Information Management Policies

4.1 Personal Information

4.1.1 The Executive Director shall ensure that any collection, use and disclosure of the personal information shall adhere to the Council’s Information Management Policy.

4.1.2 This personal information is collected for purposes of operating our education program pursuant to section 33(c) of the Freedom of Information and Protection of Privacy Act. If you have questions about this collection, please contact the Executive Director at 852-4418, Box 1509, Jasper AB, T0E 1E0.

4.1.3 When dealing with employee or volunteer information, there is more flexibility than is the case with the personal information of learners. Consent is not required, provided the purposes for the collection, use or disclosure of the personal information are reasonable. In assessing what is reasonable, the question is whether the particular collection, use or disclosure is closely related to nature of the work to be done, the legitimate needs of the organization to supervise the work and what a reasonable person would consider appropriate in the circumstances. Before providing employment references to a potential employer, Council representatives should ensure that the person who is being discussed consents to the disclosure. If a potential employee provides a list of references on an application form, an employer can assume implied consent to contact the references.

4.2 Individuals Access to their Information

4.2.1Procedure for responding to an access request from an employee or volunteer:

A volunteer or employee will make a written request, identifying the personal information they wish to see.
The organization will make all reasonable efforts to respond within 30 days.
The applicant may be charged a fee equal to the photocopy cost in making a copy of the requested material. No fee will be charged if the applicant simply wishes to inspect the file without obtaining a copy.
The organization will, upon request, explain any codes, abbreviations or terms used in the record.
Access may be denied to information that involves the personal information of a third party or if disclosure could reasonably threaten the mental or physical health or safety of the applicant or any other individual.

4.3 Correcting Information

4.3.1 Learner Personal Information:If Alberta Learning notifies the organization that it must correct or annotate personal information about a client, this must be done within 5 working days of receiving notice to do so by Alberta Learning.

4.3.2 Personal Information of Employees and Volunteers:An individual who believes that there is an error or omission in his or her personal information may request the organization to correct the information. This does not apply to an opinion, including the opinion of a professional person or an expert. If no correction is made in response to a request, the following information will be documented on the record in question; the requested change, the date and the reason for rejecting the correction. If a record is corrected or a requested change rejected, the organization must notify any third party to whom that information has been disclosed during the one year before the correction was requested. Within 30 days after a request for correction is received by the organization, the organization must give written notice to the individual that either the record has been corrected or that no correction was made and the request was documented on the record.

4.4 Confidentiality and Security of Client Information

4.4.1 The Jasper Adult Learning Council shall correct or annotate personal information about individuals receiving services, as required by the Minister, within five working days of receiving notice to do so by the Minister.

4.5 Protection of Records

4.5.1 Personal information, regardless of the format in which it is held, will be protected against loss or theft, as well as unauthorized access, disclosure, copying, use or modification by the Jasper Adult Learning Council. Hard copy records will be kept in locked filing cabinets and in secure areas where unauthorized persons cannot access them. The Jasper Adult Learning Council will keep hard copy and electronic records containing personal information about persons separate and apart from other Council records. Access to electronic files will be password protected.

4.6 Retention and Destruction Procedure

Unless the individual who is the subject of a record consents in writing to earlier destruction or longer retention of a record, the following rules shall apply.

4.6.1 Records (including interview notes and reference checks) concerning unsuccessful applicants for an employment or volunteer position shall be kept for three months after the close of a competition or the date the position is filled.

4.6.2 Records concerning employees of the Jasper Adult Learning Council will be maintained until two years after the termination of their employment.

Records concerning volunteers of the Jasper Adult Learning Council will be maintained one year after they leave the organization.
Records concerning clients of the Jasper Adult Learning Council will be maintained until two years after the organization ceased to provide service to the client
The Executive Director who is responsible for compliance with this Information Management Policy will ensure that personal information is destroyed in accordance with the retention periods.

4.6.6 A record will be made to reflect any disclosure of personal information outside of the Council. The record will reflect the date, the purpose and the recipient of the personal information.

4.7 Challenging Compliance, Dealing with a challenge to compliance:

Personal Information of a Client:

The complaint must be in writing and provide sufficient information to enable the Jasper Adult Learning Council to respond.
Any complaint with respect to client information collected, used or disclosed by the Jasper Adult Learning Council shall be first addressed by the Coordinator.
If the complaint is not resolved then it shall be referred to the FOIP Coordinator for Alberta Learning.
If the complaint is not resolved at that level, the complainant is entitled to refer this matter to the Information and Privacy Commissioner of Alberta.

4.7.2 Personal Information of an Employee or Volunteer

The complaint must be in writing and provide sufficient information to enable the Jasper Adult Learning Council to respond.
Any complaint with respect to employee or volunteer information collected, used or disclosed by the Jasper Adult Learning Council shall be first addressed by the Coordinator.
The Coordinator shall provide a written response to the complaint within 30 days.
If the complaint is not resolved at that level, it shall be referred to the Chairperson of the Jasper Adult Learning Council.

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