Personal Information Protection Policy

College of Core Belief Engineering, a division of Core Belief Engineering Ltd.

At Core Belief Engineering Ltd., we are committed to providing our clients and students with exceptional service. As providing this service involves the collection, use and disclosure of personal information about our clients and students, protecting their personal information is one of our highest priorities.

While we have always respected our clients’ and students’ privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (P.I.P.A.) which came into effect on January 1, 2004. This Act sets out the ground rules for how BC businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our students, clients, Practitioners, Master Practitioners, Evaluators, Instructors and staff of why and how we collect, use and disclose their personal information, obtain their consent where required and handle their personal information in a way that is appropriate to the circumstances.

This Personal Information Protection Policy, in compliance with the P.I.P.A, outlines the principles and practices we follow in protecting the personal information of clients, students and staff. Our privacy commitment includes ensuring the accuracy, confidentiality and security of our students’, clients’, Intern Practitioners’, Associate Practitioners’, Certified Practitioners’, Master Practitioners’, Evaluators’, Instructors’ and staffs’ personal information and allowing our students, clients, Intern Practitioners, Associate Practitioners, Certified Practitioners, Master Practitioners, Evaluators, Instructors and staff to request access to and correction of their personal information.

This Personal Information Protection Policy applies to the College of Core Belief Engineering, its licensee in Québec, Richard Thibodeau of Institut Unescorps Inc., all students, clients, Intern Practitioners, Associate Practitioners, Certified Practitioners, Master Practitioners, Evaluators, Instructors and staff. Our Basic and Practitioner Intensive students are bound by the conditions set out in the Student Enrollment Contract that they sign at the beginning of each course.

We collect information in the following areas:
Name, date of birth, mailing address, telephone numbers (business, home, cell), e-mail address, education, employment background, Social Insurance Numbers and information relating to mental and physical health which is limited to that which would impact employment, course participation and/or their ability to benefit from CBE processes.

Optional information sought:
Religious orientation, marital status and the number and gender of any children

Records kept:
Student transcripts, evaluations, personal process information and course worksheets, course payments received and owed, course and staff evaluations

Contact Information:
We define contact information as information that would enable an individual to be contacted at their preferred location. This includes name, telephone number and/or email address, and mailing address.

Privacy Officers:
President of Core Belief Engineering Ltd. and College Registrar

Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting personal information are obvious and the student, employee or client voluntarily provides his or her personal information for those purposes, we will communicate the purpose for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2 We will only collect student, staff or client information that is necessary to fulfill the following purposes:

• To verify identity we may collect name, date of birth, mailing address and telephone numbers.
• To identify that a student meets the admission requirements of the CCBE we ask for name, mailing address and telephone numbers, date of birth and a copy of the student’s High School Diploma.
• To assess suitability for processing or program admission we use the information gathered during a telephone or personal interview.
• To enroll the student in a CCBE Program we collect all of the above information, two pieces of identification (one with a current photograph) and the student’s Social Insurance Number.
• To understand the processing needs of students and clients we use the information gathered during a personal interview.
• To contact our students and clients for follow-up we may collect name, telephone numbers and/or email addresses and mailing address.
• To contact clients and students for feedback we may collect name, telephone numbers and/or email addresses and mailing address.
• To send out CBE course information we may collect name, telephone numbers and/or email addresses and mailing address.
• To provide educational services we collect information specified by B.C. law, accreditation requirements and that which is outlined in the CCBE admissions requirements.
• To provide CBE processing services we collect only the information pertinent to the client’s situation and desired change(s).
• To deliver other requested services we gather information related only to the service asked for.
• To verify credit worthiness we conduct a credit check where deemed necessary.
• To collect and process payment (for courses and/or private work) we accept cash, cheques and/or credit cards.
• To meet regulatory requirements we meet the standards set by the BC Personal Information Protection Act and the PCTIA.

Policy 2 – Consent

2.1 We will obtain students’, clients’, Intern Practitioners’, Associate Practitioners’, Certified Practitioners’, Master Practitioners’, Evaluators’, Instructors’ and staffs members’ consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2 Consent can be provided orally, in writing or electronically or it can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the students, clients, Intern Practitioners, Associate Practitioners, Certified Practitioners, Master Practitioners, Evaluators, Instructors and staff member voluntarily provides personal information for that purpose.

2.3 Consent may be implied where students, clients, Intern Practitioners, Associate Practitioners, Certified Practitioners, Master Practitioners, Evaluators, Instructors and staff members are given a reasonable opportunity to opt-out of their personal information being used for mail outs, marketing of new courses and Introductory Session information, yet they have not specifically requested to opt-out.

2.4 Subject to certain exceptions, students, clients, Intern Practitioners, Associate Practitioners, Certified Practitioners, Master Practitioners, Evaluators, Instructors and staff members can withhold or withdraw their consent from the College of Core Belief Engineering to use their personal information in certain ways. A student’s, client’s, Intern Practitioner’s, Associate Practitioner’s, Certified Practitioner’s, Master Practitioner’s, Evaluator’s, Instructor’s and staff member’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the student, client, Intern Practitioner, Associate Practitioner, Certified Practitioner, Master Practitioner, Evaluator, Instructor and staff member in making the decision.

Exceptions:
When the withdrawal of consent frustrates the performance of a legal obligation, the completion of the student’s education as agreed to upon acceptance into the College or the provision of complete and safe processing.

2.5 We may collect, use or disclose personal information without the student’s, client’s, Intern Practitioner’s, Associate Practitioner’s, Certified Practitioner’s, Master Practitioner’s, Evaluator’s, Instructor’s and staff member’s knowledge or consent in the following limited circumstances:

• When the information is available from a public source
• When the collection, use or disclosure of personal information is required and permitted by law
• In an emergency that threatens an individual’s life, health or personal security
• To investigate the contravention of law or breach of contract
• When the College requires legal advice from a lawyer (the information would then be restricted to the minimum to obtain accurate advice)
• For collecting debt
• To protect the company from fraud

Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose the student’s, client’s, Intern Practitioner’s, Associate Practitioner’s, Certified Practitioner’s, Master Practitioner’s, Evaluator’s, Instructor’s and staff member’s personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:

• To conduct the surveys in order to enhance the provision of our services;
• To contact the students, clients, Intern Practitioners, Associate Practitioners, Certified Practitioners, Master Practitioners, Evaluators, Instructors and staff members directly about programs, courses, introductory evenings and CBE updates.

3.2 We will not use or disclose the student’s, client’s, Intern Practitioner’s, Associate Practitioner’s, Certified Practitioner’s, Master Practitioner’s, Evaluator’s, Instructor’s or staff member’s personal information for any additional purpose unless we obtain consent to do so.

3.3 We will not sell students’, clients’, Intern Practitioners’, Associate Practitioners’, Certified Practitioners’, Master Practitioners’, Evaluators’, Instructors’ and staffs’ member personal information to other parties.

Policy 4 – Retaining Personal Information

4.1 All student transcripts and educational records will be kept electronically for fifty-five (55) years.

4.2 If we use the student’s, client’s, Intern Practitioner’s, Associate Practitioner’s, Certified Practitioner’s, Master Practitioner’s, Evaluator’s, Instructor’s and staff member’s information to make a decision that directly affects the student, client, Intern Practitioner, Associate Practitioner, Certified Practitioner, Master Practitioner, Evaluator, Instructor or staff member, we will inform them of the decision in writing and that we will retain that personal information for at least one year so that the student, client, Intern Practitioner, Associate Practitioner, Certified Practitioner, Master Practitioner, Evaluator, Instructor or staff member has a reasonable opportunity to request access to it.

4.3 Subject to policy 4.2, we will retain the student’s, client’s, Intern Practitioner’s, Associate Practitioner’s, Certified Practitioner’s, Master Practitioner’s, Evaluator’s, Instructor’s and staff member’s personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 – Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that the student’s, client’s, Intern Practitioner’s, Associate Practitioner’s, Certified Practitioner’s, Master Practitioner’s, Evaluator’s, Instructor’s and staff member’s information is accurate and complete where it may be used to make a decision about the student, client, Intern Practitioner, Associate Practitioner, Certified Practitioner, Master Practitioner, Evaluator, Instructor and staff member.

5.2 The student, client, Intern Practitioner, Associate Practitioner, Certified Practitioner, Master Practitioner, Evaluator, Instructor and staff member may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information should be forwarded to the Privacy Officer, must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.

5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required. If the correction is not made, we will note the student’s, client’s, Intern Practitioner’s, Associate Practitioner’s, Certified Practitioner’s, Master Practitioner’s, Evaluator’s, Instructor’s or staff member’s correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of the student’s, client’s, Intern Practitioner’s, Associate Practitioner’s, Certified Practitioner’s, Master Practitioner’s, Evaluator’s, Instructor’s and staff member’s personal information in order to protect it from unauthorized access, copying, modification, disclosure, collection, use, disposal or similar risks.

6.2 The following security measures will be followed to ensure that the student’s, client’s, Intern Practitioner’s, Associate Practitioner’s, Certified Practitioner’s, Master Practitioner’s, Evaluator’s, Instructor’s and staff member’s personal information is appropriately protected:

• All staff members sign a Confidentiality Agreement.
• All databases have a firewall and need a restricted password to access stored information.
• Backups are compressed and stored on an external hard drive.
• Filing cabinets containing personal information are locked.
• Access to personal information is restricted as appropriate.
• All entrances to the facility are locked and checked after business hours.

6.3 We will use appropriate security measures when destroying the student’s, client’s, Intern Practitioner’s, Associate Practitioner’s, Certified Practitioner’s, Master Practitioner’s, Evaluator’s, Instructor’s and staff member’s personal information. All documents are shredded and all electronically stored information is permanently deleted.

6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Policy 7 – Providing the students, clients, Intern Practitioners, Associate Practitioners, Certified Practitioners, Master Practitioners, Evaluators, Instructors and staff Access to Personal Information

7.1 All students, clients, Intern Practitioners, Associate Practitioners, Certified Practitioners, Master Practitioners, Evaluators, Instructors and staff have a right to access their personal information, subject to the following exceptions:

• The disclosure can reasonably be expected to cause immediate or grave harm to the physical or mental health or safety of the individual who made the request;
• Such disclosure could reasonably be expected to threaten the physical or mental health or safety of an individual other than the individual who made the request;
• The disclosure would reveal personal information about another individual;
• The disclosure would reveal the identity of an individual who has provided personal information about another individual and the individual providing the personal information does not consent to disclosure of his or her identity.

7.2 A request to access personal information must be made in writing, forwarded to the Privacy Officer and provide sufficient detail to identify the personal information being sought and the reason for which it is being sought.

7.3 Upon request, we will also tell the students, clients, Intern Practitioners, Associate Practitioners, Certified Practitioners, Master Practitioners, Evaluators, Instructors and staff members how we use their personal information and if applicable, to whom it has been disclosed.

7.4 We will make the requested information available within thirty (30) business days or provide written notice of an extension where additional time is required to fulfill the request.

7.5 If a request is refused in full or in part, we will notify the student, client, Intern Practitioner, Associate Practitioner, Certified Practitioner, Master Practitioner, Evaluator, Instructor and staff member in writing, providing the reasons for refusal and the recourse available to the student, client, Intern Practitioner, Associate Practitioner, Certified Practitioner, Master Practitioner, Evaluator, Instructor and staff member.

Policy 8 – Questions and Complaints: The Role of the Privacy Officer

8.1 The designated Privacy Officer is responsible for ensuring that the College of Core Belief Engineering is in compliance with this policy and the Personal Information Protection Act.

8.2 Students, clients, Intern Practitioners, Associate Practitioners, Certified Practitioners, Master Practitioners, Evaluators, Instructors and staff members should direct any complaints, concerns or questions regarding the College of Core Belief Engineering’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the student, client, Intern Practitioner, Associate Practitioner, Certified Practitioner, Master Practitioner, Evaluator, Instructor and staff member may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for the Privacy Officers:

Ms. Elly Roselle Privacy Officer CCBE 15459 Semiahmoo Avenue White Rock, BC V4B 1T7 ccbe@shaw.ca

Mrs. Christine Bowie Privacy Officer CCBE 15459 Semiahmoo Avenue White Rock, BC V4B 1T7 c.marchi@shaw.ca

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