Last amended January 23, 2013
The Canadian Association of University Business Officers (“CAUBO,” “we,” “us”) respects the privacy of its members, directors, clients, partners, employees, contractors, job applicants, CAUBO website and application users, other stakeholders, and others it collects personal information about, and makes every effort to protect personal information in its possession or control.
CAUBO is required to comply with federal privacy legislation entitled the Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable privacy laws. This policy (the “Policy”) outlines how we manage your personal information and safeguard your privacy.
This Policy does not apply to the practices of companies or other entities that CAUBO does not manage or control. This Policy does not apply to information regarding corporations or other non-individuals.
CAUBO publishes decisions and other documents that are provided to it by its members in the form provided, including any personal information. These decisions and documents are public. CAUBO does not edit the content of documents for personal information except in compliance with any judicial or quasi-judicial orders or in accordance with the requirements of the member that provided the decision or document.
1. POLICY STATEMENT
CAUBO is committed to protecting and safeguarding the personal information that it collects during the course of its various activities and projects. Maintaining the trust of members, directors, clients, partners, employees, contractors, job applicants, CAUBO website and application users, other stakeholders, and others it collects personal information about is a permanent and ongoing endeavour.
With the growth of electronic media, it is also necessary to take steps to protect the privacy of the individual.
CAUBO uses reasonable efforts to ensure that personal information entrusted to CAUBO is secure and will not be used for purposes other than what is required to deliver its services or as described in this Policy. Privacy practices enable CAUBO to be transparent and accountable in how it treats personal information that is shared with us.
CAUBO is also committed to continue to review its Policy to ensure relevance and currency with changing industry standards, technologies and laws. CAUBO therefore may change this Policy from time to time and such changes will be effective from the date of revision.
2. PRIVACY PRINCIPLES
Principle 1: Accountability
Each employee or contractor of CAUBO is responsible for personal information under his or her control and for compliance with this Policy. CAUBO has appointed a Privacy Coordinator to ensure compliance to this Policy and applicable laws.
Principle 2: Identifying Purposes
The purposes for which personal information is collected, used and disclosed by CAUBO are as identified in this Policy, or as may be identified at or before (or in some cases, after) the time the personal information is collected.
Principle 3: Consent
By providing personal information to us, by joining or becoming a member of CAUBO, or by using or providing CAUBO services, you voluntarily consent to the collection, use and disclosure of personal information as specified in this Policy. Without limiting the foregoing, we may on occasion ask you to consent when we collect, use, or disclose your personal information in specific circumstances, in which case we may ask for your consent in writing although in some circumstances we may accept your oral consent. Sometimes your consent will be implied through your conduct with us if the purpose of the collection, use or disclosure is obvious and you voluntarily provide the information. In addition, we may collect, use and disclose personal information without your consent when we are required or permitted by law to do so.
Principle 4: Limited Collection
The collection of personal information shall be limited to that which is necessary for the purposes identified or as required or permitted by law. Personal information shall be collected by fair and lawful means.
Principle 5: Limiting Use, Disclosure and Retention
Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the permission of the individual or as required or permitted by law and will be retained only as long as necessary for the fulfilment of those purposes.
Principle 6: Accuracy
CAUBO will use reasonable efforts to keep personal information as accurate, complete and up-to-date as necessary for the purposes for which it is to be used. However, CAUBO relies on the individuals to disclose all material personal information and to advise of any changes. Individuals may, with proof of entitlement, request to access and if applicable, request a correction of personal information in the Association’s possession.
Principle 7: Safeguards
CAUBO will use reasonable efforts to protect personal information against unauthorized access, modification or disclosure with security safeguards appropriate to the sensitivity of the personal information.
Principle 8: Openness
CAUBO will make readily available to individuals specific information about its policies and procedures relating to the management of personal information.
Principle 9: Individual Access
Upon written request, an individual shall be informed of the existence, use and disclosure of his or her personal information, and shall be given access to that information, except where not required or prohibited by law. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Your rights to access your personal information are not absolute. We may deny access when denial of access is required or permitted by law, when granting you access would have an unreasonable impact on other people’s privacy, to protect CAUBO’s rights and property, or where the request is frivolous or vexatious. If we deny your request for access to, or refuse a request to correct personal information, we will explain why.
Principle 10: Challenging Compliance
Individuals may address any concern or complaint regarding the compliance with this Policy to the Privacy Coordinator.
“Personal information” consists of information about an identifiable individual and which is defined as such pursuant to any applicable privacy laws, and includes information such as a person’s personal e-mail address, credit card numbers, home address, etc. It does not include contact information as defined pursuant to applicable privacy laws to enable an individual at a place of business to be contacted, such as the name, title, and business address or business telephone number of an employee of an organization or any other information that is so defined by applicable privacy laws.
This Policy applies both to the personal information currently in CAUBO’s possession or which will be in CAUBO’s possession for all CAUBO members, directors, clients, partners, employees, contractors, job applicants, CAUBO website and application users, other stakeholders, and others it collects personal information about.
All CAUBO employees and contractors are required to protect the confidentiality of personal information as part of their employment or relationship with CAUBO.
CAUBO’s Privacy Coordinator is accountable to CAUBO’s Executive Director for CAUBO’s compliance with all applicable privacy laws and with this Policy, and will help enhance CAUBO’s reputation vis-à-vis privacy practices. CAUBO management has the responsibility to be familiar with this Policy and the protection offered under applicable privacy laws.
Each employee or contractor of CAUBO is also responsible for the protection of personal information under his or her control and for compliance with this Policy.
c) Collection, Use and Disclosure of Personal Information:
This Policy covers our treatment of personal information that we collect, either through communications or interaction we may have with you (such as e-mails, telephone conversations, face-to-face or written correspondence) or through our website. This Policy also covers our treatment of any information shared with us by third parties.
Sometimes we may collect personal information about you from other sources, provided that such sources confirm to us that they are permitted to share such information, such information is publicly available, or the collection is required or permitted by law. Examples of collection from other sources include collections from publicly available contact information or publications, references, a government agency or registry, or credit bureaus.
CAUBO collects, uses, and discloses personal information for the following purposes:
- in accordance with the consent provided by the individual to whom the information relates;
- to administer and build your account with CAUBO, if you have one;
- to provide CAUBO products and services that are requested by you or that are part of your membership with CAUBO;
- to administer and manage CAUBO’s activities and operations, including personnel and employment matters, benefits, and programs;
- to administer and manage our commercial relations;
- to market new services that we believe will be of interest to you;
- in connection with an actual or prospective corporate re-organization, merger or amalgamation with another entity, provided that the personal information disclosed continues to be used by the entity acquiring the information either for evaluation of the possible transaction, or, on completion of any such transaction, for the purposes permitted by this Policy;
- or as required or permitted by law.
Under certain circumstances, CAUBO will disclose your personal information:
- when you have consented to the disclosure;
- to fulfill the purpose for which the personal information was collected;
- when the products or services we are providing to you require us to give information to third parties;
- where it is necessary to establish or collect fees;
- if the information is already publicly known; or
- when we are required or permitted by law to do so.
Personal information shall not be used by the employees or contractors of CAUBO for purposes other than as required in the performance of their duties.
CAUBO sometimes retains external parties to perform on its behalf, certain functions in support of the services or operations of CAUBO. Such functions could include, but are not limited to, payroll/benefit services, credit card payment processing, auditing services, computer, application or systems services, or archival file storage. Accordingly, these external parties will be provided with personal information to the extent that it is required in the performance of those specific functions.
To the extent commercially practicable, CAUBO uses reasonable efforts to obligate these external parties by instruction or agreement to use and take steps to protect personal information.
CAUBO does not sell member lists or other personal information. However, we do share certain member information as follows:
We may from time to time provide a list of CAUBO’s institutional and affiliate (university, college and community college) members along with their contact information to our corporate members, in order for them to offer goods and services which may be of interest.
We provide a list of conference participants to our conference sponsors, not including those participants who opt out during the conference registration process.
Any questions, concerns, complaints or requests regarding this Policy may be forwarded to:
CAUBO National Office
315-350 Albert Street
Ottawa, ON K1R 1B1
e) Withdrawal of Consent
Individuals have the right to withdraw their consent to the collection, use, or disclosure of personal information at any time, except where that withdrawal would frustrate the performance of a legal obligation by CAUBO. Upon reasonable written notice given to CAUBO, all personal information held by CAUBO that is identifiable to that individual will be removed from our records and a notice of the impact of that removal will be provided to the individual. Notwithstanding the foregoing, if you withdraw consent CAUBO nonetheless reserves the right to retain, collect, use and disclose personal information without your consent where we are required or permitted by law to do so.
You may wish to opt out of receiving certain information and marketing or promotional materials from CAUBO. You may do so by contacting us at the addresses at the end of this Policy. Notwithstanding the foregoing, if you opt-out CAUBO nonetheless reserves the right to retain, collect, use and disclose personal information without your consent where we are required or permitted by law to do so.
5. CAUBO WEBSITE AND APPLICATIONS
Our website and applications to access our website may monitor traffic patterns, usage and related information. We may automatically (i.e., not via registration) collect or compile certain information that is not personally identifiable when you access the website or use our applications. Examples of this type of information include the aggregate and unique number of visitors to the website, the dates and times of visits to the website, the domains/countries of visitors, the pages of the website visited and the content accessed, the browsers, operating systems, search engines and search terms used to visit the website and HTTP errors generated, data about the device used to access the website, and (unless you opt-out) geo-location data. We use this information in order to optimize our website and applications and to service and assess usage of them. We may provide such information to our contractors for these purposes, but this information does not include any personally identifiable information. If you cease or revoke consent to the information usages as described in this paragraph, Your sole remedy is to terminate your use of our website and applications.
6. PAYMENT DATA COLLECTED