Privacy Policy
Part 1 – General
Introduction
The Canadian Immigrant Integration Program (CIIP) is a service provided by the Association of Canadian Community Colleges (ACCC) under the terms and conditions of a contribution agreement signed between ACCC and Citizenship and Immigration Canada (CIC).
CIIP is committed to fair information practices regarding clients whose information it collects, uses or discloses in the course of CIIP administration and CIIP client service delivery.
This Privacy Policy outlines the principles and guidelines by which CIIP protects the personal information collected in the course of serving our clients, and how CIIP uses or discloses client information in its operations. Our conduct regarding personal client information is subject to the provisions of the Personal Information Protection and Electronic Documents Act (PIPEDA) (Canada) and applicable provincial privacy legislation. As well, any personal information that CIIP collects at any one of its international CIIP offices or during a CIIP seminar held outside of Canada will be processed in accordance with local privacy laws, where applicable.
Privacy Principles
1 – Accountability
CIIP is responsible for all personal information under its control. This includes personal information CIIP may transfer to third parties for processing or for providing ongoing services to clients. CIIP has designated a staff member who is accountable for the organization's compliance with this Policy.
2 - Purposes for collection
CIIP will identify the purposes for which personal information is collected. This will be done at or before the time the information is collected. It will apply equally to information collected on electronic forms and paper forms.
3 - Consent
CIIP will obtain client consent before or when it collects, uses or discloses personal information, except where authorized by law.
4 - Limiting collection
CIIP will by fair and lawful means limit the collection of personal information to that which is necessary for the purposes identified by CIIP.
5 - Limiting use, disclosure and retention
CIIP will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the client, or as required or as authorized by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes.
6 – Maintaining accuracy
CIIP will keep personal information as accurate, complete and up-to-date as necessary for the purposes for which it is to be used.
7 – Safeguards and Security
CIIP will protect personal information with appropriate security safeguards.
8 – Transparency regarding policies and procedures
CIIP will provide specific information about its policies and procedures regarding the management of personal information.
9 - Access
Upon receiving written request, and subject to exemptions stipulated by law, CIIP will inform a client of the existence, use and disclosure of their personal information and will provide access to that information. A client will be entitled to challenge the accuracy and completeness of the information and have it amended where inaccuracies exist.
10 - Challenging compliance
Any CIIP client is entitled to challenge compliance with the above principles to the Privacy Coordinator. The Manager, Human Resources and Administration is the Association’s Privacy Coordinator. The Privacy Coordinator is accountable to the President for the Association’s compliance to all applicable privacy legislation and to this Policy, and will help enhance the Association’s reputation vis-à-vis privacy practices.
Privacy Policy in detail
1 - Accountability
| 1.1 | CIIP is responsible for all personal information under its control, including personal information disclosed to third parties for processing. |
| 1.2 | The Privacy Coordinator is responsible for compliance with this Policy, even though other personnel within CIIP administration may be responsible for the day to day collection and processing of personal information, and may be delegated to act on behalf of the Privacy Coordinator. |
| 1.3 | The identity of the Privacy Coordinator will be made known internally and will be made available on request. |
| 1.4 | CIIP will use contractual or other means to protect personal information that has been transferred to CIIP partner organizations and client service providers. |
| 1.5 | Where CIIP acts as a processor of personal information or as a service provider to others, CIIP will comply with this Privacy Policy regarding the personal information it collects, uses or discloses. |
2 - Purposes for Collection
CIIP will identify the purposes for which personal information is collected, used or disclosed, at or before the time the information is collected.
| 2.1 | CIIP, subject to this Privacy Policy, will collect, use and disclose personal information for the following purposes: |
| 2.1.1 | To review and process client registrations on the CIIP Online Registration System, received in hard copy by hand delivery, post or fax, or received in scanned format by email; |
| 2.1.2 | To develop aggregate information and statistics used for monitoring and evaluation of the overall success of the Program and to identify service areas to improve upon; |
| 2.1.3 | To create and maintain the CIIP client databases; |
| 2.1.4 | To identify and select information services and service providers to meet client needs or preferences; |
| 2.1.5 | To comply with legal requirements; |
| 2.1.6 | To comply with funder requirements, see Part 3, Section 2; |
| 2.1.7 | To share relevant information with Canadian partners, including immigrant-serving organizations, colleges, regulatory and credential assessment bodies, employers and others to help with client settlement and employment needs. |
| 2.2 | Clients will be advised of the purposes for which the information is collected at the time of collection, or as soon as practicable thereafter. A client may, at any time, request or be given an explanation of how their personal information is being used. |
| 2.3 | If CIIP proposes to use or disclose personal information for a purpose not previously identified, the new purpose will be identified and documented prior to its use. Unless the new purpose is required or permitted by law, the consent of the client will be obtained before the information can be used or disclosed for that purpose. |
3 - Consent
CIIP will obtain the consent of clients before or when it collects, uses or discloses personal information, except where authorized by law.
| 3.1 | In obtaining consent, CIIP will advise each of the purposes for which personal information will be used or disclosed. Purposes will be stated in a manner that can be reasonably understood by the client. |
| 3.2 | CIIP will seek consent to use and disclose personal information at the same time it collects the information. CIIP will seek additional consent to use and disclose personal information after it has been collected, but before it is used or disclosed for a new purpose |
| 3.3 | CIIP may require clients to consent to the collection, use or disclosure of personal information as a condition for the supply of some information or services to them. (e.g: in order to make a referral to a CIIP partner organization on a client’s behalf, CIIP needs to share the client’s information with that partner.).. |
| 3.4 | In determining the appropriate form of consent, CIIP will take into account the sensitivity of the personal information and the reasonable expectations of clients regarding the proposed use or disclosure of that information. |
| 3.5 | Subject to section 3.3, refusal to agree to any of CIIP’s requests for consent will not affect clients’ participation in CIIP services. |
| 3.6 | Subject to section 3.3, a client may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. Clients may contact CIIP for more information regarding the implications of withdrawing consent: In writing: Privacy Coordinator Association of Canadian Community Colleges 1 Rideau Street, Suite 701 Ottawa, Ontario Canada, K1N 8S7 (613) 746-2222 |
4 - Limiting collection
CIIP shall limit the collection of personal information to that which is necessary for the purposes identified by CIIP.
| 4.1 | CIIP will collect personal information by fair and lawful means. |
| 4.2 | CIIP collects personal information primarily from clients directly. |
| 4.3 | CIIP may also collect personal information from other sources including: |
| 4.3.1 | CIIP stakeholder partner organizations offering services to CIIP clients; |
| 4.3.2 | Employers considering hiring CIIP clients. |
| 4.4 | CIIP may collect personal information from a client about a client or client’s family member(s) for purposes of providing services to the client and the family member. In such cases, the client will be asked to confirm that the family member has consented to the collection, use and disclosure by CIIP of such information unless CIIP obtains consent from the family member directly. |
5 - Limiting use, disclosure and retention
CIIP will not use or disclose personal information for purposes other than those for which it was collected, as set out in this privacy policy, except with the consent of the client, or as required or authorized by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes.
| 5.1 | CIIP may disclose personal information about a client to the following for the purposes set out in Part 1, Section 2: |
| 5.2 | CIIP has a records retention policy that specifies the length of time that records are maintained. All personal information is accessible only by authorized CIIP personnel, or authorized CIIP service providers, who need access to client information for the performance of their duties or provision of services to CIIP clients. |
6 - Maintaining accuracy
CIIP will keep personal information as accurate, complete and up to date as is necessary for the purposes for which it is to be used.
| 6.1 | CIIP will not routinely update personal information, unless it is necessary to fulfill the purposes for which the personal information was collected. However, CIIP will seek to ensure that personal information under its control or in its possession is sufficiently accurate, complete and up-to-date to minimize the possibility that inaccurate personal information is used to make a decision about a client. |
7 - Safeguards and Security
CIIP will protect personal information with security safeguards appropriate to the sensitivity of the information.
| 7.1 | CIIP will use appropriate security safeguards to protect personal information against loss, theft, unauthorized access, disclosure, copying, misuse or modification, regardless of the format in which the information is held.: |
| 7.2 | CIIP will protect personal information transferred to third parties providing services to CIIP and CIIP clients through contractual measures or other arrangements. These arrangements will stipulate the confidentiality of the information, restrict the purposes for which the information is to be used and prohibit its disclosure without direction from CIIP in accordance with this Privacy Policy. |
8 - Transparency regarding policies and procedures
Additional information about our privacy-related policies and procedures is available upon request from the Privacy Coordinator at the co-ordinates provided in Part 1, Section 3.6.
9 - Access
On written request, and subject to exemptions stipulated by law, CIIP will inform clients of the existence, use and disclosure of their personal information and will provide clients access to that information.
| 9.1 | A client will be able to challenge the accuracy and completeness of the information and have it amended where inaccuracies exist |
| 9.2 | In certain situations, CIIP may not be able to provide access to all of the personal information that it holds about a client. These situations shall be limited to those required or stipulated by law. |
| 9.3 | When a client successfully challenges the accuracy or completeness of personal information, CIIP will correct, delete or add information as required. |
| 9.4 | When appropriate, the amended information will be transmitted to any third parties having access to the information in question. |
10 - Challenging compliance
In the event that a client wishes to enquire or complain about CIIP’s personal information practices or compliance with this Privacy Policy, a written enquiry or complaint should be sent to the attention of the Privacy Coordinator at the co-ordinates provided in Part 1, Section 3.6. The Privacy Coordinator will investigate all complaints and respond to all written enquiries. If a complaint is found to be justified by the Privacy Coordinator, CIIP will take all reasonable steps to amend our relevant privacy-related policies or procedures.
11 - Amendments to Privacy Policy
Notification of any changes in CIIP’s Privacy Policy will be posted on the CIIP websites identified in Part 2 below.
Part 2 - Website
CIIP e-Privacy commitment for the following websites registered under CIIP:
www.newcomersuccess.ca,
www.newcomersuccess.com,
www.succesnouveauxarrivants.ca,
www.succesnouveauxarrivants.com,
http://ciip.accc.ca
1 - Introduction
This e-Privacy Commitment explains the manner in which CIIP will deal with any personal information it gathers through its websites. CIIP is committed to providing an online experience that respects and protects your personal privacy-related choices and concerns. CIIP’s Privacy Commitment incorporates its Privacy Policy and practices as detailed in Part 1, as augmented by the provisions that follow. Please read them thoroughly.
2 - Normal website usage
Users can visit CIIP’s website to read program and service information without telling CIIP who you are or revealing any personal information.
The personal information CIIP collects and stores during normal website usage is predominantly related to requests for information from prospective clients and other interested parties.
3 - Dealings with personal information
CIIP gathers personal information via its online registration form found on the CIIP website. This information is stored securely with a third-party provider. For more detail on third party requirements, see Part 1, Section 7.2.
Besides the personal information collected in the CIIP registration form, as noted above, CIIP only collects personal information via the open-text message functionality incorporated in our Contact Us web screen. This information, including email addresses and subject matter of request, is collected with the users consent and is stored by us in a manner appropriate to the nature and sensitivity of that data.
4 - Cookies
The CIIP website automatically recognizes your domain name, IP address, browser version, operating system, and other data about your computer, as well as the site you used to reach us. CIIP uses a browser feature called a "cookie" to collect information anonymously and track user patterns. This cookie is a small text file that is placed on your hard disk by our software. It remains there unless you delete it.
"Cookies" contain a unique identification number that identifies your browser, but not you, to our computers each time you visit our website or log on to the CIIP Online Registration System. Cookies compile statistical data on number and frequency of users. They also allow us to save your settings and preferences for future visits, enabling you to customize your experience. Information gathered through the use of cookies is not related to personally identifiable details.
The use of cookies is an industry standard. Many major browsers are initially set up to accept them. You can reset your browser to either refuse to accept all cookies or to notify you when you have received a cookie. However, if you refuse to accept cookies, you may not be able to use some of the features available on the CIIP website or CIIP Online Registration System.
5 - Links
The CIIP site may contain links to other sites. When you click on links that take you to third- party websites, you will be subject to the third parties' privacy policies. While CIIP supports the protection of privacy on the Internet, CIIP is not responsible for the actions of third parties or for their privacy practices. CIIP encourages its users to be aware when they leave our site and to read the privacy statements of each and every website with which they interact
6 - Security
CIIP uses industry-standard technologies when transferring personal information to and receiving personal information from CIIP website users to help ensure the security and confidentiality of that data.
7 - Children
CIIP does not use its website to solicit personal information from or market to persons under the age of 16 but information about a minor may be provided by the clients’ parent or legal guardian.
8 – Additional information
If you have any questions regarding our e-Privacy Commitment, please contact the ACCC Privacy Coordinator.
Part 3 - Database
1 - Operational database applicability
Personal information collected will be stored in the CIIP central database located in Canada and/or, in the case of personal information collected at a CIIP international office or CIIP seminar outside of Canada, in secure facilities located in the relevant CIIP international office. The information in the CIIP central database located in Canada is stored securely with a third-party provider. For more detail on third-party requirements, see Part 1, Section 7.2.
2 - Information sharing with CIC
| 2.1 | CIIP is funded by Citizenship and Immigration Canada (CIC). As part of CIIP’s funding agreement, it must provide some of your personal information to CIC (such as your full name, date of birth, immigration number or immigration document). CIC is subject to the provisions of Canada’s Privacy Act. |
| 2.2 | CIIP sends this information to CIC through a computer system called the Immigration-Contribution Accountability Measurement System (iCAMS). iCAMS will also contain some information that you provided to CIC when you applied to come to Canada, such as mother tongue and country of origin. The information that you provide also stays with the service provider organization to help them deliver services to you. |
| 2.3 | One of CIC’s goals is to help immigrants and refugees adapt to life in Canada. In order to know whether CIIP’s settlement programs are helping to achieve this, CIC needs to answer questions such as:
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| 2.4 | For a more detailed description of the information collected by CIC and its use, see the following link http://integration-net.ca/english/ini/caf-cipc/doc/r303.htm |
