Personal Information Protection

Private Sector Privacy Legislation
Personal Information Protection Policy

The Royal City Wine Factory Ltd.

dba The Wine Factory.
Personal Information Protection Policy

At The Wine Factory, we are committed to providing our clients and customers with exceptional service.  As providing this service involves the collection, use and disclosure of some personal information about our clients and customers, protecting their personal information is one of our highest priorities.

While we have always respected our clients and customers 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 (PIPA).  PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our clients and customers of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting clients’ and customers’ personal information.  Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients’ and customers’ personal information and allowing our clients and customers to request access to, and correction of, their personal information.

Policy 1 – Collecting Personal Information

1.1  Unless the purposes for collecting personal information are obvious and the client and customers voluntarily provides his or her personal information for those purposes, we will communicate the purposes 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 client and customer information that is necessary to fulfill the following purposes:

  • To verify identity and age as required by BCLDB Regulations;
  • To open and manage an account;
  • To provide requested products and services
  • To meet regulatory requirements;

Policy 2 – Consent

2.1  We will obtain client and customer 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 in writing or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client and customers voluntarily provides personal information for that purpose.

2.3  Consent may also be implied where a client and customers is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or products and the client and customers does not opt-out.

2.4  Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), clients, customers can withhold or withdraw their consent for The Wine Factory to use their personal information in certain ways.  A client’s, customer’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 client and customers in making the decision.

2.5  We may collect, use or disclose personal information without the client’s, customer’s knowledge or consent in the following limited circumstances:

  • When the collection, use or disclosure of personal information is permitted or required by law;
  • In an emergency that threatens an individual’s life, health, or personal security;
  • When the personal information is available from a public source (e.g., a telephone directory);
  • When we require legal advice from a lawyer;
  • For the purposes of collecting a debt;
  • To protect ourselves from fraud;
  • To investigate an anticipated breach of an agreement or a contravention of law

Policy 3 – Using and Disclosing Personal Information

3.1  We will only use or disclose client and customers 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 client and customers surveys in order to enhance the provision of our services;
  • To contact our [clients, customers] directly about products and services that may be of interest;]

3.2  We will not use or disclose client and customers personal information for any additional purpose unless we obtain consent to do so.

3.3  We will not sell client and customers lists or personal information to other parties [unless we have consent to do so].

Policy 4 – Retaining Personal Information

4.1  If we use client and customers personal information to make a decision that directly affects the client and customers, we will retain that personal information for at least one year so that the client and customers has a reasonable opportunity to request access to it.

4.2  Subject to policy 4.1, we will retain client and customers 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 client and customers personal information is accurate and complete where it may be used to make a decision about the client and customers or disclosed to another organization.

5.2  Clients, Customers may request correction to their personal information in order to ensure its accuracy and completeness.  A request to correct personal information 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 and send the corrected information to any organization to which we disclosed the personal information in the previous year.  If the correction is not made, we will note the clients’, customers’ correction request in the file.

Policy 6 – Securing Personal Information

6.1  We are committed to ensuring the security of client and customers personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2  We will ensure proper security measures will be followed to ensure that client and customers personal information is protected:

6.3  We will use appropriate security measures when destroying client’s, customer’s personal information.

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 Clients, Customers Access to Personal Information

7.1  Clients, Customers, Members have a right to access their personal information, subject to limited exceptions.

7.2  A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought

7.3  Upon request, we will also tell clients, customers how we use their personal information and to whom it has been disclosed if applicable.

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

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

8.1  The Privacy Officer is responsible for ensuring The Wine Factory’s compliance with this policy and the Personal Information Protection Act.

8.2  Clients, Customers should direct any complaints, concerns or questions regarding The Wine Factory’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client and customers may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for The Wine Factory’s Privacy Officer:

Harm Woldring: C/O The Wine Factory, 649 Front St., New Westminster, BC, V3M 1A2   P: 604-540-8907