EMC Privacy Policy for Communications
- There needs to be a written policy to guide the use of personal information in the realm of EMC communications
- The policy will be guided by the EMC Privacy Policy, which follows the fair information principles outlined by the PIPEDA legislation. Following is a description of personal information according to this policy:
o “personal information” means information about an identifiable individual, but does not include aggregated information that cannot be associated with a specific individual or the name, title or business address or business telephone number, e-mail or fax number of an employee of an organization.
o For a member such information may include opinions, evaluations, comments, recorded information, and donation records, but does not include certain publicly available information exempted by regulation such as a member’s name, address, telephone number and electronic address.
o For a volunteer such information may include comments, recorded information, donation records, personal and business interests, expenses while on EMC business, a personal photograph, but does not include certain publicly available information exempted by regulation such as a volunteer’s name, address, telephone number and electronic address.
o For an employee, such information may include information found in employment files, performance appraisals, a personal photograph, and medical and benefits information.
o For a contractor, such information may include information found in services contracts.
o Photos and videos are considered personal information and fall under the privacy protections of PIPEDA, except when they are used for personal, journalistic, artistic or literary purposes.
- Some factors that should be taken into consideration for the purposes of the EMC Privacy Policy for communications
o Most of EMC communications falls under the category of “journalistic purposes”
o Consideration must be given to workers serving in restricted access situations where their names, pictures and other personal information would put their ministries in jeopardy
o Names and images of children should not be posted in any situation without express consent
o Although according to privacy legislation in Canada, EMC is protected because we do not engage in commercial activities, and most of our communications is for journalistic purposes, there is still the consideration of Common Law, which is not covered by privacy legislation
o It is good practice to obtain consent from those whose personal information is being shared in any EMC communications medium
- Best Practices to follow regarding pictures and videos in group settings:
o A “good” practice is to let people know when you are taking photos and videos, even in a public place like a church, and how you intend to use the images
o A “better” practice is to obtain verbal consent from all those present
o A “best” practice is to obtain a signed waiver indicating agreement to use the images
Approved by the Board of Trustees September 2, 2021