Approved April 21, 2004 by the Board of Directors.
Revised and Approved January 31st, 2009
(2) This Policy is based on the requirements of federal and provincial laws, specifically, the Personal Information Protection and Electronic Documents Act (PIPEDA). These laws are to be regularly reviewed and the policy updated to reflect changes.
(3) The Executive Director is to review this policy annually and present it to the Board for review.
(4) All Board members, staff, volunteers and agents of OLT are to be bound by agreement to comply with this Policy both during and after their employment or term with OLT is concluded. They are also encouraged to identify situations or procedures that may cause personal information to be at risk of unauthorized disclosure.
(5) The Executive Director may vary the application of this policy so as to limit or refuse the disclosure the information. Other variations in the application of the Policy require the approval of the Operations Committee.
2. Information Officer
The designated person responsible for ensuring compliance with PIPEDA is the Executive Director. The Executive Director is also responsible for the communication of the Policy to staff, patrons, members, volunteers and agents of the OLT.
3. Defining Personal Information
(1) Personal information is any information that can be used to distinguish, identify or contact a specific individual. This information can include an individual’s opinions or beliefs, as well as facts about, or related to, the individual. While certain publicly available information, such as names, addresses and telephone numbers as published in telephone directories, are not considered personal information, they should be treated as such by the OLT to ensure that privacy is not compromised.
(2) Personal information does not include
a. information about organizations or the name, title or business address or telephone number of an employee of an organization;
b. information that does not identify individual persons, such as web traffic, surveys and demographics.
4. Collection of Personal Information
(1) The OLT collects personal information (such contact, address, e-mail, credit card or ticket history) only from ticket-buyers, members, donors, volunteers and others who have actively shown or are likely to show at interest in the organization. This may be done by electronic media (e-mail, web access, etc), telephone, paper-based form and in person.
(2) Individuals are to be informed about the purposes for which their information will be used. This is to be accomplished through subscriber or volunteer communications and by the publication of this policy in public and back-stage spaces and on the OLT website. Copies of the policy are to be available on the OLT website and in-person at the office.
5. Storage of Personal Information
(1) Personal information is stored in our ticket system, volunteer and other databases and in hard copy files. Only authorized OLT personnel may have access to this information. Every effort must be made to protect this information from unauthorized physical and electronic access:
a. passwords must be maintained and meet industry standard complexity;
b. physical data (paper, computers, etc) must be secured by practical means, such as storage in the safe or locked cabinets, from theft or other unauthorized disclosure;
c. any remote back-up or external system must employ industry-standard encryption and must contain, but be limited to, data and functions that are critical to theatre operations;
d. personal information must not leave the building (including electronically) without the Executive Director’s knowledge and consent.
(2) Personal information that is no longer required to fulfill the stated purpose must be destroyed or made anonymous as follows:
a. physical media must be shredded or destroyed;
b. electronic media must be destroyed or irrevocably electronically wiped (this includes any drives, memory device or media that may have been installed on systems used to access personal data);
c. financial and sensitive information shall be destroyed no more than two years after it is collected unless it is specifically still being used at the OLT or required to be preserved by law.
(3) Archives of financial and ticketing information may be kept beyond this limit if it is stored in a secure format or location such as safety deposit box.
6. Use of Personal Information
(1) The OLT uses personal information to better serve its patrons and to expand its volunteer community. Primarily, this includes mailings (by mail or electronic) and phone calls to:
a. provide information about tickets, memberships and donations at OLT;
b. thank supporters and issue tax receipts;
c. invite members and supporters to special events at OLT or other arts events and causes;
d. sell subscriptions, tickets and solicit donations for OLT or other arts events;
e. inform volunteers of ongoing events and news about OLT and the arts community and opportunities to work on OLT shows in an area the may be of interest to them (acting, crew, etc).
(2) The OLT is committed to using personal information in a respectful and useful way. Patrons, members and supporters will receive information that the OLT believes will be in their interest. The OLT will also make sure patrons, members and donors do not receive more than a reasonable number of letters or phone calls.
(3) If an individual requests that their personal information not be used for one of these purposes as noted above, or for any other purpose, that request will be honoured. The individual’s account will be updated accordingly as soon as possible. This may limit the information this individual receives about future events at the OLT.
7. Disclosure of Personal Information
(1) The OLT never sells or rents personal information to any third party. As a part of the arts community in Ottawa, the OLT may provide personal information to other organizations for the specific purpose of informing subscribers, donors, members or volunteers about:
a. theatrical events in the national capital region that may be of interest to them (e.g. Magnetic North, festivals, etc);
b. volunteer or arts community opportunities they fall within their area of interest.
(2) Before this information is provided to another organization, it must agree in writing to protect the information in accordance with this Policy. The organisation must also assume responsibility for any injury if they do not follow this policy. This responsibility is to supersede their internal policies and usage of information.
(3) The OLT will retain ownership of the information and it is to be used exclusively for a specific event or campaign, after which it must be destroyed.
(4) The Executive Director is responsible for all requests for information from other organizations and is to ensure that agreements are in place before any information is provided. A record is to be kept of shared information for a period of three years.
(5) Financial details about an individual or an individual’s level of financial support may only be published with their consent and must never be provided to any external partner.
(6) If information is received from external organization, it must be treated with the same respect as information about OLT subscribers, donors, members and volunteers.
(7) OLT may, from time to time, collect information about patrons on behalf of third parties, such as when OLT acts as box office agent for the third party or rental. Any data collected should be treated in a similar manner to OLT patron data unless explicitly detailed by the contract between the two organisations in which case OLT shall be an agent of that third party.
8. Verification of Personal Information
An individual may request to know what information is stored about them. The request must be made in writing and every effort must be made to verify that the person requesting this information is authorised to do so. The response is to be made in writing to the address of the person. Financial or credit card information must not be provided, but can only be confirmed.
9. Questions and Comments
The OLT welcomes questions and comments regarding this policy. These may be directed to:
Lynn McGuigan, Executive Director
400 King Edward Ave,
Ottawa, Ontario K1N 7M7
Office: (613) 233-8948