Personal Information Protection Policy

1.1 Unless the purposes for collecting personal information are obvious and the user and member 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 user and member information that is necessary to fulfill the following purposes:

• To verify identity;
• To deliver requested products and services;
• To enrol the individual in a program;
• To send out association membership information;
• To contact for fundraising;
• To ensure a high standard of service;
• To meet regulatory requirements;
• To collect and process payments.

2.1 We will obtain user and member 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 orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the user and member voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a user and member 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, fundraising and the user and member 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), users and members can withhold or withdraw their consent for RCD to use their personal information in certain ways. A user’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 user and member in making the decision.

2.5 We may collect, use or disclose personal information without the user’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.

3.1 We will only use or disclose user and member personal information where necessary to fulfill the purposes identified at the time of collection:

• To conduct user and member surveys in order to enhance the provision of our services;
• To contact our users and members directly about products and services that may be of interest;

3.2 We will not use or disclose user and member personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell user and member lists or personal information to other parties.

4.1 If we use user and member personal information to make a decision that directly affects the user and member, we will retain that personal information for at least one year so that the user and member has a reasonable opportunity to request access to it.

4.2 Subject to policy 4.1, we will retain user and member personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

5.1 We will make reasonable efforts to ensure that user and member personal information is accurate and complete where it may be used to make a decision about the user and member or disclosed to another organization.

5.2 Users and members 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.

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 users’ and members’ correction request in the file.

6.1 We are committed to ensuring the security of user and member 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 user and member personal information is appropriately protected: the use of locked filing cabinets; the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate.

6.3 We will use appropriate security measures when destroying user’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.

7.1 Users and members have a right to access their personal information, subject to limited exceptions.

7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.

7.3 Upon request, we will also tell users and members 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 user and member of the cost and request further direction from the user and member 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 user and member in writing, providing the reasons for refusal and the recourse available to the user and member.

8.1 The RCD Executive Director is responsible for ensuring RCD’s compliance with this policy and the Personal Information Protection Act.

8.2 Users and members should direct any complaints, concerns or questions regarding RCD’s compliance in writing to RCD Executive Director.