This Statement describes the privacy and confidentiality practices and commitments of the operation of the I Boost Immunity website (the “Site”), which is operated and maintained by the Public Health Association of British Columbia (“PHABC”). For more information on PHABC, please visit the PHABC website.
The purpose of the Site is to promote the uptake of immunization through a health promotion and resource Booster program for the public and healthcare professionals. The Site provides opportunities to learn more about immunization, share information and stories, inform others about the program and earn vaccines.
We periodically review our Privacy Statement and update it as necessary. You agree to review our Privacy Statement from time to time and agree that any use by you of this website after changes shall constitute your acceptance of all such changes.
PHABC is subject to the requirements of BC’s Personal Information Protection Act (PIPA), which regulates the information and privacy practices of corporations, not-for-profits, trade unions, credit unions and other private sector organizations in BC, including their collection, use, disclosure, storage and disposal of “personal information”. (Personal Information is defined in PIPA as information about an identifiable individual, which means a person can be identified by the information, either directly e.g. name, image, job title, or in combination with other information.) PHABC is committed to maintaining the confidentiality and privacy of the personal information that you provide on the Site in a manner that complies with PIPA and the 10 principles for protection of privacy.
From time to time, PHABC engages employees, representatives, agents or contractors to perform additional work on the Site, such as maintenance or upgrades. Access to information about our boosters is never granted unless it is required to do the work, and in those cases, only the minimal amount of information is made available. Any service providers or individuals who provide such work on the Site are required to provide written privacy protection and confidentiality undertakings, and owe legal obligations to maintain the privacy of all personal information.
If you have any complaints, questions or concerns about this Statement or require any further information about the privacy practices of PHABC in connection with the Site, please contact our Privacy Officer at firstname.lastname@example.org.
2. Identifying Purpose
The following information is collected for each of the services identified:
• Creating an Account: You will need to provide your email address, a username and a password to create an account and post comments, ask questions, share your stories, accumulate vaccines, and for future login. Because your username will display when you post a comment on the Leaderboard, we strongly discourage the use of your real name or other potentially identifying information in your username. The email address on your account will be used for delivering I Boost Immunity newsletters, if you select this option. You may opt out of receiving newsletters at any time.
• Completing your Profile: Your profile picture or avatar will appear with your username when you are active on the Site and help identify you to other boosters. You can create a password to enable login to the Site with your Facebook account instead of a password. You can also authenticate your Twitter account. PHABC does not access any information in your Facebook or Twitter accounts when you choose this option unless you have expressly permitted us to do so.
• Share-a-Story: To submit a story about why you support immunization, you will need to complete the mandatory fields and your email address . Your story submission may be in audio, video, image or text format. You will be asked to check a box consenting to the use of your submission (Consent and Acknowledgement) prior to submitting your story. All stories are moderated before posting to the public forum.
• Contact Us Form: If you have questions, comments or complaints about the Site, you can send them anonymously to us using the form on the Contact Us page. If you want to receive a response to your question or comment, you will need to provide your email address.
• User Surveys: From time to time, PHABC will post user surveys on the Site. These surveys are for evaluation purposes only, to help us understand how we can improve the Site and services. If you respond to a survey, the information that you provide will only be used for analysis and reporting, and will be anonymous. It will not be linked to you and cannot be used to identify you.
The Site uses temporary cookies (also known as “session cookies”), which means that the information collected is temporary in nature and is deleted as soon as you close your browser. If you have signed up for an account on the Site, you will be required to login every time. In order to protect your account from unauthorized access, your session will timeout after a reasonable period of inactivity, for example 15 minutes.
We will inform you before or at the time of collection as to why the personal information is needed and how it will be used. Your express consent is required before we collect personal information. If we would like to use your personal information for a new purpose that has not been previously identified, we will inform you of the new purpose and obtain your consent prior to its use.
You are free to withdraw consent for use of your personal information at any time by deleting your account or by contacting our Privacy Officer at email@example.com. Please note that withdrawing consent or deleting your account will limit your ability to use the Site.
4. Limiting Collection
The collection of any personal information you provide is permitted in accordance with Part 4 of PIPA, which allows PHABC to collect personal information that fulfills the purpose(s) that are disclosed and are otherwise permitted under PIPA. PHABC is collecting personal information from you for the purpose of providing the services you are requesting on the Site. We make every effort to avoid any unnecessary collection of personal information. Some of our services, such as the Share-a-Story feature, may require you to provide contact information in case the moderator needs to contact you. Personal information will only be used for the specific purpose for which it was collected or for other purposes consistent with the collection.
5. Limiting Use, Disclosure and Retention
Content that you submit to the Site (except for your account information) will be retained indefinitely to maintain the continuity of the information on the Site, and to evaluate the use and value of the Site. This includes the following information:
• Any comments or questions that you submit using the Contact Us page.
• Any stories submitted to the Share-a-Story feature.
• Any blogs, articles or other reference material.
When you are logged into our account, you can delete any comments that you have added to the Site. Deleted comments will no longer display on the Site but will be retained for a year as required under PIPA.
You can make changes to your account information or delete your account at any time. Please contact us if you require assistance correcting any personal information associated with your account.
The privacy and security of your personal information is of great importance to PHABC. We do provide reasonable safeguards by taking the measures below.
• We require email addresses and passwords from boosters to protect the Site from fraudulent use (e.g., spam) and misuse.
• We limit the number of PHABC employees, representatives, agents and contractors who can access the personal information you provide on the Site (e.g., email address and username).
Only those with a need to know have access to this information.
• All PHABC employees, representatives, agents and contractors owe legal obligations to maintain the privacy of all personal information and comply with PIA privacy and confidentiality requirements.
• We use many methods (e.g., encryption, firewalls, restricted access to data, etc.) to protect your information against unauthorized access, collection, use, disclosure or disposal.
• A PHABC moderator will review and remove any personally identifying information before the following are posted on the Site:
o Stories submitted via the Share-a-Story feature;
o Other comments posted on the Site.
• Information used for statistical, reporting, Site evaluation and Site improvement purposes is anonymized and not linked with information that could be used to identify you.
We do not communicate with you by email except when we have your explicit permission to do so, or example to respond to a question that you have asked or to contact you with a question about your shared story before it is posted publically.
The Internet is not a fully secured method for communicating. Information that is submitted over the Internet, including through a website or email, is subject to interception or incorrect routing. This means that if you send a message using the Contact Us page or another email address published on the Site, the information provided may be intercepted. Please consider this before submitting any information to the Site.
PHABC is not responsible for any damages suffered by individuals as a result of the email transmission of information that is sent to or from the Site. PHABC is not responsible for any errors or changes made to information that is transmitted by email.
For more information on our personal information policies and practices, to access your personal information, or to make a complaint about our personal information practices, please contact the PHABC Privacy Officer at firstname.lastname@example.org.
9. Individual Access
Upon request, PHABC will provide you with access to your personal information, an explanation of how it has been used and a list of individuals or organizations to whom your personal information has been disclosed, if any. This information will be provided within 30 business days at minimal or no cost.
If we have reason to refuse the requested information, PHABC will provide you with the reasons and the provision of the Act on which the refusal is based, a contact who can answer questions about the refusal, and information on how to request a review by the BC Information and Privacy Commissioner.
10. Challenging Compliance
PHABC has a process in place for receiving and responding to complaints and inquiries about personal information practices and will investigate all complaints. Where a complaint is justified, PHABC will take appropriate measures to rectify the situation including correcting information handling practices and policies where necessary.
Tips For Protecting Your Privacy
• For the protection of your privacy and the privacy of others, we strongly discourage you from including any personal information about yourself or others in any content that you post to the Site.
• Your email address and password are required to access your I Boost Immunity account. Do not share your password with anyone.
• The information that you post on the Site in the form of questions or comments is publically available to everyone using the Internet. Do not post anything that you want to keep private.
• When posting content to the Site (e.g., questions, comments), do not include your name or someone else’s name or any other information that can be used to identify you or someone else.
• Clear your browser history and cache after each use of the Site or use our browser’s anonymous browsing mode.
• If you are concerned about your privacy when submitting your email address, use an email account with a name that is not linked to your real name or other information that can identify you.
Copyright© 2016. Public Health Association of British Columbia. All Rights Reserved.
Last Updated March 1, 2016