Spryberry Creative Strategy Inc.
Personal Information Protection Policy

 At Spryberry Creative Strategy Inc., we are committed to providing our users/clients with exceptional service.  As providing this service involves the collection, use and disclosure of some personal information about our users/clients protecting their personal information is one of our highest priorities.

While we have always respected our users/clients 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 users/clients 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 users’/clients’ personal information.  Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our users’/clients’ personal information and allowing our users/clients to request access to, and correction of, their personal information.

Definitions

 Personal Information –means information about an identifiable individual (E.g., including name, age, home address and phone number, 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 Spryberry Creative Strategy Inc. complies with this policy and PIPA.

Policy 1 – Collecting Personal Information

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

·       To verify identity

·       To identify client preferences

·       To deliver requested products and services

·       To enrol the client in a program

·       To ensure a high standard of service to our clients

·       To meet regulatory requirements

Policy 2 – Consent

2.1  We will obtain user/client 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/client voluntarily provides personal information for that purpose.

2.3  Consent may also be implied where a user/client is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs and the marketing of new services or products and the user/client 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/clients can withhold or withdraw their consent for Spryberry Creative Strategy Inc. to use their personal information in certain ways.  A user’s/client’s 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/client in making the decision.

2.5  We may collect, use or disclose personal information without the user’s/client’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 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 user/client personal information where necessary to fulfill the purposes identified at the time of collection:

·       To conduct user/client surveys in order to enhance the provision of our services

·       To contact our users/clients directly about information, products and services that may be of interest

·       To properly administer user/client web hosting accounts

·       To provide user/client login access to comment areas and learning areas on our website

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

3.3  We will not sell user/client lists or personal information to other parties.

Policy 4 – Retaining Personal Information

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

4.2  Subject to policy 4.1, we will retain user/client 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 user/client personal information is accurate and complete where it may be used to make a decision about the user/client or disclosed to another organization.

5.2  Users/Clients 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’/clients’ correction request in the file.

Policy 6 – Securing Personal Information

6.1  We are committed to ensuring the security of user/client 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/client personal information is appropriately protected:

·       Personal information is stored on secure servers, password protected, with restricted access for only personnel managing the data.

·       Personal information is not stored in hard copy form.

·       Credit card information is maintained through our payment gateway providers. Copies of credit card information are managed or retained on our servers.

6.3  We will use appropriate security measures when destroying users’/clients’ personal information such as shredding documents and 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 Users/Clients Access to Personal Information

7.1 Users/Clients 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/clients 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/client of the cost and request further direction from the user/client 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/client in writing, providing the reasons for refusal and the recourse available to the user/client.

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

8.1  The Privacy Officer is responsible for ensuring Spryberry Creative Strategy Inc. compliance with this policy and the Personal Information Protection Act.

8.2  Users/Clients should direct any complaints, concerns or questions regarding Spryberry Creative Strategy Inc. compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the user/client may also write to the Information and Privacy Commissioner of British Columbia.