KYOKO MANABE, THE “NOTARY”
1. INTROUDCTION
The Personal Information Protection Act (“PIPA”) regulates the way organizations in British Columbia use, keep, secure, disclose and collect personal information. “Personal Information” means all information about an identifiable individual and includes paper and electronic information. THE NOTARY recognizes the importance of privacy and recognizes the sensitivity of Personal Information received in the course of THE NOTARY’S practice. THE NOTARY recognizes her professional obligation to maintain the confidentiality of her clients’ information, and recognize her obligations concerning the Personal Information of all individuals that THE NOTARY collects, uses or discloses in her practice. This policy has been developed with those obligations in mind.
2. DEFINITION OF PERSONAL INFORMATION
personal information is defined as any information, recorded or not, that is about an identifiable individual. Anonymous or aggregate information is not considered personal information and does not fall under the scope of this Policy. Personal information can be objective information such as your e-mail address or your country of residence, or it can be subjective information such whether you have plans to purchase or sell real estate or whether you need a will. The following is a list of the most common types of personal information which the NOTARY collects, uses, discloses and retains from the Web Sites:
- name;
- Internet Protocol (IP) address;
- mailing and e-mail addresses;
- other contact information such as telephone and fax numbers;
- web browser type;
- operating system;
- language preference if the user selects this option;
- opinions and suggestions;
- pages visited (on a single site or across sites);
- length of time spent on THE NOTARY’s pages; and
- business title and contact information.
All personal information that THE NOTARY collects, uses, and discloses under this Policy is protected as confidential information.
3. COOKIES
THE NOTARY uses “cookies” to enhance the convenience and use of its websites. A cookie (also known as an HTTP cookie, web cookie, or browser cookie) is a small piece of data sent from a website and stored in a user’s web browser while the user is browsing. Cookies are designed to recall information about past browsing activity and to allow a Web Site to recognize future visits. Cookies, among other things, allow us to recognize you as a previous user of our Web Sites (so you do not have to enter information about yourself every time). They also allow THE NOTARY to offer personalized web content, thus facilitating your overall website experience. Cookies may also be shared with THE NOTARY partners and third party advertising vendors to allow for internet-based advertising and content personalization consistent with the Purposes set out above. Cookies placed on user browsers do not contain any Personal Information. In addition to our use of cookies, THE NOTARY may use Google Analytics and other web tools to analyze traffic and other data related to our Web Sites. THE NOTARY uses these tools to understand what features visitors to our Web Sites like best and what best encourages engagement and interaction. Through cookies, we only collect aggregated, anonymous data. Information collected through cookies and produced through analytical data does not contain personal identifying information. Cookies used by THE NOTARY cannot capture or access files and data stored on your computer. Browsers may allow you to disable the use of cookies through the use of your browser’s ‘ad settings’ (generally in the ‘privacy’ or ‘security’ settings), for mobile apps and/or other available means (please see section 2 d. above). Doing so may, however, affect your use of our Web Sites and/or your ability to access certain features of these sites. Should you wish to prevent your data from being used by Google Analytics, this link provides instructions on how to opt-out: www.google.com/settings/u/0/ads . To opt-out of Display Advertising you should go to: https://www.google.com/settings/ads/onweb Advertisements displayed on our Web Sites may also contain cookies. These advertisements may be provided by third party advertising companies. We do not have any control over the cookies used in those advertisements, and bear no responsibility or liability for the use and/or disclosure of information collected by third parties through advertisement cookies. We will not, however, knowingly permit advertising companies to use or disclose information collected through the Web Sites for illegal or other improper purposes.
4. RELEASE OF INFORMATION
The Act permits individuals to submit written requests to THE NOTARY to provide them with:
- their Personal Information in her custody or control;
- information about how the NOTARY uses their Personal Information under her control;
- the names of the individuals and organizations to whom THE NOTARY has disclosed their Personal Information under her control.
THE NOTARY will respond to requests in the time allowed by the Act and as authorized by you pursuant to various documents in her file. THE NOTARY will make a reasonable effort to assist applicants and to respond as accurately and completely as reasonably possible. All requests may be subject to any fees and disbursements the law permits THE NOTARY to charge. An individual does not have an absolute ability to access his or her Personal Information under my control. The Act provides that THE NOTARY must not disclose Personal Information when:
- disclosure could reasonably be expected to threaten the safety or physical or mental health of someone else;
- disclosure can reasonably be expected to cause the person who made the request immediate or grave harm as to their safety or physical or mental health;
- disclosure would reveal Personal Information about someone else;
- disclosure would reveal the identity of an individual who has provided Personal Information about someone else and the person providing the Personal Information does not consent to disclosure of his or her identity.
The Act further provides that THE NOTARY is not required to disclose Personal Information when:
- the Personal Information is protected to the extent allowed by notary/client privilege;
- disclosure of the Personal Information would reveal confidential commercial information that, if disclosed, could in the opinion of a reasonable person, harm the competitive position of an organization;
- the Personal Information was collected or created by a mediator or arbitrator in the conduct of a mediation or arbitration for which he or she was appointed to act:
(i) under a collective agreement,
(ii) under an enactment, or
(iii) by a court.
5. SECURITY SAFEGUARDS
THE NOTARY recognizes her professional and legal obligation to protect the confidential information of her clients and other individuals she collected within her practice. THE NOTARY will protect your personal information against loss or theft, as well as from unauthorized access, collection, disclosure, copying, use, disposal, destruction or modification. Personal information under the control of THE NOTARY will be protected regardless of the format in which it is held.
THE NOTARY will use appropriate security safeguards to provide necessary protection such as:
- Physical measures (locked filing cabinets, restricting access to offices, alarm systems);
- Technological tools (passwords, encryption, firewalls); and
- Organizational controls (security clearances, limiting access on a “need-to-know” basis, staff training, and confidentiality agreements.
6. OPENNESS
This Policy may be changed from time to time. Our latest Policy will be posted on our website. It is also available by contacting the NOTARY. When visiting our Web Sites, you are encouraged to review any changes since the last version you may have read. You could also bookmark this Policy and periodically review it to ensure that you are familiar with its terms.
7. CHALLENGES AND CONCERNS
If you have any questions about my handling of your Personal Information or if you want access to it or to request a correction of your Personal Information that is under my care and control, please contact THE NOTARY at:
Suite 500 – 171 West Esplanade, North Vancouver, BC V7M 3J9 Phone: 604 454 8222
All individuals have the right to contact the relevant privacy authority in their own jurisdiction. In BC, you may wish to contact the Office of the Information and Privacy Commissioner at:
P.O. Box 9038, Stn Prov Govt Victoria, BC V8W 9A4
Telephone (250) 387-5629
Fax (250) 387-1696