Personal Information Protection Policy

At Shuswap Vacation Rentals, we are committed to providing our employees, customers and/or home owners’ privacy with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our employee, customers and home owners’, protecting their personal information is one of our highest priorities.

While we have always respected our employee, customers and home owners’ 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 employees, customers and home owners’ 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 employee, customers and home owner’s privacy and personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of employee, customers and home owners’ privacy personal information and allowing our employee, customers and home owner’s to request access to, and correction of, their personal information.

Scope of this Policy

This Personal Information Protection Policy applies to Shuswap Vacation Rentals

This policy also applies to any service providers collecting, using or disclosing personal information on behalf of Shuswap Vacation Rentals.

Definitions

Personal Information – means information about an identifiable individual 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).

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 Scotch Creek Cottages complies with this policy and PIPA.

Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the employee, customers and/or home owners’ 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 employee, customers and home owner’s information that is necessary to fulfill the following purposes:

To verify identity;
To verify creditworthiness;
To identify [employee, customers and home owners’] preferences;
To open and manage an account;
To deliver requested products and services
To guarantee or provide a vacation home rental
To guarantee or provide other vacation rentals; e.g. boat rentals
To enrol the client in a program;
To send out association membership information;
To contact our [employee, customers and home owners’] for fundraising;
To ensure a high standard of service to our [employee, customers and home owners’];
To meet regulatory requirements;
To assess suitability for tenancy;
To collect and process rent payments;
To determine bonding and or bonding eligibility;

Policy 2 – Consent

2.1 We will obtain employee, customers and/or home owners’ 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 employee, customers and/or home owners’ voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where an employee, customer or home owner 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 employee, customer and/or home owner 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), employee, customers and/or home owners’ can withhold or withdraw their consent for Shuswap Vacation Rentals to use their personal information in certain ways. An employee, customers and/or home owner’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 employee, customers and home owner’s in making the decision.
2.5 We may collect, use or disclose personal information without the employee, customers and home owner’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 Information

3.1 We will only use or disclose employee, customers and home owner’s 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:

Communication with banks or credit card processing companies as required.
To conduct client, customer, member surveys in order to enhance the provision of our services;
To contact our employee, customers and home owner’s directly about products and services that may be of interest;

3.2 We will not use or disclose employee, customers and home owner’s personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell employee, customers and home owner’s lists or personal information to other parties [unless we have consent to do so].

Policy 4 – Retaining Personal Information

4.1 If we use employee, customers and home owner’s personal information to make a decision that directly affects the employee, customers and home owner’s, we will retain that personal information for at least one year so that the employee, customers and home owner’s has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain employee, customers and home owner’s 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 employee, customers and home owner’s personal information is accurate and complete where it may be used to make a decision about the employee, customers and home owner’s or disclosed to another organization.

5.2 Employee, customers and home owner’s 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 employee, customers and home owner’s’ correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of employee, customers and home owner’s 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 employee, customers and home owner’s personal information is appropriately protected:

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].
Securing or monitoring offices where personal information is held

6.3 We will use appropriate security measures when destroying employee, customers and home owners’ personal information such as deleting files and mechanical shredding of paper documents.
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 Employee, Customers and/or Home owners’ Access to Personal Information

7.1 Employees, customers and/or home owners’ have a right to access their personal information, subject to limited exceptions:

disclosure would reveal personal information about another individual,
health and safety concerns

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 employees, customers and/or home owners 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 employees, customers and/or home owners of the cost and request further direction from employees, customers and/or home owners 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 employees, customers and/or home owners in writing, providing the reasons for refusal and the recourse available to the employees, customers and/or home owners.

Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual

8.1 The Privacy Officer is responsible for ensuring Shuswap Vacation Rentals compliance with this policy and the Personal Information Protection Act.
8.2 employees, customers and/or home owners should direct any complaints, concerns or questions regarding Name of organization’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the employees, customers and/or home owners may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for Shuswap Vacation Rentals:

Privacy Officer
Shuswap Vacation Rentals
Toll Free: 1 800 979-3599
Phone: 1 250 955-0080
Fax: 1 250 955-0270
greg@shuswap.ca
www.shuswapvacation.com