The New Democratic Party of British Columbia (the “BC NDP”) values the support and trust of our supporters and recognizes that maintaining this requires that we be open and accountable for how we treat personal information.
In our continuing quest to build a better British Columbia, raise funds and build a strong base of support, we gather and use personal information. We comply with – and try to exceed - the requirements of applicable law.
This policy has been developed in compliance with British Columbia’s Personal Information Protection Act(“PIPA”). BC’s Personal Information Protection Actsets out rules for how organizations such as ours can collect, use and disclose your personal information.
TABLE OF CONTENTS
- Organizations to which this policy applies
- Why we collect and use personal information
- Limits on collection, use and disclosure
- How we disclose personal information
- How we obtain consent to collect, use, and disclose personal information
- How long we retain personal information
- How we keep personal information secure
- How we ensure that personal information is accurate
- How we provide individuals with access to their personal information under our control
- How you can complain, ask for access or ask questions
Constitution means the BC NDP’s constitutional documents, which include the BC NDP Constitution and the Constitution of the New Democratic Party of Canada (“Canada’s NDP”).
Member means an individual who has obtained membership in accordance with the Constitution.
Individual means a person who has provided personal information to the BC NDP and may or may not include Members. Individual includes supporters, donors and volunteers.
Personal information means information about an identifiable individual, such as someone’s name, age, home address, personal email and phone number, gender, family or marital status, religion, race, political affiliation, social insurance number, income, education, employment and donation history including credit card information.
Employee personal information is information that is collected, used or disclosed solely for the purposes reasonably required to establish, maintain, manage or terminate an employment relationship between an employee (including a volunteer) and an organization. This may include information such as name, home address, educational history and employment history. This does not include businesscontact informationor work product information(see below).
Business Contact information means information that allows an individual to be contacted at work. It includes the name, position name or title, business telephone number, business address, business e-mail and business fax number for the individual. Business contact information is not covered by this policy and is excluded from the definition of personal information in PIPA.
Work product information is information that is prepared or collected by an employee as part of that individual’s work responsibilities, but does not include information about an individual who did not prepare or collect the information. Work product information is not covered by this policy and is excluded from the definition of personal information in PIPA.
Confidential business information includes but is not limited to financial information and reports, membership and donor information, fundraising information, political communications, campaign plans and strategies (including strategies related to voter contact, digital, data and targeting, campaign messaging, and volunteer recruitment).
Organizations to which the policy applies
This policy extends across the BC NDP’s organizations as recognized under the BC NDP’s Constitution.
This policy applies to the information the BC NDP collects, uses and discloses in relation to its recognized organizations.
Why we collect and use personal information
Unless the purposes for collecting personal information are obvious, we will communicate the purposes for which personal information is collected, either orally, electronically or in writing, before or at the time of collection. We will only collect individual or member information that is reasonably necessary to fulfilling the following purposes:
- To create and maintain a list of members pursuant to the Constitution and to contact individuals and members as is reasonably necessary
- To verify the identity of individuals and members
- To interview, nominate, endorse and support candidates for public office
- To employ and manage staff
- To conduct the BC NDP’s financial and administrative affairs
- To promote the BC NDP, its affiliate and member organizations, and its candidates to the public
- To engage in public outreach and communications activities, including maintaining a web and social media presence
- To identify member and individual preferences, including to improve our communications with you
- To send out membership information
- To contact individuals and members to ask for their support for the BC NDP’s campaigns, including support through donations, volunteering and taking a lawn sign
- To manage donations and promote and support fundraising efforts
- To meet legal or regulatory requirements
- To conduct electoral campaigns and associated activities
- To make decisions about current and future campaigns, including voter contact activities, campaign messaging, policies, and platforms
- To maintain a list of voters
- To maintain a list of volunteers
- To conduct or commission polling, focus groups, surveys and other information-gathering activities reasonably related to the electoral process
- To occasionally exchange direct mail donor lists with like-minded not-for-profit organizations to help reach new supporters
Limits on collection, use, and disclosure
The BC NDP will only collect and use personal information that is necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to the purposes identified in this policy. The BC NDP will not collect, use or disclose personal information except for these purposes unless we receive further consent from the individual. We will not release individual or member lists or personal information to other organizations unless we have consent to do so.
We will only collect, use or disclose personal information in accordance with PIPA and applicable electoral or other legislation. Where we obtain data commercially, our vendors will either have obtained consent from individuals indicating that their personal information may be made available to other organizations or will have a legal basis for doing so (such as the phone numbers of subscribers that appears in a public telephone directory).
Individuals may withdraw consent to the collection, use or disclosure of their personal information at any time upon giving reasonable written notice, unless PIPA permits collection, use or disclosure without consent. Upon receiving written notice, the BC NDP will inform you of the likely consequences of withdrawing your consent.
Individuals or members cannot withdraw consent where this would frustrate the performance of a legal obligation. For example, the BC Election Act requires the BC NDP to provide the names and addresses of donors who give $250 or more per year to Elections BC. As such, a donor who gave more than $250 could not withdraw consent for the collection, use and disclosure of their personal information related to the donation.
How we disclose personal information
The BC NDP may disclose personal information where authorized by PIPA or required by law. In particular, we may be required to disclose personal information outside of our organization to comply with applicable electoral legislation. This may include an individual’s name and dates and amounts of donations.
The BC NDP will never sell or rent personal information to anyone. The BC NDP occasionally engages the services of a third party vendor to exchange our direct mail donor list with other like-minded not-for-profit organizations. Neither the BC NDP nor the other organizations receive each other’s donor lists; rather the third party vendor mails BC NDP materials to households on the other organizations’ direct mail donor lists and vice versa.
How we obtain consent to collect, use, and disclose personal information
The BC NDP will get individuals’ consent to collect, use or disclose their personal information, except where we are legally authorized or required by law to do so without consent. We mostly collect personal information directly from individuals when they voluntarily provide this information in the course of communicating with the BC NDP online, during canvassing activities, or at events.
The BC NDP may collect, use, or disclose personal information without knowledge or consent as permitted by PIPA, including in the following limited circumstances:
- The personal information is available to the public from a source prescribed in PIPA’s Regulations, including telephone directories or directory assistance services
- The personal information is necessary to determine a member’s suitability to be awarded Honorary Life Membership or another honour, award or benefit pursuant to the Constitution
- The collection is necessary to determine an individual or member’s suitability to represent the organization in any election
- To create and maintain a list of members pursuant to the Constitution
- To investigate a breach of an agreement, including the Constitution, a contravention of a law, or to prevent fraud
- The collection is required or authorized by law
For example, as a registered political party in British Columbia, we are authorized under the BC Elections Act to receive the voters list from Elections BC, which provides us with names and addresses of eligible voters and information about when or if they voted in the last election.
Consent can be provided in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting, using, or disclosing the personal information is considered obvious and the individual or member voluntarily provides personal information for that obvious purpose.
Consent may also be implied where an individual is given notice and a reasonable opportunity to opt-out of their personal information being used and the individual does not opt out.
In the case of employee personal information, PIPA allows the BC NDP to collect, use or disclose employee personal information without consent if it is reasonable for the purposes of establishing, managing or terminating an employment relationship. However, in such cases, the BC NDP will notify employees of the collection, use or disclosure.
How long we retain personal information
The BC NDP will keep personal information used to make a decision that directly affects individuals for at least one year after we make that decision. (PIPA requires this.)
The BC NDP will only retain personal information for as long as necessary to fulfil the identified purposes or as long as required for a legal or business purpose. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of the personal information, the purposes for which we use your personal information and whether we can achieve those purposes through other means, and the applicable legal requirements.
Different purposes will have different retention periods. Individuals can request further information regarding retention periods for different aspects of their personal information by contacting the BC NDP’s Chief Privacy Officer.
How we keep personal information secure
The BC NDP is committed to ensuring that information under our custody or control is protected against risks such as unauthorized access, collection, use, disclosure, copying, modification or disposal.
The BC NDP ensures appropriate security arrangements are in place to protect your personal information from these risks, including physical, technological and operational security measures. The BC NDP continually reviews and updates our security arrangements and controls as technology changes to ensure ongoing security of your personal information.
The BC NDP’s security privileges follow the principle of least privilege, where no one is granted access to information beyond what is required to fulfill the purpose for which the personal information has been collected/used. All individuals, including volunteers, and affiliated organizations, such as constituency associations, who may have access to personal information for the BC NDP’s purposes – such as canvassing activities – are required to review and agree to the BC NDP’s confidentiality, and non-disclosure requirements and to complete related privacy training.
Access to sensitive information is permitted over secure connections only, including through the use of secure logins, encryptions, VPNs and access logs with regular audits conducted by external security specialists.
The BC NDP uses reasonably secure methods whenever we destroy personal information.
How we ensure that personal information is accurate
The BC NDP will make reasonable efforts to ensure that individual or personal information is accurate and complete.
Individuals or members may write to the BC NDP to request corrections to their personal information that is under the BC NDP’s control. If the BC NDP is satisfied that an individual’s request for correction is reasonable, we will correct the personal information as soon as reasonably possible. If applicable, as soon as reasonably possible, the BC NDP will also send an individual’s corrected personal information to each organization it was disclosed to during the year before we corrected it.
How we provide individuals with access to their personal information under our control
Individuals and members have the right to access their personal information under the control of the BC NDP, subject to limited exceptions. The BC NDP will make a reasonable effort to assist and to respond to each applicant as accurately and completely as reasonably possible.
A request for access to personal information must be made in writing and must provide sufficient detail to identify the personal information being sought. The BC NDP may require individuals to prove their identity before giving them access to their personal information.
Upon request, the BC NDP will also provide individuals with information about the ways in which their personal information is or has been used, and, if applicable, to whom it has been disclosed.
PIPA allows the BC NDP to charge a “minimal” fee for providing an individual with access to their personal information. While the BC NDP will generally avoid charging a fee, depending on the scope of the access request, a fee may be required, in which case, we will provide the individual with a written fee estimate in advance and may require a deposit or pre-payment before releasing the information.
The BC NDP will provide the requested personal information within 30 business days after it is requested or we will give the individual written notice if we need more time to respond.
In some cases, the BC NDP may not give an individual access to certain personal information where authorized or required by PIPA to refuse access. The BC NDP will not disclose information that would reveal personal information about another individual or confidential business information that, if disclosed, could harm the competitive position of the organization.
If a request is refused in whole or in part, the BC NDP will tell the applicant in writing, providing reasons for the refusal and outlining further steps that are available to the applicant (including any internal review by the BC NDP in the case of members and the right to ask the Office of the Information and Privacy Commissioner for British Columbia to review the decision).
How individuals can complain, ask for access or ask questions
The BC NDP’s designated Privacy Officer or their delegate is responsible for ensuring the BC NDP’s compliance with this policy and PIPA.
Individuals and members should direct any access requests, complaints, concerns or questions regarding the BC NDP’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the individual or member may also write to the Office of the Information and Privacy Commissioner for British Columbia.
BC NDP Chief Privacy Officer: Deputy Provincial Director Heather Stoutenburg
Mailing address: #320 - 34 West 7th Avenue, Vancouver, BC V5Y 1L6
This policy may be amended by the BC NDP at any time without notice other than the posting of such amendments on this site.