Newman Theological College respects the privacy of the personal information of its employees, students, donors, alumni, and other stakeholders. The college is committed to protecting the privacy of personal information entrusted to us. In line with that commitment, we seek to be transparent and accountable with respect to the collection, use, disclosure, and security of personal information. Any personal information provided is managed according to the Alberta Personal Information Protection Act (PIPA) and accords with the Freedom of Information and Protection of Privacy Act (FOIP). This policy sets out the principles that Newman Theological College applies with respect to the collection, use, disclosure, and protection of personal information.
This policy applies to personal information of NTC’s employees, students, donors, alumni and other stakeholders such as applicants for admission as students and third-party educational partnerships or agencies contracted for purposes of promotion and advertising.
NTC has designated its President as the Privacy Officer maintaining overall responsibility for the protection of personal information and compliance with this policy.
NTC maintains internal practices and procedures to:
- Protect personal information;
- Receive and respond to complaints and inquiries;
- Train and communicate to staff regarding privacy policies and practices; and
- Communicate NTC’s privacy policies and practices publicly.
PURPOSES FOR COLLECTION
NTC shall identify the purposes for which personal information is being collected at or before the time of collection. NTC shall communicate either orally or in writing the purposes for which personal information is collected at the time of collection. NTC shall not use or disclose for any new purpose any personal information without first identifying and documenting the purpose and obtaining the written consent of the individual concerned, unless otherwise authorized or required by applicable legislation. The main purposes for which NTC collects personal information are as follows:
Personal information of employees is collected to fulfill the following purposes:
- Maintain administrative and financial records in accordance with provincial and federal regulations;
- Maintain personnel files in accordance with approved NTC policies;
- Communicate, via email, telephone, or personal interview, details regarding special employee activities and events;
- Planning; and
- To comply with legal and regulatory requirements.
Personal information of students is collected for the following purposes:
- To register for NTC events;
- To provide educational services;
- To process financial transactions and applications for financial aid;
- To facilitate students’ membership with the Newman Theological College Library;
- To transfer information upon graduation to the NTC Foundation and Alumni Association;
- To provide accurate information to a third party when the student has requested a reference; and
- To comply with legal and regulatory requirements.
Personal information of alumni is collected to fulfill the following purposes:
- To communicate: mailing/E-mail/Telephone/Face-to-Face contact for the objective of relating NTC’s activities/events/news;
- To establish and maintain responsible relations with alumni and to provide ongoing service;
- To understand alumni needs and preferences;
- To develop, enhance, advise and provide products and services; and
- To comply with legal and regulatory requirements.
Personal information of donors is collected by the Foundation of SJS & NTC strictly for the purpose of:
- Compliance with legal and regulatory requirements;
- Facilitation of fundraising activities for SJS and NTC; and
- Communications which foster continued engagement of donors in the mission of SJS and NTC.
Please see the Access to Donor and Donor Database Information Policy of The Catholic Archdiocese of Edmonton. This policy applies to Donor information gathered for NTC. All donor information that is viewed by staff and faculty is to be kept in strictest confidence.
The knowledge and consent of individuals, expressed or implied, are required for the collection, use, and disclosure of personal information. Consent will not be obtained through fraudulent means or by deceptive methods, and clear communication will be employed to fairly and reasonably draw the individual’s attention to the issue of consent.
An individual’s expressed consent is communicated to NTC either personally or through an authorized representative. As appropriate, individual expressed consent to the collection, use and disclosure of personal information in exclusive conditions will be sought. In other circumstances, NTC will seek implied consent from individuals in situations where it is more fitting to seek consent through “opt-out” opportunities presented through direct mail publications, telephone, e-mail, or other communication methods. Where such mechanisms are not employed by an individual, NTC shall be entitled to assume that the individual has consented.
WITHDRAWAL OF CONSENT
Any individual may withdraw his or her consent to the collection, use, or disclosure at any time, subject to legal or contractual restrictions and reasonable notice. NTC shall comply with these requests and inform the individual of the implications and restrictions of such withdrawal of consent.
As prescribed by legislation, staff may lawfully collect personal information without the knowledge or consent of the individual only under certain circumstances. Some examples are:
- Where collection of the personal information is clearly in the interest of the individual and consent cannot be obtained in a timely way;
- When collection and use of personal information is required in the case of an emergency that threatens the life, health or security of an individual;
- Where collection of the personal information with the knowledge or consent of the individual would compromise the availability of the accuracy of the information and the collection is reasonable for purposes of an investigation or a proceeding;
- When the information is already publicly available; and
- When the information is collected from another organization that collected it with the consent of the individual and the information is collected solely for the purposes for which it was previously collected and to assist that organization.
Collection of personal information shall be limited to that which is necessary for the purposes identified by NTC. The collection of personal information shall primarily be obtained from the individual concerned with their consent, either expressed or implied, through fair and lawful means.
MEANS OF COLLECTION
Personal information may be collected in many ways including, but not limited to:
- Personal communications, whether in verbal or written form, between the individual and staff of NTC;
- Publicly available information;
- Responses to mailings or other advertising media;
- Communications from authorized representatives of individuals;
- Responses from NTC sponsored, or co-sponsored, events or activities.
USE, DISCLOSURE AND RETENTION
NTC shall not use or disclose personal information for purposes other than that for which the information was collected, except with the consent of the individual or as required or permitted by law. Personal information shall be retained only as long as is necessary for the fulfillment of those purposes. Personal information that is no longer required for its identified purposes or for legal or business requirements shall be destroyed or made anonymous. Personal information used to make a decision which affects an individual to whom the personal information relates shall be retained for no less than one year from the time of notifying the individual of the decision. NTC shall not sell, rent or loan the personal information of its employees, students, donors, and partnered relationships to third parties. Except as stated below, personal information is not disclosed to any third party even those whose purpose could be construed to be compatible with that of Newman Theological College. In disclosing personal information to third parties, NTC shall make every reasonable effort to ensure that the organizations to which the information is disclosed use that information only for the purposes for which it was disclosed.
The following personal information may be disclosed to a third party without consent:
- The credentials Newman Theological College has awarded to the student and the date those credentials were awarded;
- The names of recipients and the amounts of scholarships, bursaries or awards that have been conferred by Newman Theological College;
- The names and addresses of members of NTC’s mailing lists to mail handling agencies.
As permitted by legislation, personal information may be disclosed without consent in certain circumstances. These include, but are not limited to, the following:
- Where the disclosure is clearly in the interests of the individual and consent cannot be obtained in a timely way;
- Where the disclosure is necessary in order to collect a debt owed to the organization or for the organization to repay an individual money owed to them by the organization; and
- Where the disclosure is to a law-enforcement agency in Canada, concerning an offence under the laws of Canada or a province, to assist in an investigation.
In all other cases, personal information of an individual will not be disclosed to a third party unless consent has been obtained.
ALUMNI AND LIBRARY SERVICES
Certain personal information such as names, student identification numbers, and contact information of all students may be disclosed to the following:
- Newman Theological College Alumni Association in order to provide membership services;
- Newman Theological College Library Services;
- The Foundation of Newman Theological College and St Joseph Seminary.
EMPLOYEES OF NEWMAN THEOLOGICAL COLLEGE
Access to records is permitted only to NTC faculty and staff whose official responsibilities require such access. Furthermore, access is limited, as much as is feasible, to the extent that is consistent with those responsibilities. Personal information about an individual will be disclosed to a member of NTC faculty and staff or to members of a College committee only where that information is judged to be consistent with the official duties of that faculty, staff or committee.
The office of the Registrar distributes to faculty, and to their teaching assistants, class lists, and grade rosters which shall include contact information of students registered for classes.
OFFICIALS AND OFFICIAL AGENCIES
Personal information concerning individuals may be disclosed by NTC when it is legally required to do so (e.g., information required by subpoena or court order).
NTC provides personal information of students to Statistics Canada as required. Personal information of individuals is also provided to Canada Customs and Revenue Agency. Students and employees may appeal to Statistics Canada to have their personal information removed from its database.
NTC shall make reasonable efforts to ensure that all personal information collected by it is accurate and complete, and shall also make reasonable efforts to keep the personal information up-to-date. It is the responsibility of the individual to whom the information relates to notify NTC of any changes or corrections to that information. Inaccurate information shall be corrected upon request made by the individual to whom the information relates. Supporting legal documentary evidence may be requested to substantiate the request.
NTC shall take reasonable steps to protect and ensure the security of all personal information that is retained by it or in its control. Security arrangements will be employed to protect personal information against loss or theft, as well as against unauthorized access, disclosure, copying, use, modification, or disposal. Personal information shall be protected regardless of the format in which it is held. The nature of the safeguards will vary depending on the sensitivity of the personal information that has been collected, the amounts, distribution, and format of the information, and the method of storage. More sensitive personal information will be safeguarded at a higher level of protection.
METHODS OF PROTECTION
- Physical: fireproof, security lock filing cabinets, restricted access to offices, security systems with individual password protection.
- Organizational: disclosure of personal information within NTC shall be limited to those whose job responsibilities require access to such information.
- Technological: software security on LAN and individual computers is ensured through passwords and restrictive access.
Faculty and staff are regularly advised of privacy issues and their role in ensuring the protection of personal information.
THIRD PARTY DISCLOSURE
DESTRUCTION OF PERSONAL INFORMATION
NTC shall ensure that personal information is destroyed securely, and that care and attention is paid to the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.
NTC shall ensure that its policies and procedures regarding the protection of privacy of personal information are communicated in a fashion that allows for access to this information without unreasonable effort. This Policy will be made available in a form that is reasonable and understandable.
NTC shall make available:
- The means of requesting access to personal information held by NTC;
- A description of the type of personal information retained by NTC and its use;
Communication tools that will be employed to highlight the above shall include, but are not limited to:
- NTC news publications;
- NTC website;
- Office of the Registrar
Upon request in writing, NTC shall inform an individual of the existence, use and disclosure of his or her personal information by NTC, and the individual shall be given access to that information, except where the law requires or permits NTC to deny access. The individual must provide sufficient information to permit NTC, with a reasonable effort, to provide an account of the existence, use, and disclosure of personal information. This information provided will only be used to respond to the request for access made by the individual. NTC shall respond to the request within thirty days upon receipt of a request.
NTC may lawfully deny access by an individual to his or her personal information in certain limited circumstances, including where:
- The information is protected by solicitor/client privilege;
- Disclosure of personal information results in the disclosure of the personal information of another individual.
If NTC denies an individual’s request for access to his or her personal information, the individual shall be notified of the reasons. The individual may then challenge this decision.
COMPLIANCE AND COMPLAINTS
All complaints will be investigated. If the Privacy Officer determines a complaint is justified, NTC will take appropriate measures, including, if necessary, amending its policies and procedures. The complainant shall be notified of the outcome of the investigation regarding his or her complaint.
Privacy Officer Newman Theological College, President, Office of the President, 10012-84 Street, Edmonton, AB T6A 0B2 Phone: 780-392-2448; Fax: 780-462-4013 Email: email@example.com
Approved by the Board of Governors 2016-04-20