1. Context
In furtherance of its mandate, the Association of Manitoba Bilingual Municipalities (AMBM) has, for a number of years, organized events and implemented initiatives designed to promote intergovernmental collaboration and to support the continuous improvement of municipal services.
In the course of its activities, AMBM collects, uses, and maintains personal information relating to its members, event participants, employees, partners, and other stakeholders, including for purposes of communications, registration, administrative management, and accountability.
Recognizing the fundamental importance of protecting personal information and maintaining the confidence of individuals and partner organizations, AMBM has adopted this Privacy Policy to govern the collection, use, disclosure, retention, and safeguarding of personal information, in accordance with applicable legislative requirements and generally accepted privacy best practices.
2. Purpose and Objectives
The purpose of this Privacy Policy is to:
- ensure the appropriate protection of personal information;
- promote compliance with applicable privacy legislation;
- establish a clear framework governing AMBM’s internal practices with respect to personal information; and
- maintain the trust of individuals and organizations with whom AMBM interacts.
3. Policy Statement
AMBM is committed to safeguarding the confidentiality and privacy of the personal information of its members, directors, employees, corporate partners, and other stakeholders. AMBM values the trust placed in it by the public and by those with whom it conducts its activities and acknowledges that such trust is dependent on transparency, accountability, and responsible information management practices.
In carrying out its programs, initiatives, and operations, AMBM regularly collects and uses personal information. Any individual whose personal information is collected by AMBM may expect that such information will be appropriately protected and that any use, disclosure, or other handling of the information will be carried out with the individual’s consent, except where otherwise permitted or required by law. AMBM’s privacy practices are intended to uphold this commitment.
4. Definition of Personal Information
For the purposes of this Policy, personal information means any information about an identifiable individual, other than business contact information used solely for the purpose of communicating with an individual in relation to their employment, business, or professional activities.
In limited circumstances, where residential contact information is used for professional or operational purposes, such information may be treated as business contact information; however, it will continue to be protected in a manner appropriate to its sensitivity.
5. Personal Information Management Practices
Personal information collected by AMBM is treated as confidential. Access to personal information by AMBM employees is restricted to instances where access is required to fulfill the purposes for which the information was collected.
AMBM has implemented physical, organizational, and technological safeguards and continues to review and enhance such measures to ensure that personal information is not accessed, disclosed, or shared beyond what is reasonably necessary to achieve its identified purposes. Measures are also in place to ensure the accuracy and integrity of personal information.
AMBM collects, uses, and discloses personal information only for purposes that a reasonable person would consider appropriate in the circumstances. Where appropriate, individuals are provided with the opportunity to opt out of uses of their personal information that are not integral to the original purpose for which the information was collected.
Personal information is retained only for as long as necessary to fulfill the purposes for which it was collected, or as otherwise required by applicable legislation.
6. Disclosure to Third Parties
Subject to the consent of the individuals concerned, AMBM may disclose limited business contact information of its members to approved partners for purposes consistent with AMBM’s mandate. Such disclosures are governed by written agreements that strictly limit the use of the information. Information disclosed for these purposes is limited to the individual’s name, title, business address, and business telephone and facsimile numbers.
AMBM may also engage third-party service providers to perform certain administrative or operational services that require access to personal information, including but not limited to payroll and benefits administration, credit card payment processing, and external auditing. Such service providers are contractually required to maintain the confidentiality of the information and to use it solely for the purposes of providing the contracted services.
AMBM may disclose personal information where required or authorized by law, including under the Personal Information Protection and Electronic Documents Act (PIPEDA), or where such disclosure is necessary to protect the legal rights or property of AMBM.
7. Accuracy and Updating of Personal Information
AMBM makes reasonable efforts to ensure that personal information in its custody is accurate, complete, and up to date. Accurate information enables AMBM to effectively serve its members, directors, employees, partners, and other stakeholders.
Requests to update or correct personal information, including changes of address or legal name, as well as inquiries or concerns relating to privacy practices, may be directed to:
Association of Manitoba Bilingual Municipalities
614 Des Meurons Street
Winnipeg, Manitoba
R2H 2P9
Email: [email protected]
8. Implementation and Privacy Principles
Principle 1 – Accountability
AMBM is responsible for personal information under its control. The Chief Executive Officer acts as AMBM’s Privacy Officer and is accountable for ensuring organizational compliance with this Policy. All AMBM employees share responsibility for the protection of personal information within the scope of their duties.
Principle 2 – Identifying Purposes
The purposes for which personal information is collected are identified at or before the time of collection.
Principle 3 – Consent
AMBM obtains informed consent for the collection, use, or disclosure of personal information, except where consent is not required due to legal or security considerations.
Principle 4 – Limiting Collection
The collection of personal information is limited to that which is necessary to fulfill the identified purposes and is carried out by fair and lawful means.
Principle 5 – Limiting Use, Disclosure, and Retention
Personal information is not used, disclosed, or retained for purposes other than those for which it was collected, except with the consent of the individual or as permitted or required by law.
Principle 6 – Accuracy
Personal information is maintained as accurately, completely, and up to date as necessary to fulfill its intended purposes.
Principle 7 – Safeguards
Personal information is protected by safeguards appropriate to the sensitivity of the information. In the event of a privacy breach involving personal information, AMBM will take reasonable steps to mitigate potential harm and will notify affected individuals where required by law.
Principle 8 – Openness
AMBM makes information readily available regarding its privacy practices and procedures governing the management of personal information.
Principle 9 – Access to Personal Information
Upon request, individuals are entitled to be informed of the existence, use, and disclosure of their personal information and to access such information. Individuals may request corrections to their personal information where it is inaccurate or incomplete.
Principle 10 – Complaints and Inquiries
Complaints or inquiries regarding compliance with this Policy may be submitted to the Chief Executive Officer at [email protected].
Additional information regarding privacy rights and obligations may be obtained from the Office of the Privacy Commissioner of Canada at www.priv.gc.ca.
9. Amendments
AMBM reserves the right to amend this Privacy Policy at any time. Any amendments will take effect upon adoption and may be implemented without prior notice.
