UCN Privacy Policy

PRIVACY POLICY STATEMENT 


The University College of the North (UCN) is committed to safeguarding the personal information entrusted to us by our students and employees. Personal information will be managed in accordance with Manitoba’s Freedom of Information and Protection of Privacy Act (FIPPA), the Personal Health Information Act (PHIA) and the Personal Information Protection and Electronic Documents Act (PIPEDA). 

Definition: 
“Personal Information” - FIPPA defines “personal information” as “recorded information about an identifiable individual.” Examples of personal information include an individual’s name, home address, home telephone, facsimile or e-mail number, information about an individual’s age, sex, sexual orientation, marital status, family status, ancestry, race, colour, nationality, national origin, ethnic origin, religion or creed, religious belief, religious association or activity, personal health information, blood type, fingerprints, hereditary characteristics, political beliefs, political association or activity, education, employment, educational history, employment history, source of income, financial circumstances, financial activities or history, criminal history and identifying numbers, symbols or other particular assigned to an individual (SIN number, student number, etc.). 

APPLICATION OF POLICY 
This policy applies to UCN employees and to anyone else providing services on behalf of UCN. 

PROCEDURES 

1. Collection of Personal Information 
a) UCN will collect only that personal information on students and employees that is required to fulfill its mandate. 
b) UCN collects information on students through the application and registration process. Personal information will include, but not be limited to, social insurance number, date of birth, contact information (mailing/street address, telephone/cell numbers, email address), educational history, sponsorship details, citizenship, disability, cultural status, etc. Additional personal information may be gathered by student services.
 c) UCN collects information on employees from the application for employment and resume, and through discussion with the individual. Personal information will include, but not be limited to, employment information, social insurance number, date of birth, contact information (mailing/street address, telephone/cell numbers, etc.), dependant information, beneficiary information and marital status. 
d) UCN normally collects personal information directly from students and employees, but may collect personal information from other persons with client consent or as authorized by law. 
e) UCN will inform students and employees, before or at the time of collecting personal information, of the purposes for which the information is collected. The only time this notification would not be provided is when the information has been volunteered for an obvious purpose or prior consent has been provided. 

2. Consent 
a) UCN will ensure consent to collect, use or disclose client personal information is obtained, except in specific circumstances where collection, use or disclosure without consent is authorized by law.
 b) UCN may assume consent in cases where information has been volunteered for an obvious purpose. In cases where personal information was collected before May 1998, UCN assumes consent to use and, where applicable, disclosure for the purpose for which the information was collected. 
c) UCN may not be able to provide certain services if the individual is unwilling to provide express consent to the collection, use or disclosure of certain personal information. 
d) Where express consent is needed, UCN will normally ask students and staff to provide their consent orally (in personal or by telephone), in writing (by signing a consent form or by checking a box on a form), or electronically (by clicking a button). 
e) In cases that do not involve sensitive personal information, UCN may rely on “opt-out” consent. Such requests can be made by checking the appropriate box on the application form, in person, or by telephone. 
f) Consent may be withdrawn at any time, unless the personal information is necessary for UCN to fulfill its legal obligations. UCN will inform the individual if withdrawal of consent affects UCN’s ability to provide services. 
g) UCN may collect, use or disclose personal information without consent only as authorized by law. 
For example, consent is not required when the collection, use or disclosure is reasonable for an investigation or legal proceeding, to collect a debt owed to UCN, in an emergency that threatens life, health or safety, or when the personal information is publicly available (i.e. from a public telephone directory). 

3. Disclosure of Personal Information 
a) UCN uses and discloses personal information only for the purposes for which the information was collected, except as authorized by law. 
b) Should UCN wish to use or disclose personal information for any new purpose, UCN will obtain consent from the individual to disclose the information for that purpose. 

4. Safeguarding Personal Information 
a) UCN will make every reasonable effort to ensure that client information is accurate and complete. UCN relies on students and employees for notification of changes to their personal information that may affect their relationship with UCN. Requests for correction of personal information must be provided in written form. 
b) UCN will protect personal information in a manner appropriate for the sensitivity of the information and will make every reasonable effort to prevent any loss, misuse, disclosure, or modification of personal information, as well as any unauthorized access to personal information. 
c) UCN will use appropriate security measures when destroying client personal information, including shredding paper records and permanently deleting electronic records. 
d) UCN will retain personal information only as long as is reasonable to fulfill the purposes for which the information was collected or for legal or business purposes. 

5. Access 
a) Students and employees have the right, subject to some exceptions, to access their own personal information in a record that is in UCN’s custody or under UCN’s control. 
b) Under FIPPA, organizations are required to refuse access to information that would reveal personal information about another individual. 
c) Organizations are authorized under the Act to refuse access to personal information if disclosure would reveal confidential business information. 
d) If access is refused in whole or in part, UCN will provide the reasons for the refusal. In some cases where exceptions to access apply, UCN may withhold that information and provide the remainder of the record. 
e) Students and employees of UCN may request access to personal information by writing to the FIPPA Coordinator for UCN (see Contact Information) and providing sufficient information to allow accurate identification of the requested information. 
f) Students and employees of UCN may request information about the use of personal information managed by UCN and any disclosure of that information to persons outside the organization. 
g) Students and employees of UCN may request in writing the correction of an error or omission in their personal information. UCN will respond to the request within 45 calendar days, unless an extension is granted.

 6. Enforcement 
UCN deans and divisional managers are responsible for the development, communication, and enforcement of procedures to be followed on the collection and use of personal information within their areas. 

7. Responsibility for Privacy at UCN 
Responsibility for the collection, safeguarding, communication and disclosure of personal information at UCN is assigned as follows: 
Student personal information – Director of Enrolment Services and Registrar Employee personal information – Director of Human Resources 

CONTACT INFORMATION 
Questions and complaints regarding the collection, use, or disclosure of personal information by UCN, and requests for access to personal information should be sent to: 

Access and Privacy Coordinator 
University College of the North 
7 th and Charlebois 
P.O. Box 3000 
The Pas, MB R9A 1M7 
Telephone: (204) 627-8500 
Toll free: 1-800-627-8500 
Website: www.ucn.ca 

If the student or employee is not satisfied with the response received or the actions taken, they may contact the: 
Information and Privacy Commissioner of Manitoba 
750 – 500 Portage Avenue 
Winnipeg, MB R3C 3X1 
Telephone: (204) 982-9130 
Toll free: 1-800-665-0531
 Fax: (204) 942-7803 
Website: http://www.ombudsman.mb.ca/access.htm