PERSONAL INFORMATION PRIVACY POLICY
(Last updated: January 2024)
The Students’ Union (“SU”) is committed to safeguarding the personal information entrusted to us by our employees, volunteers, clients, vendors, and patrons. We manage your personal information in accordance with the Personal Information Protection Act (Alberta) (“PIPA”).
This policy outlines the principles and practices we follow in protecting your personal information.
What is personal information?
Personal information is information that can identify an individual (for example, name, home address, home phone number, email address, ID numbers, financial information such as credit card numbers), and information about an individual (for example, physical description, educational qualifications, blood type). For this policy to apply, the personal information in question must be about an individual, identify an individual, or be able to identify an individual.
However, not all the information we collect about or from you is necessarily considered personal information. For example, business or student club contact information, which includes an individual’s name and position or title, along with the organization’s telephone number, mailing address, email, and other organizational contact information, is not considered personal information and is not covered by this policy.
What personal information do we collect?
The collection, use, or disclosure of personal information is limited to that which is necessary to conduct the SU’s day-to-day business, commercial activities, and services and shall not be used for any other purposes except as authorized by the SU’s Privacy Officer.
This includes, but is not limited to, the personal information needed to:
- establish, manage, or terminate the employment relationship between the SU and its employees and volunteers;
- run the SU general election and by-election;
- determine the financial eligibility and manage the lease of space within the MacEwan Building;
- provide a safe environment to patrons of the Den and Black Lounge;
- manage the daily operation of the SU and its various businesses and services including, but not limited to, the MacEwan Conference and Events Centre, Den and Black Lounge, retail outlets including the Stör and Bound & Copied, the Clubs office, Volunteer Services, the Campus Food Bank, the Volunteer Tax Program, and the Information Centre; and
- rent lockers to students.
We normally collect information directly from our employees and/or customers. We may collect your information from other persons with your consent or as authorized by law.
We inform employees and/or customers, before or at the time of collecting personal information, of the purposes for which we are collecting the information.
Consent
We ask for consent to collect, use, or disclose 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.
We ask for your express consent for some purposes and may not be able to provide certain services or access to businesses if you are unwilling to consent to the collection, use, or disclosure of certain personal information. Where express consent is needed, we will normally ask customers to provide their consent verbally and in person or in writing by signing a consent form or by checking a box on a form, which may include electronic forms.
A person may withdraw consent to the use and disclosure of personal information at any time unless the personal information is necessary for us to fulfill our legal obligations. We will respect your decision, but we may not be able to provide you with certain services or access if we do not have the necessary personal information.
We may collect, use, or disclose personal information without consent only as authorized by law. For example, we may not request consent when the collection, use, or disclosure is reasonable for an investigation or legal proceeding, to collect a debt owed to the SU, in an emergency that threatens life, health, or safety, or when the personal information is from a public source.
How do we use and disclose personal information?
We use and disclose personal information only for the purposes for which the information was collected, except as authorized by law. For example, we may disclose customer information to credit bureaus or credit companies to prevent fraud. The law also allows us to use contact information for collecting a debt owed should that be necessary.
We do not distribute personal information to any private or public organizations, including the University of Calgary, without your consent, except as required by law.
If we wish to use or disclose your personal information for any new business purpose other than the marketing of services or as set out herein, we will ask for your consent.
How do we safeguard personal information?
We make every reasonable effort to ensure that personal information is secure, accurate, and complete.
We rely on persons who have provided us with information to notify us if there is a change to their personal information that may affect their relationship with the SU. If you are aware of an error in our information about you, please let us know and we will correct it wherever possible. In some cases, we may ask for a written request for correction.
We retain personal information only if it is reasonably necessary to fulfill the purposes for which the information was collected or for legal or business purposes.
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 deleting electronic records. Electronic files are maintained in a secure environment with restricted access. Access to more sensitive files is restricted to employees who require access to them.
SU websites
The SU operates several different websites. All are hosted by third-party web-hosting services. By using one of our websites, you are acknowledging that you consent to your information being used for the purposes and for the manner described in this policy.
Our websites use Google Analytics. This means that when you visit one of our websites, a limited amount of information which may identify you is passively collected, such as your IP address, the type of device, operating system, and browser you use, and your activity on our website. This information is used for statistical purposes only, to collect and count the number of visits to our websites. We do not track or record information about individuals and their visits.
Some of our websites also use the Meta pixel. With its help, we can keep track of what users do after they see or click on a Facebook/Instagram advertisement. This enables us to monitor the effectiveness of Facebook/Instagram ads for purposes of statistics and market research. Data collected in this way is anonymous to us, which means we cannot see the personal data of individual users. However, this data is saved and processed by Meta. Meta can connect this data with your Facebook/Instagram account and use it for its own advertising purposes, in accordance with Meta’s Data Policy.
Our websites are protected, as necessary, by alphanumeric passwords, physical protection, and encryption.
Our websites may contain links to other websites. Although the SU believes the organizations to which links are provided are reputable and have high standards, the SU is neither responsible nor liable for the content, actions, or policies of these websites.
Of importance to note, confidentiality and security may not be assured when information is transmitted through email, internet, or wireless communication. The SU will not be responsible for any loss or damage suffered because of breach of security or confidentiality when you transmit information to us by email or other internet or wireless communication, or when we transmit information by such means.
Access to records containing personal information
Employees and/or customers have the right to access their own personal information in a record that is in our custody or under our control, subject to some exceptions. For example, organizations are required under PIPA to refuse to provide access to information that would reveal personal information about another individual. Organizations are also authorized under PIPA to refuse access to personal information if disclosure would reveal confidential business information, the information is privileged or contained in mediation records, or could reasonably be expected to threaten the life or security of another individual.
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 by writing to:
Branden Cave
Privacy Officer and Director, Legal and Human Resources
The Students’ Union, The University of Calgary
251 MacEwan Student Centre, 2500 University Drive NW
Calgary, Alberta T2N 1N4
Phone: 403-220-3905
Email: bacave@ucalgary.ca
You may also request information about our use of your personal information and any disclosure of that information to persons outside our organization. Any such request must include sufficient information to allow us to identify the information you are seeking.
You may also request a correction of an error or omission in your personal information. We will respond to your request within 45 calendar days, unless an extension is granted.
Questions and complaints
If you have a question or concern about any collection, use, or disclosure of personal information by the SU, or about a request for access to your own personal information, please contact our Privacy Officer at the address above.
If you are not satisfied with the response you receive, you can contact the Information and Privacy Commissioner of Alberta:
Office of the Information and Privacy Commissioner of Alberta
Suite 2460, 801 – 6 Avenue SW
Calgary, Alberta T2P 3W2
Toll Free: 1-888-878-4044
Email: generalinfo@oipc.ab.ca