Phyllis Katcher, a Comox-based international student homestay host (pictured in the foreground [...]
The Canada Homestay Network fulfills each of the ten fair information principles of Schedule 1 of the Personal Information Protection and Electronic Documents Act (PIPEDA) through the following measures. To receive copies of our policies and procedures, please contact our Data Controller at firstname.lastname@example.org.
1. Be Accountable
CHN has written this document in order to comply with all of the principles of Schedule 1 of the PIPEDA. The privacy officer appointed by CHN is Jennifer Wilson. The privacy officer will:
- ensure that all personal information held by the organization is protected;
- maintain the organizations’ personal information policies and practices;
- have the authority to intervene on privacy issues relating to any of the organization’s operations;
- analyze all personal information handling practices including ongoing activities and new initiatives.
The privacy officer’s name will be identified on CHN’s website. CHN staff will be informed and trained on privacy policies and procedures. Information about our policies and procedures will be made available to our customers on our website and in our contractual agreements.
Related Policies and Procedures:
- Host Agreement
- Student Participation Agreement
- Request for Personal Information Form
- Appropriate Use of Personal Information Policy
- Correction of Personal Information Form
- Policy on Maintaining Accurate Personal Information
- Retention and Destruction of Personal Information Policy
- Complaints Procedure
- Security Measures for Personal Information Policy
- Staff Training for PIPEDA Procedure
- List of Personal Information Collected
- Storage and Retrieval of Personal Information Procedure
2. Identify the Purpose
CHN has identified the following reasons for collecting personal information from our host families and program participants (our “customers”):
- Maintain a file of the customer’s personal information, to allow us to match host families with international students;
- In the event that a host family is matched with a student, CHN will disclose information about the host family to the international student, their family and, if applicable, the agent acting on their behalf in their country of origin, and student information will be disclosed to the host family;
- In the event that a host family is matched with a student, CHN will also disclose information about the host family to third-party organizations that are involved in the international student’s stay in Canada. These organizations may include, but are not limited to, schools, universities and tour companies;
- Manage invoicing, payments, and refunds for the service the host family provides as homestay hosts for international students;
- Contact the customer for the purpose of informing them of meetings, changes to our policies or to communicate any other important information pertaining to the homestay program;
- Collect statistics for the sole use of CHN’s business development.
CHN identifies these purposes in our Host Agreement and Student Participation Agreement, which are signed by hosts or students respectively as a condition of their involvement in the homestay program. Any new purposes for the information will be identified as they arise and CHN will obtain the customer’s consent before using the information for any new purpose.
3. Obtain Consent
CHN will obtain consent for the use of personal information from each customer, through the use of our Host Agreement and Student Participation Agreement. These documents also inform the customer of the purpose for the collection, use and disclosure of personal information. CHN will record the consent received by filing the signed Agreement in the customer’s profile. In the event that a customer withdraws their consent for use of personal information, the file will be removed from our electronic system and all hard copies of the customer information will be destroyed. CHN staff will be trained to be able to answer the customer’s questions about the purposes of the collection.
4. Limit Collection
CHN limits the amount and type of personal information collected to what is necessary for our identified purposes. CHN identifies the kind of personal information we collect. See our List of Personal Information Collected. CHN staff is trained to ensure that they are able to explain to customers why the information is needed.
5. Limit Use, Disclosure and Retention
CHN uses and discloses personal information only for the purposes identified in our Host Agreement and Student Participation Agreement. CHN retains personal information on a customer only as long as they are considered “active” in our database, or as long as required by law for Revenue Canada.
CHN has identified guidelines and procedures for the retention and destruction of personal information. See Retention and Destruction of Personal Information Policy. CHN destroys, erases, or renders anonymous personal information that is no longer required for an identified purpose or a legal requirement. CHN conducts regular reviews of our inactive customers to determine whether the information is still required.
6. Be Accurate
CHN has established a policy to ensure that personal information is kept current in our database. See our Policy on Maintaining Accurate Personal Information. CHN can reasonably expect our customers to inform our office in the event that the following personal information has changed:
- Address including street, apartment, city and postal code;
- Phone number including home, office, fax, cell;
- Email address (if applicable);
- Pets (of host families);
- Changes or renovations to house or students bedrooms (of host families);
- Account information for payment/refund purposes.
CHN will verify personal information prior to its disclosure. CHN staff maintain accuracy by
- Following the List of Personal Information Collected to ensure all information is collected for a specified purpose;
- Following the Storage and Retrieval of Personal Information Procedure;
- Ensuring that personal information received from a third party is accurate and complete;
- Recording the date when the personal information was obtained or updated; and
- Recording the steps taken to verify accuracy, completeness and timeliness of the information in the database or customer file.
7. Use Appropriate Safeguards
CHN protects personal information against loss, theft, unauthorized access, disclosure, copying, use, or modification as outlined in our Security Measures for Personal Information Policy. CHN staff are allowed access to the database and personal information on a “need-to-know” basis. CHN staff are trained in the importance of maintaining the security and confidentiality of personal information. CHN staff are regularly trained on security safeguards. The CHN privacy officer regularly reviews our security measures and recommends updates to the security measures as needed.
8. Be Open
CHN informs our customers that we have policies and practices for the management of personal information on our website and during our initial interviews. CHN distributes our policies and procedures by posting links to these documents on our website and making them available to customers in a hard copy format on request. CHN staff are trained in the procedures for responding to individual inquiries. The name and address of the CHN Privacy Officer are made available on our website, or by request from our office.
CHN customers have full access to their personal information at any time and may contact our head office for our Request for Personal Information Form and/or the Correction of Personal Information Form. Customers are made aware of the process of obtaining personal information on our website.
CHN customers are made aware of our complaints process on our website. See also our Complaints Procedure.
CHN has outlined what personal information is disclosed to other organizations in our List of Personal Information Collected.
9. Give Individuals Access
CHN employees are trained in the procedures for responding to individual inquiries regarding their personal information, how it is or has been used, and to whom it has been disclosed. CHN customers have full access to their personal information at any time and may contact our head office for our Request for Personal Information Form. Customers are made aware of the process of obtaining personal information on our website.
CHN customers may correct errors in their personal information by phone, by logging into their host or student portal account, or by completing our Correction of Personal Information Form. Customers are made aware of the process for correcting personal information on our website. CHN verifies the identity of the requestor by signature, as outlined in our Request for Personal Information Form.
CHN documents any disagreements in the file or database and advises third parties where appropriate. CHN ensures that the requested information is understandable by eliminating or explaining acronyms, abbreviations, and codes.
10. Provide Recourse
CHN has developed a simple Complaints Procedure. CHN informs our customers of their avenues of recourse on our Complaints Procedure which is posted on our website and is available upon request from our head office. CHN investigates all complaints received, and takes appropriate measures to correct information handling practices and policies. CHN handles all complaints in a timely fashion by recording the date the complaint is received and promptly acknowledging receipt of the complaint, as outlined in our Complaints Procedure. CHN will maintain a record of all decisions to ensure consistency in applying the Act.
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12. Data Controller
The Data Controller responsible for your personal information for the purposes of the applicable European Union data protection law is:
The Canada Homestay Network
ATTN: Data Protection Officer
1031 St David St, Victoria,
BC, Canada V8S 4Y7
Tel: 1 877 441 4443 x 2123
If you have any questions about this Privacy Notice or our data collection practices, please contact us at the address, telephone or email listed above and specify your country of residence.
13. How we share information with third parties
As a general rule, we do not share your personal information with anyone outside of CHN. However, in the normal course of business, CHN may utilize trusted third parties relevant to the services we provide, including but not limited to; consultants, strategic partnerships and contractors. These trusted third parties would be bound by obligations of confidentiality.