Introduction

Minerva BC respects the privacy of our participants, donors and volunteers. We recognize our obligation to protect all personal information. According to the B.C. Personal Information Protection Act, personal information is information about an identifiable individual and includes employee personal information but does not include (a) contact information, or (b) work product information.

Minerva BC’s policy complies with Provincial privacy laws guided by adherence to the following 10 principles.

Principle 1: Accountable

Minerva BC is responsible for all personal information under its control. Our Privacy Officer is accountable for our compliance with the principles described in this Privacy Policy. Minerva BC has designated Tina Strehlke as the Privacy Officer, effective January 1, 2021.

Tina Strehlke

Minerva BC

320-111 West Hastings Street Vancouver, BC V6B

Tel: 604.683-7635

tinas@minervabc.ca

At times, the Privacy Officer may designate other individuals to act on their behalf.

Under this principle, Minerva BC is responsible for the collection, storage, use, disclosure, protection and accuracy of personal information collected and controlled by all Minerva BC programs and services.

Minerva BC has established:

- Procedures to protect personal information

- Procedures to receive and respond to complaints and inquiries

- Staff training to explain the privacy policy and to help them respond to customer queries about our privacy policy

Principle 2: Identify the Purpose

The purposes for which personal information is collected will be identified and documented by the Minerva BC at or before the time the information is collected.

Minerva BC collects personal information only for the following purposes:

- To establish and maintain responsible relations with customers, donors and volunteers and to provide ongoing service.

- To understand participant needs.

- To develop, market or provide programs and services that helps us to achieve our mission.

- To recognize donors and volunteers

- To track statistical information; and

- To meet legal and regulatory requirements

We collect, use and disclose personal information only for purposes that a reasonable person would consider appropriate in light of the circumstances. Upon request, staff collecting personal information shall explain these identified purposes or refer the individual to a designated person within Minerva BC who shall explain the purposes. Unless required by law, Minerva BC shall not use or disclose for any new purpose, personal information that has been collected without first identifying and documenting the new purpose and obtaining the consent of the individual concerned.

Principle 3: Consent

In determining the appropriate form of consent, Minerva BC shall consider the sensitivity of the personal information and the reasonable expectations of its participants. In general, the use of services by an individual constitutes implied consent for Minerva BC to collect, use and disclose personal information for all identified purposes.

For sensitive information, Minerva BC will obtain express consent at or before the time of collection. Individuals may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Individuals wishing to withdraw consent, should allow for 15 working days for this to be processed. Customers may contact Minerva BC for more information regarding the implications of withdrawing consent.

Principle 4: Limit Collection

Minerva BC will restrict its collection of personal information to that information which is necessary and reasonable for the purposes identified by the organization. Minerva BC will not collect extraneous personal information. Minerva BC will collect personal information only by fair and lawful means, and by being transparent with customers.

Principle 5: Limit Use, Disclosure and Retention

Minerva BC shall 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 by law. We shall retain personal information only if necessary for the fulfillment of those purposes, or as required by law. Personal information that is no longer necessary or relevant for the identified purposes or required to be retained by law shall be destroyed, erased or made anonymous.

Principle 6: Be Accurate

Minerva BC will keep personal information as accurate, complete and up to date as necessary for its purposes. Personal information will be updated as and when necessary to fulfill the identified purposes or upon notification by the individual.

Principle 7: Safeguarding Personal Information

Minerva BC shall protect personal information by security safeguards appropriate to the sensitivity of the information. We will protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures. Minerva BC shall protect personal information, regardless of the format in which it is held.

All Minerva BC employees with access to personal information shall be required as a condition of employment to respect the confidentiality of personal information.

Principle 8: Be Open

Minerva BC makes available to all participants, donors and volunteers’ information about our privacy policy and practices relating to the management of personal information.

We shall make information about our policies and practices easy to understand, including:

- The title and contact information of our privacy officer.

- The means of gaining access to personal information held by Minerva BC; and

- The complaint process for the management of personal information

Principle 9: Access to Personal Information

Upon request in writing, Minerva BC shall confirm the existence, use and disclosure of his or her personal information and shall give the individual access to that information. Individuals may challenge the accuracy and completeness of the information and have it amended as appropriate.

Upon request, Minerva BC shall provide a copy of the information requested or a response that includes reasons for not providing access, within 30 business days. According to the Personal Information Act, there may be certain circumstances whereby Minerva BC is not able to provide access to personal information it holds on an individual.

Principle 10: Challenging Compliance

Individuals will be able to address a challenge concerning compliance with the above principles to

Minerva BC’s privacy officer. Minerva BC will establish and maintain procedures to receive and respond to complaints or inquiries about its policies and practices related to the handling of personal information. The complaint procedure will be easily accessible and simple to use.

Minerva BC will investigate all complaints concerning compliance with the policy. If a complaint is found to be justified, Minerva BC will take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures.

PRIVACY AND USE OF ZOOM TECHNOLOGY

Zoom is compliant with the Freedom of Information and Protection of Privacy Act (FIPPA) which governs public bodies and BC. It is also compliant with PIPEDA federal privacy legislation. Minerva has enabled settings on Zoom to ensure all data transfer and data residency requirements are met.

Minerva Facilitators use Zoom for real-time leadership learning sessions as follows:
- Facilitators inform participants that they can maintain privacy by logging in using only their first name, or a nickname, turning off their camera, and muting their microphone

- Facilitators may record sessions using Zoom but will keep these recordings secure and confidential. Participants are always informed when a session is being recorded so that they can manage their privacy settings

PRIVACY AND USE OF SURVEY MONKEY

Minerva uses Survey Monkey to collect information from potential program participants, and to seek feedback on programs and events. Survey Monkey stores data in international centres including the United States, Canada and Ireland.

In order to limit collection, storage and access to personal data, Minerva follows the following practices:
- We notify users that data may be transferred/stored outside of Canada and provide a different option for applicants as required

- We download and delete survey information (program applications) to a secure VPN

- We make responses to feedback surveys anonymous for program participants and event attendees wherever possible

- We review the data saved in our account regularly and delete it when it is no longer necessary

PRIVACY AND THE USE OF THINKIFIC TECHNOLOGY

Minerva uses technology created by Thinkific Labs to deliver online programs. Thinkific collects learner information including enrollment information, and collects data on their use of their platform. Thinkific may transmit personal information outside of Canada and ensures that any such transfer is done in accordance with regulations including transfers to countries where the EC reached an “adequacy

decision” about the country where the receiver is based, or transfers being covered by “appropriate safeguards” including, for example, standard contractual clauses.

In order to limit collection, storage and access to personal data, Minerva follows the following practices:
- We manually enroll program participants in Thinkific with the following information: Name, Email Address, Company Name, and Job Title. This information is provided by the applicants

- Participants are registered in the course they have been accepted to, and their personal information is only visible to Facilitators and administrators of the Minerva Thinkific platform

- When users are enrolled, they receive a link to a personal Google document that is stored in a unique file on the Minerva shared Google Drive. Participants are encouraged to save, download and store this file on their personal computers. Minerva deletes copies of the individual participant workbooks within a year of program completion

- Online course access is closed, and participant information deleted within one year of program completion

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Minerva BC is a Vancouver-based charity that is
dedicated to advancing the leadership of women and girls.

Our office is located on the unceded territory of the Coast Salish Peoples, including the territories of the xʷməθkʷəy̓əm (Musqueam), Skwxwú7mesh (Squamish), and səl̓ílwətaʔɬ/Selilwitulh (Tsleil-Waututh) Nations.