Carey Hall (“Carey” or “we”) is committed to providing excellence in its offerings for all members of Carey’s working, learning and living community. It is understood that all individuals who choose to formally associate with Carey will conduct themselves in a manner that is consistent with the Biblical principles of the Christian faith. The choice to participate in Carey’s community entails a commitment to maintain a personal lifestyle and interpersonal interactions marked by integrity, honesty, kindness, mutual respect, sensitivity to the needs and concerns of others, on campus and in all settings where the Carey community is embodied.To this end, Carey respects the privacy of the personal information of its employees, contractors, Students, residents, guests, donors, alumni, and other stakeholders and 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. This policy sets out the principles that Carey applies with respect to the collection, use, disclosure, consent and protection of personal information.
In 1991 the residence and college were separated and renamed as Carey Theological College and Carey Centre. Carey Institute was established in 2006 to fill an educational gap for people wanting to further their theological education and leadership skills through non-traditional means. Carey Institute hosted workshops, seminars, dialogues, skill-building, mission experiences, and short media presentations. Carey Institute also used traditional course formats and culturally contextualized theological education to prepare and equip spiritually maturing persons to integrate theological commitment with life in professional and lay ministry.
2. Scope
This policy and its associated procedures, and the regulations, codes and statutes of the regulatory authorities, apply to Carey and all Members of the Carey Community. This policy and its associated procedures also apply to any service providers collecting, using or disclosing personal information on behalf of Carey.
3. Definitions & Interpretation
“Associates” means Carey’s faculty, staff, visiting scholars, consultants and contractors to Carey, volunteers, management, members of the Board of Administration and Senate; and any other persons appointed or engaged by Carey to perform duties or functions on its behalf. “Carey” means Carey Hall and includes Carey Theological College and Carey Centre and all faculties, departments and offices related thereto. “collection” means the act of gathering, acquiring, recording, or obtaining personal information from any source, including sources other than the Individual to whom the personal information belongs, by any means. “consent” includes a voluntary agreement to the collection, use or disclosure of personal information for defined purposes. “disclosure” means making personal information available outside Carey. “individual” means any person who directly or indirectly provides his or her personal information to Carey as described in the policy. “Employee” means an employee of Carey, including a casual employee or dependent contractor. “Members of the Carey Community” means Employees, Students, Associates, alumni, donors and Visitors. “personal information” - means information about an identifiable Individual, and therefore does not include information that cannot be associated with a specific individual. Personal information does not include contact information (information that would enable an individual to be contacted at a place of business like name, position name or title, business telephone number, business address and/or business email). “PIPA” means Personal Information Protection Act, S.B.C. 2003, c.63 as amended or restated. “Privacy Officer” means the individual designated responsibility for ensuring that Carey complies with this policy and PIPA. “Student” includes: (a) a person who has been admitted as either a resident student of Carey or an affiliate (non-resident) student of Carey, for the duration of such admission; and (b) any other person resident in Carey. “UBC” means the University of British Columbia. “use” means the treatment, handling, management and retention of personal information. “Visitor” means any guest, invitee or visitor to Carey’s properties (including real properties, buildings and facilities) or other property owned by Carey or to a function or event authorized or organized by Carey.
4. Accountability for Personal Information
Carey is responsible for the protection of all personal information under its control and maintains overall responsibility for the protection of personal information and compliance with this policy. While senior management is ultimately accountable for the protection of personal information, the day-to-day monitoring for compliance may be delegated to other staff. Carey has designated a Privacy Officer who is responsible for promoting, monitoring, and reporting on compliance with the PIPA and with Carey privacy, records management, and information security policies.
5. Collecting Personal Information
5.1. Unless the purposes for collecting personal information are obvious and a Member of the Carey Community voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
5.2. Carey collects, uses and where appropriate discloses an individual’s personal information for a variety of reasons, including the following:
to provide educational services including, without limitation, determining eligibility for admission to Carey and into specific degree programs; offering courses, programs and services to Students; and assessing and recording academic performance of Students and other matters relevant to a Student’s enrolment at Carey or participating as a Member of the Carey Community;
to manage and administer resident services including, without limitation, determining eligibility for admission to residential programs at Carey and occupancy of short-term and long-term accommodations within Carey’s facilities;
to provide library services through the UBC Library Services, EBSCO, DTL2 and other library platforms;
to manage and administer relationships with Associates and Employees including, without limitation, assessing the qualifications and suitability of applicants for positions as an Associate or Employee; retaining Associates and Employees; managing payroll and benefits; and other matters relevant to Associates’ and Employees’ relationship with Carey or participating as a Member of the Carey Community;
to develop, enhance, and administer relationships with donors including, without limitation, communication with donors of Carey news, activities, and events; the issuance of donation tax receipts; and other services to promote donors’ relationship with the Carey;
to develop, enhance, and administer relationships with, and provide services to, alumni including, without limitation, communication with alumni of Carey news, activities, and events and other services to promote alumni’s relationship with the Carey after the completion of their studies;
to maintain responsible commercial relationship with our third party vendors and service providers including, for example, services offered to Students, Associates and Employees through UBC and billing and credit card payments for items or services purchased;
to manage, plan, and develop Carey’s operations, offerings, recruitment and budget requirements; and
to meet legal and regulatory requirements.
6. Third Parties and Third Party Sites
6.1. To the extent that you submit any Personal Information to any third party (for example, via a third-party software application or service including any social media service that is included in, available through or linked to from any of Carey’s websites and platforms or used in the delivery of Carey’s services), such third party’s collection, use and disclosure of such information may be governed by its privacy policy, and not by this privacy policy. We recommend that individuals familiarize themselves with the privacy policies and practices of any such third parties.
6.2. We are not responsible for the information collection, usage, disclosure or other privacy practices of any third parties, including our affiliates, third-party service providers, any third-party social media platform, any third party making available the devices or operating systems for which Carey’s websites, platforms or services are available (such as Apple Inc. or Google Inc.) and any third party operating any site to which Carey’s websites or platforms contain a link. The inclusion of a link on any of Carey’s websites or platforms does not imply endorsement of the linked site by us or by our affiliates.
7. Using and Disclosing Personal Information
7.1. We will only use or disclose a Member of the Carey Community’s personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
the collection, use and/or disclosure is clearly in the interests of the individual and consent cannot be obtained in a timely way;
the collection, use and/or disclosure is necessary for the medical treatment of the individual and the individual is unable or does not have the legal capacity to give consent;
it is reasonable to expect that the: (i) collection with the consent of the individual would compromise the availability or the accuracy of the personal information; (ii) use or disclosure with the consent of the individual would compromise an investigation or proceeding; and the collection, use or disclosure (as applicable) is reasonable for purposes related to an investigation or a proceeding;
the personal information is collected by observation at a public event at which the individual voluntarily appears;
the personal information is available to the public from a source prescribed by regulation for the purposes of paragraphs 12(e), 15(e) and/or 18(e) of PIPA, as applicable;
the collection, use and/or disclosure is necessary to determine the individual's suitability to receive an honour, award or similar benefit, including an earned degree, honorary degree, scholarship or bursary;
the organization is a credit reporting agency that collects or uses the personal information to create a credit report and the individual consents at the time the original collection takes place to the disclosure for this purpose;
the collection, use and/or disclosure is required or authorized by law;
the information was disclosed to the organization under sections 18 to 22 of PIPA or the disclosure to a third party is authorized by PIPA; or
the collection, use or disclosure personal information is necessary to facilitate: (i) the collection of a debt owed to Carey, or (ii) the payment of a debt owed by Carey.
As permitted by PIPA, Carey may also use and/or disclose personal information in urgent or emergent circumstances when:
the use is necessary to respond to an emergency that threatens the life, health or security of an individual;
the use is necessary for medical treatment and a person does not have the capacity to give consent at the time;
disclosure is for the purpose of contacting next of kin or a friend of an injured, ill or deceased individual; or
there are reasonable grounds to believe that other compelling circumstances exist that affect the health and safety of any individual, in which case notice of the disclosure will be mailed to the last known address of the individual to whom the personal information relates.
8. Retaining Personal Information
Carey has developed or is subject to certain guidelines for the retention of personal information, which include minimum and maximum retention periods in compliance with the privacy legislation. For example, academic transcripts are retained for a period of 50 years while most other information is retained for a maximum period of seven years unless otherwise required by law. If we use an individual’s personal information to make a decision that directly affects the individual, we will retain that personal information in accordance with these retention guidelines so that an individual has a reasonable opportunity to request access to it. The underlying principle of these retention guidelines is to keep personal information only as long as remains necessary or relevant for the identified purposes; and as required by law.
9. Ensuring Accuracy of Personal Information
9.1. We will make reasonable efforts to ensure that an individual’s personal information in the custody or control of Carey is accurate and complete where it may be used to make a decision about the individual or disclosed to another organization.
9.2. Individuals may make a request to correct or rectify personal information held by Carey. The request must be made in writing and provide sufficient detail to allow Carey to identify the personal information, and the correction being sought. If the Individual successfully demonstrates that the personal information is inaccurate or incomplete, we will correct the personal information, as required, and send the corrected personal information to any third party to which we disclosed the personal information in the prior year. If the correction is not made, we will note the individual’s correction request in the file.
10. Securing Personal Information
10.1. Carey is committed to ensuring the security of an individual’s personal information in the custody or control of Carey in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
10.2. To protect personal information, regardless of the format in which it is held, against loss or theft, unauthorized access, collection, disclosure, copying, use, or modification, we have implemented security safeguards which are appropriate to the sensitivity of the information that has been collected, the amount, distribution, format of the information, and the method of storage. These methods of protection used include, but are not limited to:
physical measures, for example, locked filing cabinets and restricted access to offices, classrooms and residences;
organizational measures, for example, limiting access on a “need-to-know” basis; and
technological measures, for example, the use of passwords and encryption.
We will also use appropriate security measures when destroying any personal information in the custody or control of Carey such as shredding documents or deleting electronically stored information.
Carey will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
11. Ensuring Accuracy of Personal Information
11.1. Individuals have a right to access their personal information, subject to limited exceptions. An individual may make a request for access to his or her personal information in the custody or control of Carey. Upon request, we will also tell an individual how we use their personal information and to whom it has been disclosed, if applicable. The request must be made in writing and provide sufficient detail to allow Carey to identify the personal information they desire access to.
11.2. A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the requesting individual of the cost and request further direction from the individual on whether or not we should proceed with the request.
11.3. We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request. If a request is refused in full or in part, we will notify the individual in writing, providing the reasons for refusal and the recourse available to the individual.
12. Contacts
Individuals are to direct any complaints, concerns or questions regarding this privacy policy in writing to the Privacy Officer at:
Carey Theological College ATTN: Privacy Officer 5920 Iona Drive Vancouver, BC V6T 1J6
privacy@carey-edu.ca If the Privacy Officer is unable to address the individual's concerns, the issue can be referred to the Office of the President of Carey Theological College. At any point in this process the individual may also write to the Privacy Commissioner of British Columbia.
