Privacy

ID:      P02-21.0
Type:      Governance
Created:      2019-05-27
Revised:      2021-04-20

Rationale

Whitby Courthouse Theatre’s Board of Directors, Coordinators, staff and volunteers are required to safeguard all personal information in accordance with the Privacy Act (R.S.C., 1985, c. P-21), Personal Information Protection and Electronic Documents Act (S.C. 2000, c. 5), Freedom of Information and Protection of Privacy Act (R.S.O. 1990, c. F.31), and the Municipal Freedom of Information and Protection of Privacy Act (R.S.O. 1990, c. M.56). This policy outlines the principles and practices enforced to protect individual personal information, and Whitby Courthouse Theatre.

Responsibilities

This policy applies to every individual volunteering or working for, on behalf of, or in the name of Whitby Courthouse Theatre, sometimes referred to as ‘agents’ for the remainder of this policy.

Definitions

Personal information is defined as information about an identifiable individual. This includes an individual’s name in conjunction with home address or phone number, age, sex, gender identity, marital or family status, financial information, educational history, etc.

Collection of Information

Agents of Whitby Courthouse Theatre may only collect personal information that is required in their line of duty, for the purposes of providing requested services to our members, volunteers, patrons, employees or members of the public, including personal information needed to:

  • Sell and deliver tickets
  • Facilitate memberships
  • Rent equipment or services
  • Send electronic communications
  • Comply with government regulations

Agents must inform individuals, before or at the time of collecting personal information, of the purposes for which we are collecting the information, unless an individual provides their information for an obvious purpose.

Consent

Consent must be received for the collection or use of personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. Consent may be assumed in cases where information is volunteered for an obvious purpose.

Use of Information

Personal information may only be used for the purpose for which it was collected. It is not permitted that information be used for any other purpose.

Safeguarding of Information

The following must be done to ensure that personal information is secure:

  • Strictly limiting access to data.
  • Storing and protecting all personal data securely.
  • Taking every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information as well as any unauthorized access to personal information.

Personal information may only be retained as long as is required to fulfil the purposes for which the information was collected or for legal or business purposes, it is otherwise to be destroyed.

Privacy Officer

The Treasurer shall assume the role of the Privacy Officer and is responsible for the enforcement of this policy and for ensuring compliance with relevant laws and statues.

Access to Records Containing Personal Information

Individuals have a right to access their own personal information in a record that is in the custody of Whitby Courthouse Theatre, except if that information would reveal personal information about another individual. Sufficient information must be included in the request to allow the Privacy Officer to identify the information that is being requested.

If a request is rejected in whole or in part, the Privacy Officer will provide the reasons for the refusal. In some cases where exceptions to access apply, that information may be withheld, and the individual will be provided with the remainder of the record. Individuals may also request information about Whitby Courthouse Theatre’s use of personal information. In addition, individuals may request a correction of an error or omission in their personal information.

All requests must be made to the Privacy Officer who must respond within 45 calendar days, unless an extension is granted.

Location of Personal Information

All document (or copies of documents) containing personal information as defined in this policy must:

  • Not be taken home or removed from the Whitby Courthouse Theatre Office.
  • Be stored in the safe or locked filling cabinets in the Whitby Courthouse Theatre Office.
  • Only be accessible to those necessary as detailed in ‘Access to Personal Information’.

The Whitby Courthouse Theatre Office is located at 416 Centre Street South in Whitby, Ontario.

Access to Personal Information

  • Access to personal financial information is restricted to the Treasurer.
  • Access to any personal information must be limited to only those requiring it to fulfil their duties.

Retention

Information must be destroyed as soon as it is no longer required. The Privacy Officer is responsible for ensuring records are destroyed. The following retention policies apply:

  • Financial and corporate records – 7 years
  • Subscription forms – 2 years
  • Membership forms – 1 year
  • Youth group registration forms – 1 year
  • Audition forms – 6 months
  • All other non-financial/corporate records – 1 year

Paper records must be shredded and disposed of securely, digital records must be permanently deleted.