RETAIL WHOLESALE UNION'S
Personal Information Protection Policy

The Retail Wholesale Union (RWU) is committed to protecting the privacy, confidentiality, accuracy and security of members' personal information collected and to use and retain it in the course of conducting our duties as a trade union. The following policy outlines the RWU's operational practices concerning the collection, use, disclosure and protection of personal information to meet the requirements of the British Columbia - Personal Information Protection Act (PIPA). The purpose of the Act is to govern the collection, use and disclosure of personal information by organizations in a manner that recognizes both the right of individuals to protect their personal information and the need of organizations to collect, use or disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances. Updated versions of this Members' Personal Information Protection Policy will be posted on the RWU website at www.rwunion.com. Copies will also be available at the RWU office.

What is personal information?
The Act defines "personal information" as information about an identifiable individual and includes employee personal information but does not include the name, business contact information or work product information of an employee of an organization.

What information is the RWU responsible for protecting?
The RWU is responsible for protecting members' personal information in its possession including personal information that has been received from a third party or personal information that may not be in the custody of the RWU but which has been transferred to a third party.

Collecting, using and disclosing members' personal information.
The RWU collects certain personal information in order to:

• maintain a complete record of membership in the Union
• maintain communication with members and respond to their enquiries
• investigate and settle grievances, appeals and claims
• collect and manage dues, fees and assessments
• assist the Union in representing its members with respect to employment under collective agreements
• verify eligibility for benefits
• provide information about Union membership programs and benefits
• administer the business of the Union such as local business, correspondence and research (eg member survey)

Personal information may be collected, used or disclosed for any of these identified purposes as set out above. If members' personal information is needed for any purpose other than those set out above, the RWU will not use or disclose it without obtaining additional consent from the member(s).

How does the Union gather members' personal information?
The collection, use and disclosure of personal information depends on gathering information from the following sources:

• membership application
• grievance, appeal or claim forms
• employers, with respect to dues submissions and seniority
• a member's interaction with the Union, for example, e-mail, correspondence or telephone
• name or address change
• benefit application

Protection of personal information.
In order to protect members' personal information in the Union's possession or control, the RWU has made reasonable security arrangements to protect personal information such as:

• access to personal information is limited to selected employees and officers who require access to the information in the performance of their job function and/or duties.
• security safeguards are in place to prevent unauthorized access on computer systems.
• the Union will not collect or disclose personal information for purposes other than what has been listed in this Operational Policy.
• the Union will do its best to ensure that personal information is accurate and current.

Further,

• any membership lists or information will not print a member's social insurance or employee number(s).
• membership and reference lists/reports produced for the purpose of conducting the Union's business, will be distributed with advice on the appropriate use of such information in order to comply with this Operational Policy. (Examples of such lists/reports would include steward and officer lists, membership lists, grievance reports, worksite reports.)

Elected officers found to be abusing membership information, can be subject to the disciplinary procedure in the RWU Constitution and By-laws.

Staff of the RWU found to be abusing membership information can be subject to disciplinary action.

How do members access their personal information?

Requests should be in writing addressed to the RWU Privacy Officer, Brian DeBeck, 4371 Fraser Street, Vancouver, B.C. V5V 4G4 stating as specifically as possible what personal information you are requesting.

Response to such requests will be within thirty (30) days or as soon as possible. If, for some reason, the Union is unable to respond within this timeline, the member will be advised.

A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the member of the cost and request further direction from the member as to whether or not we should proceed with the request.

There may be some types of information the Union is prohibited from providing, such as information about another individual that cannot be separated from your information or information which cannot be disclosed for legal reasons.

Keeping members' information accurate is a priority.
The RWU strives to ensure that the personal information we have on file is accurate and up-to-date as necessary for the identified purposes for which it is to be used.

Can a member decline to have their personal information collected, used, or disclosed for certain purposes?
Yes, a member can decline to have their personal information collected, used, or disclosed for certain purposes. A member may also decline to have personal information collected, used, or disclosed for other purposes. This may, however, restrict the Union's ability to represent their interest. The member will be informed if this applies.

Filing a complaint.
Any complaint relating to this members' Personal Information Operational Policy or any of the procedures should be forwarded to the attention of the RWU Privacy Officer. If the complaint is justified, the Union will take the steps necessary to resolve the issue, including amending the Operational Policy and practices, if necessary.

If the Union is not able to resolve a complaint, or if a member has any other concerns about the RWU Members' Personal Information Operational Policy and procedures, the member may contact the Office of the Provincial Privacy Commissioner. The RWU Privacy Officer will provide this contact information upon request