The Improv Embassy Personal Information Protection Policy
The Improv Embassy is committed to safeguarding the personal information entrusted to us by our students and customers [hereafter clients]. We manage your personal information in accordance with Canada’s Personal Information Protection and Electronic Documents Act (PIPEDA) and other applicable laws. This policy outlines the principles and practices we follow in protecting your personal information.
This policy applies to the Improv Embassy and to any person providing services on our behalf. A copy of this policy is provided to any client on request.
What is personal information?
Personal information means information about an identifiable individual. This includes an individual’s name, home address and phone number, age, sex, marital or family status, an identifying number, financial information, educational history, image, etc.
What personal information do we collect?
We collect only the personal information that we need for the purposes of providing services to our clients, including personal information needed to: deliver requested products and services enrol a client in a course of workshop provide clients with informational emails and advertising. We normally collect client personal information directly from our clients. We may collect your information from other persons only with your consent or as authorized by law. We inform our clients, before or at the time of collecting personal information, of the purposes for which we are collecting the information. The only time we don’t provide this notification is when a client volunteers information for an obvious purpose (for example, producing a credit card to pay for a service when the information will be used only to process the payment).
The Improv Embassy may request to inspect a driver’s licence, healthcare card, or passport for the purpose of verifying that a client is of the age of majority, but will not make records of these documents.
The Improv Embassy does not sell client’s personal information. The Improv Embassy may grant indirect use of non-sensitive personal information to third-parties from time to time (e.g. a third party service provider may have an advertisement in an email sent out to the Improv Embassy mailing list).
Consent
We ask for consent to collect, use or disclose client personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose, like enrolling in a course.
We assume your consent to continue to use and, where applicable, disclose personal information that we
have already collected, for the purpose for which the information was collected.
We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask clients to provide their consent orally (in person, by telephone), or in writing (by signing a consent form).
In cases that do not involve sensitive personal information, we may rely on “opt-out” consent.
For example, the Improv Embassy maintains an email mailing list to keep past clients informed about future Improv Embassy course offerings. Each email sent to the mailing list provides an opportunity to opt-out of receiving future e-mails. The Improv Embassy maintains a list of email addresses that have opted-out of receiving emails to prevent the receipt of unwanted emails. The Improv Embassy will completely erase any record of an individual’s email address upon request.
Additionally, an individual’s image may be recorded during Improv Embassy events, and may be used in
advertising. Individuals may opt-out of having their image recorded by telling the organizer of an event of their wishes, or they may opt-out after the fact, and their image will be removed from the Improv Embassy’s records upon request.
In general, a client may withdraw consent to the use and disclosure of personal information at any time,
unless the personal information is necessary for us to fulfil our legal obligations. We will respect your
decision, but we may not be able to provide you with certain products and services if we do not have the
necessary personal information.
How do we use and disclose personal information?
We use and disclose client personal information only for the purpose for which the information was collected, except as authorized by law. For example, we may maintain lists of past participants in Improv Embassy courses, for the purpose of tracking which clients are eligible to partake in courses with prerequisites.
If we wish to use or disclose your personal information for any new business purpose, we will ask for your consent. We may not seek consent if the law allows this (e.g. the law allows organizations to use personal
information without consent for the purpose of collecting a debt). Purchasing Improv Embassy products may require providing personal information to third-party service providers.
The Improv Embassy endeavours to work with third-parties that are in compliance with PIPEDA, but clients are encouraged to review the personal information and privacy policies of third-party service providers. The Improv Embassy’s primary service provider for course registration and ticket sales is Corsizo. Information concerning Corsizo’s compliance with PIPEDA can be found here: https://help.corsizio.com/article/36-erase-personal-data-from-corsizio
What is personal employee information?
Personal employee information is personal information about an employee or volunteer which is collected, used or disclosed solely for the purposes of establishing, managing or terminating an employment relationship or a volunteer work relationship. Personal employee information may, in some circumstances, include a Social Insurance Number, a performance review, etc.
We can collect, use and disclose your personal employee information without your consent only for the
purposes of establishing, managing or ending the employment or volunteer relationship. We will provide
current employees and volunteers with prior notice about what information we collect, use or disclose and our purpose for doing so.
What personal employee information do we collect, use and disclose?
We collect, use and disclose personal employee information to meet the following purposes:
- Determining eligibility for employment or volunteer work, including verifying qualifications and references Establishing training and development requirements
- Assessing performance and managing performance issues if they arise
- Administering pay and benefits (paid employees only)
- Processing employee work-related claims (e.g. benefits, workers’ compensation, insurance claims) (paid employees only)
- Complying with requirements of funding bodies (e.g. artistic grants)
- Complying with applicable laws (e.g. Canada Income Tax Act, Ontario Employment Standards Act)
We only collect, use and disclose the amount and type of personal employee information that is reasonable to meet the above purposes. The following is a list of personal employee information that we may collect, use and disclose to meet those purposes.
- Contact information such as your name, home address, telephone number
- Criminal background checks (if an employee or volunteer will be teaching or otherwise providing services to minors)
- Employment or volunteer information such as your resume (including educational background, work history and references), reference information and interview notes, letters of offer and acceptance of employment, policy acknowledgement forms, background verification information, workplace performance evaluations, emergency contacts, etc.
- Benefit information such as forms relating to applications or changes to health and insurance benefits including medical and dental care, life insurance, short and long term disability, etc. (paid employees only)
- Financial information, such as pay cheque deposit information and tax-related information, including Social Insurance Numbers (paid employees only, in order to provide employees with records of employment and T-4 slips for income tax and Canada Pension Plan (CPP) purposes.)
- Other personal information required for the purposes of our employment or volunteer relationship
We will inform our employees and volunteers of any new purpose for which we will collect, use, or disclose personal employee information, or we will obtain your consent, before or at the time the information is collected.
We will obtain your consent to collect, use and disclose your personal information for purposes unrelated to the employment or volunteer relationship.
The Improv Embassy will never require passwords to the social media accounts of prospective employees of volunteers for the purpose of employee/volunteer screening.
What information do we provide for employment/volunteer references?
In some cases, after your employment or volunteer relationship with us ends, we will be contacted by other organizations and asked to provide a reference for you. It is our policy not to disclose personal information about our employees and volunteers to other organizations who request references without consent. The personal information we normally provide in a reference includes:
Confirmation that an individual was an employee or volunteer, including the position, and date range of the employment or volunteering
General information about an individual’s job duties and information about the employee or volunteer’s
ability to perform job duties and success in the employment or volunteer relationship
How do we safeguard personal information?
We make every reasonable effort to ensure that personal information is accurate and complete. We rely on individuals to notify us if there is a change to their personal information that may affect their relationship with our organization. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible. In some cases we may ask for a written request for correction.
We protect personal information in a manner appropriate for the sensitivity of the information. We make
every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as
well as any unauthorized access to personal information.
We use appropriate security measures when destroying personal information, including shredding paper
records and permanently deleting electronic records.
We retain personal information only as long as is reasonable to fulfil the purposes for which the information was collected or for legal or business purposes.
Access to, or destruction of, records containing personal information
Individuals have a right to access their own personal information in a record that is in the custody or under the control of The Improv Embassy subject to exceptions required by law. For example, the Improv Embassy may refuse to provide access to information that would reveal personal information about another individual. Individuals have the right to request the Improv Embassy delete any personal information in a record that is in the custody or under the control of the Improve Embassy subject to exceptions required by law, or any obligations the Improv Embassy maintain that information, as required by law.
If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where
exceptions to access apply, we may withhold that information and provide you with the remainder of the
record.
You may make a request for access to your personal information, or the destruction of your personal
information, by writing to the Board of Directors, which is tasked with ensuring the Improv Embassy is in
compliance with PIPEDA. You must provide sufficient information in your request to allow us to identify the information you are seeking.
You may also request information about our use of your personal information and any disclosure of that
information to persons outside our organization. In addition, you may request a correction of an error or
omission in your personal information. We will respond to your request within 30 calendar days, in most cases.
The Improv Embassy may notify you that an additional 30 days is required to respond to your request, if
fulling your request within 30 day would unreasonably interfere with the activities of the organization, or
your request requires the Improv Embassy to undertake legal or other consultations necessary to respond to the request, or your request requires the conversion of your personal information into an alternative format.
Breeches of Security Safeguards
The Improv Embassy shall report to the Privacy Commissioner of Canada any breach of security
safeguards involving personal information under its control if it is reasonable in the circumstances to
believe that the breach creates a real risk of significant harm to an individual.
Unless otherwise prohibited by law, the Improv Embassy shall notify an individual of any breach of
security safeguards involving the individual’s personal information under the organization’s control if it
is reasonable in the circumstances to believe that the breach creates a real risk of significant harm to the
individual.
Questions and complaints
If you have a question or concern about any collection, use or disclosure of personal information by the
Improv Embassy, or about a request for access to, or destruction of your own personal information, please contact the Board of Directors at [email protected]. Each member of the Improv Embassy’s Board of Directors is a Privacy Officer for the organization, with a responsibility to ensure the organization is in compliance with this policy.
If you are not satisfied with the response you receive concerning a commercial activity undertaken by the
Improv Embassy, you should contact the Office of the Privacy Commissioner of Canada:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, QC K1A 1H3
Toll Free: 1-800-282-1376
Website: http://www.priv.gc.ca
Complaint form: www.plainte-complaint.priv.gc.ca/en/register-pipeda