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UNION OF B.C. PERFORMERS 
Personal Information Protection Policy

UBCP is committed to protecting your Personal Information.

SCOPE OF THIS POLICY

The UBCP Personal Information Protection Policy (the “Policy”) sets out the principles that the Union of B.C. Performers (“UBCP” or the “Union”) follows regarding the collection, use and disclosure of Personal Information about any identifiable person.  The Policy is subject to all applicable laws, including but not limited to, the Personal Information Protection Act (“PIPA”) and the Personal Information Protection & Electronic Documents Act (“PIPEDA”).

If Personal Information is made anonymous by removing details so that an individual is not identifiable to the user or recipient of that information, it is not governed by the Policy, but will still be treated with appropriate safeguards.

DEFINITIONS

For the purposes of the UBCP Personal Information Protection Policy:

"Performers" and "Members" include current, past and prospective Performers and Members. 

"Personal Information" means any information about an identifiable individual, whether it was collected before or after the Policy was first published, including but not limited to the individual's name, address, age, gender, income, employment history, credit card numbers, GST numbers, and other finance-related information.  "Personal Information" may also include a physical description, photograph, resume and citizenship/immigration status.  With respect to any specific individual, UBCP may or may not have Personal Information within these enumerated categories.

PRINCIPLE 1 - ACCOUNTABILITY

The business of UBCP is governed by the ACTRA Constitution (Alliance of Canadian Cinema, Television & Radio Artists) and the UBCP Bylaws.

UBCP has established and implemented procedures to protect Personal Information and to respond to inquiries and complaints.

UBCP is responsible for all Personal Information under its control.  UBCP’s Privacy Officer is accountable for compliance with the principles described in the Policy, and may be contacted at:

Alison Stewart
Privacy Officer
Union of B.C. Performers
Suite #400 - 1155 West Pender Street
Vancouver, BC V6E 2P4

Telephone:  604.689.0727  Ext. 2251

Email:  privacyofficer@ubcp.com

PRINCIPLE 2 - THE PURPOSES FOR (AND THE MANNER IN WHICH) UBCP MAY COLLECT, USE OR DISCLOSE PERSONAL INFORMATION

Subject to applicable law, UBCP will identify the purposes for which Personal Information is collected, used or disclosed before that information is collected, used or disclosed, as the case may be.

General Purposes

The general purposes for which UBCP may collect, use or disclose Personal Information concerning Performers and Members include the following: (a) to ensure compliance with the ACTRA Constitution and UBCP Bylaws; (b) to ensure correct compensation under the applicable Collective Agreements, including but not limited to residuals, insurance and retirement contributions and RSP deductions; (c) to track permits for Membership qualification; (d) to confirm working hours and conditions; (e) to provide information for casting directors; (f) to provide Members with Union communications; (g) to substantiate or dispute grievances; (h) to substantiate or dispute payroll discrepancies; (i) to investigate fraudulent claims; (j) to conduct the business of the Union; and, (k) to comply with legal and regulatory requirements.

Disclosure to Affiliates, Agencies and Service Providers

UBCP may transfer Personal Information to a third party for processing or to provide services, but uses contractual or other means to provide a comparable level of protection while the Personal Information is in the custody of that third party.

Changed Purposes

From time to time, UBCP may wish to use or disclose Personal Information for a purpose other than that for which it was initially collected.  UBCP will ensure that Personal Information is not used or disclosed for that new purpose unless the individual is informed of the new purpose and gives his or her consent.

PRINCIPLE 3 - CONSENT

Subject to applicable legal exceptions, UBCP will make a reasonable effort to ensure that the individual is advised in advance of the purposes for which his or her Personal Information will be collected, used or disclosed, and to ensure that his or her consent to such collection, use or disclosure is obtained.  As required by applicable law, consent may be express or implied.  (Prior to January 1, 2004, consent to the collection, use or disclosure of Personal Information as defined in the Policy is “implied”.)

UBCP does not require an individual to consent to the collection, use or disclosure of Personal Information beyond that required to fulfill UBCP’s explicitly specified, and legitimate purposes.

From time to time, UBCP may also collect information from external sources such as payroll companies, production companies and financial institutions.

PRINCIPLE 4 - LIMITING COLLECTION

UBCP limits the amount and type of Personal Information collected to that which is necessary for the purposes identified by UBCP.

PRINCIPLE 5 - LIMITING USE, DISCLOSURE AND RETENTION

UBCP does not use or disclose Personal Information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law.  Personal Information is retained only as long as necessary for the fulfillment of those purposes.

Personal Information used by UBCP to make a decision about an individual will be retained for a reasonable amount of time to allow the individual access to the information, if requested, after the decision has been made.

PRINCIPLE 6 - ACCURACY

UBCP aims to keep Personal Information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

UBCP relies upon individual Members to provide up-dated information, such as changes to addresses and other contact information, GST numbers, new agent information, etc.

If an individual revises their Personal Information, UBCP may disclose the revised Personal Information to third parties who were provided with the initial information to permit them to revise their records as well.

PRINCIPLE 7 - SAFEGUARDS

UBCP has implemented appropriate security safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification.  The nature of the safeguards vary depending on the sensitivity of the Personal Information that has been collected, the amount, distribution, and format of the information, and the method of storage.  The more sensitive Personal Information is safeguarded at a higher level of protection.

The methods of protection employed by UBCP include: (a) physical measures, including locked filing cabinets, restricted access to offices, and shredding of materials; (b) organizational measures, such as security clearances and limiting access to a "need to know" basis; and (c) technological measures, such as the use of passwords and encryption.

UBCP employees are required to adhere to these policies and procedures for protecting Personal Information.

PRINCIPLE 8 - OPENNESS

UBCP strives to be open about its policies and procedures with respect to management of Personal Information.  Copies of the UBCP Personal Information Protection Policy are available on our website (www.ubcp.com) or by contacting the Privacy Officer.

PRINCIPLE 9 - INDIVIDUAL ACCESS

Upon an individual's request in writing, with a stated reason for access, UBCP will inform that individual of the existence, use, and disclosure of his or her Personal Information and the individual will be given access to that information, except where the law requires or permits UBCP to deny access.  UBCP will require that an individual provide sufficient information in his or her access request in order to permit UBCP to provide an account of the existence, use, and disclosure of the individual’s Personal Information.

UBCP will respond diligently to a proper request and in any case not later than 30 days after receipt of the request, unless that time is extended according to applicable law.  As permitted by applicable law, certain fees may be charged in respect of requests for access.  Individuals will be informed of any applicable fees before the work is undertaken.

PRINCIPLE 10 - CHALLENGING COMPLIANCE

Any individual may direct a challenge concerning compliance with this Personal Information Protection Policy to the UBCP Privacy Officer, in writing.  UBCP has established procedures to receive and to respond to inquiries or complaints about UBCP’s policies and practices relating to the handling of Personal Information.

UBCP investigates all complaints made in writing to the Privacy Officer.  If UBCP finds that a complaint is justified, UBCP will take appropriate measures, including, if necessary, amending its policies and practices.

REFERENCE

Personal Information Protection Act (British Columbia) – “PIPA”

Office of the Information & Privacy Commissioner for British Columbia

http://www.oipc.bc.ca/private

Government of British Columbia, Private Sector Privacy Legislation

http://www.mser.gov.bc.ca/foi_pop/Privacy/default.htm

Personal Information Protection & Electronic Documents Act (Federal) – “PIPEDA”

Office of the Privacy Commissioner of Canada