Guidelines and Procedures
Personal Information and Privacy Protection
1.1 The Student Price Card and its subsidiaries abide to the
principles of personal information protection in accordance with Bill C-6 Personal
Information Protection and Electronic Documents Act.: Accountability, Identifying
Purposes, Consent, Limiting Collection, Limiting Use, Disclosure and Retention,
Accuracy, Safeguards, Openness, Individual Access, Challenging Compliance Guidelines.
1.1 The Director of Operations of the Student Price Card is
responsible for the Student Price Card and its subsidiaries’ compliance with the
principles of Bill C-6.
1.2 The Student Price Card is responsible for personal information
in its possession or custody, including information that has been transferred to
a third party for processing.
1.3 The procedures as set forth represent the Student Price
Card and its subsidiaries’ implementation to give effect to the principles of Bill
C-6, Personal Information Protection and Electronic Documents Act.
1.4 All staff of the Student Price Card and its subsidiaries
will be trained on the practices for the handling of personal information pursuant
to the procedures outlined below.
1.1 The purposes for which personal information is collected
shall be identified by the Student Price Card at or before the time the information
is collected, verbally or in written. The Student Price Card shall document the
purposes in order to comply with the Openness and Individual Access principles of
1.2 When personal information that has been collected is to
be used for a purpose not previously identified, the new purpose shall be identified
by the Student Price Card prior to use.
1.3 Recognizing that consent is required for the collection
of personal information and the subsequent use or disclosure of said information,
the Student Price Card shall seek consent for the use or disclosure of information
of a personal nature at the time of collection. In certain circumstances,
consent with respect to use or disclosure may be sought after the information has
been collected (for example, e-mail broadcast messages after the fact).
1.4 The Student Price Card will make a reasonable effort to
ensure that individuals are advised of the purposes for which information will be
used taking into account reasonable expectations of the individual and by providing
opportunities for the granting of consent in its written documentation, on its web-sites
and in its market research endeavours.
1.5 The Student Price Card will not gather information on their
clients for the purpose of marketing to a third party without clients being given
the opportunity to be removed from such lists for this purpose.
1.6 For circumstances involving consent after the fact, individuals
will be given the opportunity to be removed from further announcements, third party
communication and other circumstances as modified and legislated from time-to-time.
1.7 The collection of personal information shall be limited
to that which is necessary for the purposes identified by the Student Price Card.
Information shall be collected by fair and lawful means.
1.8 Personal information obtained by the Student Price Card
in the course of its business activity shall not be used or disclosed for purposes
other than those for which it was collected, except with the consent of the individual
as required by law. Personal information shall be retained only as long as
necessary for the fulfillment of the express purpose.
1.9 Personal information retained by the Student Price Card
shall be as accurate, complete and up-to-date as is necessary for the purposes of
which it is to be used.
1.10 Personal information in the Student Price Card’s possession
shall be protected by security safeguards determined appropriate to the sensitivity
of the information.
1.11 An individual can address a challenge concerning compliance
with the above principles to the Director of Operations of the Student Price Card.
1.12 All complaints or inquiries further to the Student Price
Card’s procedures and practices relating to the handling of personal information
will receive a response from Director of Operations in verbal or written form, within
five (5) business days upon receipt of a complaint or inquiry.
1.13 In the case of a complaint, if it is found to be justified
and non-compliant to the principles legislated in Bill C-6, the Student Price Card
will take appropriate measures including possibly amending its policies and practices.