Respect for your privacy + the confidentiality of your personal information is a fundamental value of the Royal Winnipeg Ballet.
This Privacy Code informs you of RWB’s commitment to and policy on privacy. It tells you about the ways we ensure that your privacy and the confidentiality of your information are protected.
RWB’s Commitment to Privacy
The objective of RWB’s Privacy Code is to promote responsible and transparent personal information management practices in a manner consistent with the provisions of the Personal Information Protection and Electronic Documents Act (Canada) and other applicable privacy legislation. The RWB will conduct periodic reviews of this Privacy Code to make sure that it remains current with changing standards, technologies and laws.
RWB’s Privacy Code
RWB’s Privacy Code only applies to identifiable individuals whose personal information RWB collects, uses, retains and discloses in the course of commercial activities. When we use the words “personal information” or “information” in this Privacy Code, we mean information about an identifiable individual, with the exception of the name, title or business address or telephone number of an employee of an organization. Further, these terms do not include information that does not identify particular individuals, like aggregate statistics or anonymous data. RWB’s Privacy Code consists of these key principles, which apply to all aspects of handling an individual’s personal information, including collection, use, retention and disclosure:
Compliance With Legal and Industry Standards
We will make every reasonable effort to comply with industry standards and applicable federal and provincial laws in Canada, including the Personal Information Protection and Electronic Documents Act.
Purposes for the Collection, Use, Retention and Disclosure of Information About You
Our purposes for collecting, using, retaining and disclosing your personal information depends upon your relationship with RWB.
The following outlines our purposes if you are a subscriber, donor or student:
With Respect to our Subscribers:
- to establish and serve you as our customer
- to process your payment with a financial institution (such as your credit card company, your bank or our bank);
- to issue tickets and receipts or other documentation that may be reasonably required; to provide you with information and invite you to attend future performances;
- to provide you with information and invite you to contribute or participate in campaigns and fundraising events and programs, which campaigns, events and programs may be operated by RWB or an unrelated third party; to maintain adequate accounting and tax records, to assess the quality and quantity of our performances and services and to have information in such form as we may reasonably require for our business needs; to meet any legal, governmental or regulatory requirements, to detect and prevent fraud, and to protect the interests of you and RWB.
With Respect to our Donors:
- to establish you as a donor or a participant in a fundraising event, such as a lottery or a draw; to process your contribution or payment with a financial institution (such as your credit card company, your bank or our bank);
- to issue income tax receipts, tickets or other documentation that may be reasonably required; to inform you about the progress of campaigns, the results of fundraising events or the use made of contributions or payments;
- to provide you with information and invite you to contribute or participate in future campaigns and fundraising, programs and events, which campaigns, programs and events may be operated by RWB or an unrelated third party;
- to maintain adequate accounting and tax records, to assess the quality and quantity of our campaigns and fundraising events and to have information in such form as we may reasonably require for our business needs;
- to meet any legal, governmental or regulatory requirements, to detect and prevent fraud, and to protect the interests of you and RWB.
With Respect to our Students:
- to establish and serve you as our student;
- to administer billing and process payments with a financial institution;
- to enable us to contact and liaison with your parents, teachers, schools, physicians, health care providers, and other necessary third parties to assess your abilities and needs and to provide you with appropriate programs, services and care;
- to maintain adequate accounting and tax records;
- to assess the quality and quantity of our services and to have information in such form as we may reasonably require for our business needs;
- to meet any legal, governmental or regulatory requirements, to detect and prevent fraud, and to protect the interests of you and RWB.
Giving You Control Over How We Handle Information About You
We collect, use, retain and disclose information about you only with your consent, except as outlined in this Privacy Code. In obtaining your consent, whether express or implied, our purposes for which we require your information are as outlined herein if you are a subscriber, donor or student or will be identified at or before the time of collection. We may depart from the consent principle only in accordance with the limited exceptions described in this Privacy Code, when permitted by other written and posted policies established by the RWB or where permitted by applicable laws (for instance, we may disclose personal information in an emergency to protect human life or safety).
Limiting Disclosure to Third Parties
We may provide your information to other persons only:
- when we have your consent, whether express or implied; or
- when we need to disclose the information to protect our interests in the context of an existing or potential legal or administrative proceeding; or when we are required or permitted by law or regulation to do so; or
- to agents or third parties who assist us or you and whom we can reasonably trust to respect your privacy.
Safely Storing Information About You
We will protect your information with appropriate safeguards and security measures. We will retain your information only for the time that it is reasonably required.
Providing You with the Right to Access and Update Information About Yourself
We will give you access to the information we retain about you and will make every reasonable effort to keep your information accurate and up-to-date.
Responding to Your Privacy Concerns
Any refusal or withdrawal of your consent to the collection, use or disclosure of your information by us is subject to legal and/or contractual restriction and reasonable notice. We will investigate and respond to your concerns about any aspect of our handling of your information. We have appointed a privacy officer who will oversee compliance on our part and ensure that your concerns are addressed appropriately by the RWB.
In this Privacy Code, we will explain how we fulfill each of these important principles and will provide examples for your better understanding.
Why We Ask For Your Information
We ask for information from you for the purposes of our business relationship. At RWB, we gather and use personal information about you in connection with your business relationship with us. We obtain most of our information about you directly from you. The type and extent of information we ask for depends on the nature of our business relationship. For every subscriber and donor, we need your contact information and your payment information.
For every student, we require your contact information, your birth date, your program selection and your payment information. Your birth date is required to ensure your suitability and eligibility for certain programs and is used to celebrate this occasion. Depending on your program selection, we may also require other information, such as your social insurance/security number, certain medical information and your parent/guardian information. Here is why we need some of this information:
- Social Insurance/Security Number - This is needed to comply with immigration requirements.
- Medical Information - This is required for our health and safety requirements.
- Parent/Guardian Information - This is needed for all students under legal age and is also used for contact information.
We only collect the information needed and only use it for the purposes explained to you. When we contact you, we will indicate how we intend to use the information we collect from you if our purposes differ from that outlined in this Privacy Code. If we wish in the future to use the information collected for purposes not previously identified, we will ask you for your consent at that time. We will only ask for the information necessary for the purposes we identified. If applicable, we will advise which information is optional for you to provide.
When We Disclose Your Information
RWB will not disclose information about you to third parties, except in the following limited circumstances:
- where we have your consent, whether express or implied; to agents and third parties who assist us; when we are required or permitted by law to do so;
- when we wish or are required to disclose to fulfill a public duty, such as preventing fraud;
- when we are protecting or advancing our interests in the context of dealings with regulators or industry bodies, administrative tribunals or courts;
- under an exception to the requirement for consent expressly set out in applicable laws, such as exception for disclosures necessary to protect human life or safety in an emergency.
In all such cases, RWB will only make disclosure to the extent that is necessary to accomplish its purposes or discharge its regulatory, legal or public duty. Whenever possible, RWB will also require that the party receiving the information provides reasonable assurances that it will respect the privacy of your information in accordance with applicable laws.
The following list provides some examples of situations in which we disclose your personal information:
RWB discloses personal information regarding its subscribers and donors to credit card companies and banks in order to process payments and donations. In certain circumstances, RWB discloses personal information regarding a student’s prior injuries to a health care professional on contract with RWB to ensure that the health and safety of the student and other students are not compromised. RWB discloses personal information regarding RWB discloses personal information regarding any students contracted to perform with the company where such information is required by Canadian Actors Equity Association. RWB must give information in response to a valid demand, search warrant or other legally valid enquiry or order. We may disclose information to the authorities to serve a clear public interest and fulfill our public duty - such as to protect against fraud or other criminal activity. We may also take action to protect our interests, which may result in disclosing information to parties outside the RWB (for example, our lawyers).
How We Protect Your Information
We will protect your information with appropriate safeguards and security measures. We have reasonable security standards to protect our systems and your information against unauthorized access and use. All safety and security measures employed by RWB are appropriate to the sensitivity level of your information. Electronic files are kept in a secured environment with restricted access. Paper-based files are stored in locked filing cabinets. Access is also highly restricted. In terms of online security, we appropriately manage our server environment and firewall infrastructure. Our security practices are reviewed on a periodic basis to ensure that the confidentiality and privacy of your information is protected. When we disclose information to a third party for a purpose that is permitted under this policy, we shall disclose no more than is necessary to accomplish the purpose, and whenever possible, obtain reasonable assurances that the third party will respect your privacy in accordance with applicable laws. When we provide information in response to a legal enquiry or order, we ensure that the order is valid and we disclose only the information that is legally required. We retain your information only as long as it is reasonably required. Our retention period depends upon the information in question and your relationship with us. For example, if as a subscriber or donor you have provided your credit card information, your credit card information is kept only for so long as required to process your payment. If you are a student who transfers to our professional division, your student information is transferred and maintained by our professional division for so long as your relationship with us. The retention period may extend beyond the end of your relationship with us but only for so long as required by law or as is reasonably required by us. When your information is no longer needed by RWB, we have procedures to destroy, delete, erase or convert it to an anonymous form.
Your Right To Access Your Information
We will give you access to the information we have about you. It is important that your personal information is accurate and complete. Please contact our Privacy Officer if you wish to have access to any information we may have about you. We will advise you in advance if a minimal charge is required for us to conduct a search of our records for information about you, and will respond to your request within 30 days. Please note that we may not be able to provide information about you from our records if it contains references to other persons, is subject to legal privilege, contains information proprietary to RWB, is too costly to retrieve or cannot be disclosed for other legal reasons.
Keeping Your Information Accurate
We will make reasonable efforts, to keep your information accurate and up-to-date. If you find any errors in our information about you, let us know and we will make the appropriate corrections and make sure they are conveyed to anyone we may have misinformed. In order to make a change to the personal information RWB holds about you, please send us the correction in writing by mail, fax or e-mail. For information that remains in dispute, we will make a note of your opinion as to the accuracy of the information in our files.
Recording Your Options
Any refusal or withdrawal of your consent to the collection, use and disclosure of your information is subject to legal and/or contractual restrictions and reasonable notice. In certain circumstances, we must decline to accept your registration where you refuse or withdraw consent to the collection, use or disclosure of your information by us. If you wish to withdraw your consent, please contact our offices. Our staff will be pleased to explain your options and any consequences of refusing or withdrawing your consent.
Information Regarding Website Practices
We collect and store your e-mail addresses from any communications that you may send to RWB by clicking on any of our e-mail links. We may use your e-mail address to communicate with you, if your e-mail indicates that a response to your inquiry is requested or to address a concern or complaint you may have. Links to external sites are provided for you as a convenience and we assume no responsibility or liability for such linked sites.
Updating This Code
Any changes to this Privacy Code or to our information handling practices will be recorded in a timely manner. We may add, modify or remove portions of this Privacy Code when we feel it is appropriate to do so. However, we will not use any information collected prior to such changes for any new purposes without first obtaining your consent.
Who Can Answer Your Questions About Privacy
If you have any concerns or questions about privacy and confidentiality - or any concerns about the way a request for information was handled - you can take the following action:
Contact the RWB’s Privacy Officer:
Our Privacy Officer has the decision-making authority to resolve most concerns. However, if you are unsatisfied with the way your complaint or request was addressed, you may contact the federal privacy commissioner:
Office of the Privacy Commissioner
112 Kent Street