excludes the name, position, name and title, business contact information of an individual, or their work product information. Employee personal information is separately defined as personal information about an employee that is collected, used or disclosed solely for the purposes reasonably required to establish, manage or terminate the employment relationship.
 
Definitions
This policy applies to personal information meaning any information about an identifiable individual, as further defined under British Columbia’s Personal Information Protection Act or other applicable laws.   Personal information excludes work information and the name, position name or title, business telephone number, business address, business email, and business fax number of an individual, as well as any publicly available information as designated under applicable laws, such as information available from a public telephone directory or from a public registry.
 
“Parent” means the parent, guardian or other legal representative of a student. “Student” means a prospective, current or past student of WPGA.
“Alumni” means a student who has graduated from WPGA.
Employeemeans any person or contractor who is compensated by WPGA for work or services.
 
“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.
 
“Work product” 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.
 
“Consent” means voluntary agreement to the collection, use or disclosure of personal information for reasonable purposes, which have been made known to the individual.   Consent can be expressed or implied.  Implied consent is consent that can be reasonably inferred from the action or inaction of an individual.
 
Collection, Use and Disclosure of Information 
WPGA collects, uses and discloses personal information for the following purposes:
  • To communicate with and on behalf of students, parents, employees or former employees, and alumni, process applications and ultimately to provide students with educational services and co-curricular programs;
  • To communicate with parents (past and present), students (past and present), alumni, employees, and friends of WPGA for the purposes of advising of activities, events in the promotion of the school fundraising and advancement initiatives;
  • To communicate with external parties in the course of the school’s activities including publications such as yearbooks and newsletters, and websites;
  • To provide students with the educational services enunciated by the Mission statement of the school, including the student’s school activities, performance or behaviour such as attendance records or grades.  This may include electronic information on academic, health, and personal matters needed by the school to provide the best possible education and co-curricular programs;
  • To provide specialized services areas such as health, psychological or legal information or as adjunct information in delivering educational services
  • To enable the School to operate its administrative function, including payment of school fees and maintenance of non-educational school programs, including parent and volunteer participation and fundraising;
  • To monitor the use of the School’s network systems and the public and alumni use of the School’s website;
  • To administer and/or process compensation, benefits, and pension.  This may include disclosure of information to CRA, WorkSafe BC, Employment Insurance, and to consultants who assist with processing of payroll;
  • To comply with WPGA policies;
  • To meet legal and regulatory requirements, including the Independent School Act;
  • To administer insurance for School assets;
  • To ensure communication in the event of emergency;
  • To investigate breaches of law, complaints and breaches of policy or the Code of Conduct;
  • To provide a safe environment for Faculty, Staff and students; and
  • To protect WPGA School assets.  
Authority
WPGA is responsible for maintaining and protecting the personal information under its control. In fulfilling this mandate, WPGA has designated the Director of Finance and Operations as the Privacy Officers for the School
 
Contact information
Attention: Aga Jendo, Privacy Officer
4125 West 8th Avenue, Vancouver, BC
Phone: 604-222-8750, x. 1510
Fax: 604-222-8756
Email: PrivacyOfficer@wpga.ca
 
Personal Information Protection and Security
  • WPGA will maintain and protect the personal information under its control and will protect personal information by security safeguards that are appropriate to the sensitivity of the level of the information.  This includes locking file cabinets, training and reminding employees about the protection of personal information, appropriate computer passwords and screen savers to prevent unauthorized access and other reasonable safeguards.
  • All electronic information will be stored in confidential and secure databases and restricted only to authorized staff.
  • WPGA will, before or at the time personal information is collected, identify the purposes for which the information is collected, used and disclosed.  The personal information collected will be limited to that information necessary for the purposes identified.
  • WPGA will only use, disclose and retain personal information for the purpose for which it was collected unless the individual has otherwise consented, or when the information’s disclosure, use, or retention is required or permitted by law.
  • WPGA will take appropriate steps to ensure that personal information collected, disclosed, used or retained by WPGA is as accurate and complete as is reasonably required in connection with the purposes for which it was collected, used or disclosed.
  • WPGA will publicize in the employee handbook the policies and practices that apply to the management of personal information.
  • WPGA will inform an individual, upon the individual’s request in writing, of the existence, use and disclosure of the individual’s personal information, and shall give the individual access to it in accordance with the law.
  • Upon request, WPGA will provide individuals with copies of their personal information, information on how their personal information is being used, and/or names of individuals and organizations to whom their personal information has been disclosed, in accordance with the law.
  • WPGA will exercise its right to deny access to some information contained in student or employment files where the disclosure of information may threaten someone else's safety, mental or physical health, or where disclosure could be harmful to personal privacy of a third party (pursuant to the Personal Information Protection Act).
  • Individuals may question WPGA’s compliance with the Personal Information Protection Act and this Privacy Policy by contacting the WPGA’s Privacy Officer
1. Protection of Personal Information
Employees must take all reasonable and appropriate steps to prevent accidental disclosure of student, parent, employee or volunteer personal information.
 
Any disclosure of personal information, whether deliberate or accidental, may result in disciplinary action, up to and including termination.
 
Employees are bound by confidentiality obligations that survive the termination of their employment.
 
2. Procedure 

2a. Parents and Students Information - Collection, Use and Disclosure
Personal information may be collected, used, and disclosed in the course of the operation of building security systems, including video and other surveillance systems which WPGA may utilize from time to time.
 
Personal information about students, parents, employees and alumni (including photographs and biographical information) may be collected, used and disclosed in the course of WPGA’s activities including publications such as yearbooks and newsletters, electronic bulletins, and websites. The collection of student information and its storage, use, disclosure and protection is addressed in “Student Records Requirements and Best Practices Policy.”

2b. Employees
Personal information collected, used and disclosed in the hiring process, including information on resumes and application forms (contact information, personal and professional history, qualifications, emergency contact information) results of criminal records checks, information collected from references. Information will be collected, used, retained and disclosed as is necessary for normal business operations and as is required by law, and notice given to employees. Information will include payroll and related information necessary to process payroll and to administer benefits; social insurance number, rate of pay, hours of work, deductions, bank information and any court orders, medical information, marital status etc.

3. Consent
WPGA will obtain consent of the individual for the collection, use or disclosure of personal information except where the law states exemptions, grants permission, or creates a requirement for collection, use, retention or disclosure of personal information.

3a. Requirements for consent to collection, use or disclosure of personal information vary depending on circumstances and on the type of personal information that is intended to be collected, used or disclosed.   In determining whether consent is required and, if so, what form of consent is appropriate, WPGA will take into account both the sensitivity of the personal information and the purposes for which the information will be used. Consent may be expressed, implied (including through use of “opt-out” consent where appropriate), or deemed.
  • For students and families, consent will be obtained as part of enrollment.
  • For alumni, consent will be obtained every 24 months.
3b. On giving reasonable written notice to WPGA, an individual may withdraw consent to the collection, use or disclosure of his or her personal information.  Upon notice of withdrawal of consent, WPGA will notify the individual of the likely consequences of withdrawing his or her consent and, except where otherwise required or permitted by law, WPGA will stop collecting, using or disclosing the personal information as requested.

3c. If a person provides WPGA or its service providers or agents with personal information about an individual, the person represents that it has all necessary authority and/or has obtained all necessary consents from such individual to enable WPGA to collect, use and disclose such personal information for the purposes set forth in this Privacy Policy.

4.
Use, Disclosure and Retention
4a. WPGA does not sell, lease or trade information to other parties.
  • If for any reason personal information is required to fulfill another purpose, the school will notify you of the new purpose before proceeding with the collection, use or disclosure.
Disclosure:

i. WPGA may disclose an individual’s personal information to others in connection with the purpose for which it was collected, as consented to by the individual, or as required or permitted by law. WPGA may disclose personal information as follows:

ii. When Authorized by Individual 
  • Other educational institutions routinely contact the school for personal information about students.   For example, if a student moves to another school, college or university, student records are requested by the enrolling institution.  Consent to pass on these records is usually obtained when the student is registered and parents authorize WPGA to disclose such information to other appropriate educational institutions for the ongoing education of the student, and is also governed by legislation.
  • Contact information may be used to enable the school to provide the educational and administrative services usually operated by the school. These services include phoning committees, parent directory, participation groups, parent meetings, fundraising events.
iii. When Required by Law
  • WPGA may be legally required to disclose personal information relating to family court issues, legal proceedings, court orders and government tax reporting requirements.
  • Only personal information specifically required will be disclosed.  WPGA takes precautions to satisfy itself that the authorities making the request have legitimate grounds to do so by, if necessary, consulting with legal counsel.
  • Student and teaching faculty information is filed annually with the Ministry of Education as required by statute. The Head of School will authorize any such request.
 
iv. When Permitted by Law
 
WPGA is legally permitted to disclose some personal information in situations such as an investigation of illegal activities, reasonable methods to collect overdue accounts, a medical emergency or suspicion of illegal activities. Only necessary personal information is disclosed.

v. Outside Service Providers/Contractors
 
WPGA contracts outside organizations to perform specialized services such as payroll services or printing. For example, the school gives its yearbook publisher the information required to produce the annual yearbook. Service providers or contractors are given only information necessary to perform those services. WPGA takes appropriate steps to ensure that such information is securely transferred, stored and used only to fulfill the purposes for which it was disclosed to the service provider.
 
vi. Restricting Sharing Information – Students, Families, Employees, Alumni
 
If a parent chooses to limit the sharing of personal information, the individual must submit to the Privacy Officer a written request specifying which items of personal information are to be limited and to whom these items are to be restricted.  The Privacy Officer will advise the individual whether the requested information can be restricted in the manner requested.
 
Employees may restrict the sharing of their personal information by contacting the Human Resources office.
 
Certain agencies, by law, have access to certain types of personal information.

4d. Retention
 
Personal information will only be retained for the period of time required to fulfill the purpose for which it was collected.  Once the personal information is no longer required to be retained to fulfill the purposes for which it was collected and is no longer required or permitted to be retained for administrative, legal, business or historical purposes, it will be destroyed or made anonymous in a secure manner (e.g. shredding).
 
5. Accuracy
 
WPGA will, to the best of its ability, endeavor to ensure that all personal information is accurate.   However, it is the individual’s responsibility to ensure that the information maintained by WPGA is accurate and up to date.

5a. Updating  Information - Parents
 
Parents/guardians should update the personal information for themselves and their children or wards through their WolfNet account. Alternatively, an individual may, upon written request to WPGA, request that WPGA correct an error or omission in any personal information that is under WPGA’s control.  WPGA will, as appropriate, amend the personal information as requested.

5b. Updating Information - Employees
 
Employees should update their personal information through the Human Resources office. Examples of when personal information should be updated include changes in residence, marital status or banking information.

6.   Safeguarding Personal Information

6a. Employees
In the course of daily operations, access to personal information is restricted to authorized employees who have a legitimate reason for accessing it. For example, teachers will have access to personal information about students but not financial information.
 
Employees are appropriately educated about the importance of privacy and they are required to follow the school’s policies and procedures regarding handling of personal information.

6b. Employee Personal Information
Personal information about employees (social insurance numbers, medical information) is confidential and restricted to authorized employees who have a legitimate reason for accessing it (Payroll/Human Resources).

6c. Student Files 
Student files are stored in secured media (filing cabinets, secure and confidential databases). Access is restricted to only those employees (teachers, counselors, secretaries, etc.) who, by nature of their work, are required to see them.   

6d. Electronic Security
The school manages electronic files with passwords and other security measures (i.e. encryption) that limit access by unauthorized personnel. The school’s security practices are reviewed periodically to ensure that the personal information is not compromised.

6e. Openness
Any questions or enquiries with respect to the School’s privacy policies or practices should be directed, in writing, to the Privacy Officer of WPGA School (PrivacyOfficer@wpga.ca).

7. 
Access to Personal Information
Individuals may access and verify any of their personal information with appropriate notice so that WPGA is able to supply the information required.
    
7a. Parent/Student Access to Student Personal Information
Most of the student information is available in the registration forms and other forms that parents complete when enrolling a student. A parent may make an appointment during regular School hours to access and verify student records held by the School. Parents or guardians may verify their personal information at any time through their WolfNet account.

7b. Employees
Employees may access their personal information through the Human Resources office.

7c. Exceptions to Access to Record: Employees, Students, Parents
In limited circumstances, WPGA may exercise its right to deny access to some information contained in student or employment files.  In considering disclosure exception, WPGA will take into consideration legal requirements and obligations, and relevant circumstances.
 
Examples of denying access to information could include:
  • Evaluations supplied in confidence by a teacher about student with the mutual understanding that the evaluation will be confidential.
  • Disclosure of counselor’s notes of interviews with student to their parent on the basis of a threat to safety or mental or physical health.
8. Complaint Process
Questions, concerns, and complaints about privacy, confidentiality and personal information handling policies and practices of WPGA should be directed to the WPGA’s Privacy Officer. If necessary, individuals will be referred to use the WPGA’s complaint procedure and appeals policies.
 
Contact Information:
Attention: Aga Jendo, Privacy Officer
4125 West 8th Avenue, Vancouver, BC
Phone: 604-222-8750, x. 1510
Fax: 604-222-8756
Email: PrivacyOfficer@wpga.ca