Rationale
Independent schools in British Columbia must comply with the requirements of the Personal Information Protection Act (British Columbia) for the purpose of protecting the privacy of students and families. Policy Statement BC Waldorf Schools’ Commitment to You
Safeguarding personal information of parents and students is a fundamental concern of BC Waldorf Schools. BC Waldorf Schools are committed to meeting or exceeding the privacy standards established by British Columbia’s Personal Information Protection Act (PIPA) and any other applicable legislation. This Personal Information Privacy Policy describes the policies and practices of BC Waldorf Schools regarding the collection, use and disclosure of personal information about students and parents, including the steps the school has taken to ensure personal and financial information is handled appropriately and securely. BC Waldorf Schools may add, modify or remove portions of this Personal Information Privacy Policy when it is considered appropriate to do so, and any such changes will be effective upon giving notice of the revised policy. You may ask for the most recent update of this Personal Information Privacy Policy at any BC Waldorf school office. This Personal Information Privacy Policy may be supplemented or modified by agreements entered into between BC Waldorf Schools and an individual from time to time. Ten Privacy Principles As part of BC Waldorf Schools’ commitment, the Ten Privacy Principles govern the actions of schools as they relate to the use of personal information. This Personal Information Privacy Policy describes the Ten Privacy Principles and provides further details regarding BC Waldorf Schools’ compliance with the principles. Definitions In this Personal Information Privacy Policy, the following terms have the meanings set out below: “personal information” means any information about an identifiable individual, as further defined under British Columbia’s Personal Information Protection Act or other applicable laws. Personal information excludes the name, position name or title, business telephone number, business address, business email, and business fax number of an individual, as well as any publicly available information as designated under applicable laws, such as information available from a public telephone directory or from a public registry. “Parent” means the parent, guardian, or other legal representative of a student. “Student” means a prospective, current, or past student of a BC Waldorf School. Principle 1 – Accountability
BC Waldorf Schools are responsible for maintaining and protecting the personal information under their control. In fulfilling this mandate, each school designates (an) individual(s) who is(are) accountable for the school’s compliance with the Ten Privacy Principles. This individual is the Privacy Officer of that school. Principle 2 – Identifying Purposes
BC Waldorf Schools will, before or at the time personal information is collected, identify the purposes for which the information is collected, used and disclosed. What Information is Collected? BC Waldorf Schools collect and use personal information to provide students with the best possible educational services enunciated by the Mission statement of each BC Waldorf school. Most of the information the schools collect comes to schools directly from parents and students or is information regarding the students’ school activities, performance or behaviour, such as attendance records or grades. For example, when a student applies to register in a BC Waldorf school, the school will ask parents to provide the information that enables it to complete the registration process. This also includes information on academic, health, and personal matters needed by the schools to provide the best possible education and co-curricular programs. During the educational life of a student at a BC Waldorf School, there are times when student information must be shared to resolve peer to peer conflict in a restorative way. For example, if two students have ongoing conflict in a class, teachers may include student names in parent communications, and hold collaborative meetings to repair the relationships. BC Waldorf Schools also collect information in connection with the use of their computer systems. [Personal information may also be collected and used and disclosed in the course of the operation of building security systems, including video and other surveillance systems.] Principle 3 – Consent
BC Waldorf Schools will obtain consent of the individual for the collection, use or disclosure of personal information except where the law states exemptions, grants permission, or creates a requirement for collection, use, or disclosure of personal information. Requirements for consent to collection, use or disclosure of personal information vary depending on circumstances and on the type of personal information that is intended to be collected, used or disclosed. In determining whether consent is required and, if so, what form of consent is appropriate, BC Waldorf Schools will take into account both the sensitivity of the personal information and the purposes for which schools will use the information. Consent may be express, implied (including through use of “opt-out” consent where appropriate), or deemed. For example, if an individual provides his/her mailing address and requests information regarding a particular service, consent to use the address to provide the requested information may be implied. On giving reasonable written notice to a specific BC Waldorf School, an individual may withdraw consent to the collection, use or disclosure of his or her personal information. Upon notice of withdrawal of consent, the school will notify the individual of the likely consequences of withdrawing his or her consent and, except where otherwise required or permitted by law, the school will stop collecting, using or disclosing the personal information as requested. If a person provides a BC Waldorf School or its service providers or agents with personal information about an individual, the person represents that it has all necessary authority and/or has obtained all necessary consents from such individual to enable a specific BC Waldorf School to collect, use and disclose such personal information for the purposes set forth in this Personal Information Privacy Policy. Principle 4 – Limiting Collection
BC Waldorf Schools will limit the personal information collected to that information necessary for the purposes identified by the school. Principle 5 – Use, Disclosure and Retention
BC Waldorf Schools will only use, disclose and retain personal information for the purpose for which it was collected unless the individual has otherwise consented, or when its use, disclosure or retention is required or permitted by law. How is Information Used? BC Waldorf Schools use personal information as follows:
When May Information be Disclosed? BC Waldorf Schools may disclose an individual’s personal information to others in connection with the purpose for which it was collected, as consented to by the individual, or as required or permitted by law. The following are some examples of how a BC Waldorf School may disclose personal information. When Authorized by You
your information will be obtained verbally. In other cases such as when you communicate through email, your consent will be obtained electronically. When Required by Law The type of information BC Waldorf Schools are legally required to disclose most often relates to family court issues, legal proceedings, court orders and government tax reporting requirements. Student information as per Form 1701 is annually filed with the Ministry of Education. Only the information specifically requested is disclosed and schools take precautions to satisfy themselves that the authorities making the request have legitimate grounds to do so. When Permitted by Law BC Waldorf Schools are legally permitted to disclose some personal information in situations such as an investigation of illegal activities, reasonable methods to collect overdue accounts, a medical emergency or suspicion of illegal activities, etc. Only pertinent information is disclosed. BC Waldorf Schools do not sell, lease or trade information about parents or students to other parties. Outside Service Suppliers BC Waldorf Schools sometimes contact outside organizations to perform specialized services such as printing, student assessments, market research or data processing. Suppliers of specialized services are given only the information necessary to perform those services, and schools take appropriate steps to ensure that such information is securely transferred and stored and is used only to fulfill the purposes for which it was disclosed to the service provider. Restricting Sharing Information If parents choose to limit the sharing of personal information, they must contact their specific school office and submit a written letter specifying which items of personal information they wish to limit, and to whom they wish these items to be restricted. Certain agencies, by law, have access to certain types of personal information. How Long Is Personal Information Retained? Personal information will only be retained for the period of time required to fulfill the purpose for which it was collected. Once the personal information is no longer required to be retained to fulfill the purposes for which it was collected and is no longer required or permitted to be retained for legal or business purposes, it will be destroyed or made anonymous. Principle 6 – Accuracy
BC Waldorf Schools will take appropriate steps to ensure that personal information collected is as accurate and complete as is reasonably required in connection with the purposes for which it was collected, used or disclosed. How May I Update Outdated or Incorrect Information? An individual may, upon written request to a specific BC Waldorf School, request that the school correct an error or omission in any personal information that is under that school’s control and the school will, as appropriate, amend the information as requested and send the corrected personal information to each third party to which it has disclosed the information during the preceding year. Principle 7 – Safeguarding Personal Information
BC Waldorf Schools will protect personal information by security safeguards that are appropriate to the sensitivity level of the information. BC Waldorf School Employees In the course of daily operations of individual schools, access to personal information is restricted to authorized employees who have a legitimate reason for accessing it. For example, teachers will have access to personal information about students at their school but not entire accounts with that school. Employees are appropriately educated about the importance of privacy and they are required to follow the schools’ policies and procedures regarding handling of personal information. Student Files Student files are stored in secured filing cabinets. Access is restricted to only those employees (teachers, teacher-aides, counselors, admin assistants or coordinators, etc.) who, by nature of their work, are required to see them. Electronic Security BC Waldorf Schools manage electronic files appropriately with passwords and security measures that limit access by unauthorized personnel. Schools’ security practices are reviewed periodically to ensure that the privacy of personal information is not compromised. Principle 8 – Openness
BC Waldorf Schools will make information available to individuals concerning the policies and practices that apply to the management of personal information. Individuals may direct any questions or enquiries with respect to a school’s privacy policies or practices to the Privacy Officer of a specific school. Principle 9 – Individual Access
BC Waldorf Schools will inform an individual, upon the individual’s request, of the existence, use and disclosure of the individual’s personal information, and shall give the individual access to it in accordance with the law. How May I Access My Personal Information? Individuals may access and verify any personal information with appropriate notice so that a school’s office personnel is able to supply the information required. Most of this information is available in the registration forms and other forms that were filled out. Parent Access to Student Personal Information A parent may access and verify school records of the student, with appropriate notice during normal school hours. In situations of family breakdown, the school will grant access to records of students in accordance with the law. Principle 10 – Complaint Process
Individuals may question compliance with the above principles. Questions, Concerns and Complaints Questions, concerns, and complaints about privacy, confidentiality and personal information handling policies and practices of a BC Waldorf School should be directed to the specific school’s Privacy Officer by calling the school office. If necessary, individuals will be referred to use the school’s complaint procedure and appeals policies. BC Waldorf Collective - AWNSA Registered Initiative, Associate, and Full Member Waldorf Schools of BC
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