Privacy Policy
Last Updated: October 28, 2024
BC Health Care Occupational Health and Safety Society (“SWITCH BC”, “us”, “our” or “we”) values your privacy and cares about the treatment of your personal information.
This Privacy Policy (“Policy”) describes the personal information we may collect, use, disclose and otherwise process about individuals who access our website, register as users of the OHS Resource Centre (the “Centre”) or otherwise use our services (the “Services”).
By providing personal information to us, you agree to the processing set out in this Policy as well as authorize SWITCH BC, its third parties and service providers to process your personal information for the purposes set out below.
I. COLLECTION OF PERSONAL INFORMATION
For the purposes of this Policy, “personal information” is information about an identifiable individual whether identified directly or indirectly. For the purposes of this Policy, personal information does not include information normally used to contact an individual at their place of business except as required by applicable privacy and data protection law.
Personal Information Collected Directly from You. While the personal information we collect varies depending upon your use of the Services and our interactions with you, in general, we may collect the following personal information directly from you:
- Information that is reasonably required to register you as a user. Information that is reasonably required to register you for access to Your Say or any discussion board, including invitation only board.
- Communications and Interactions. When you email, call, or otherwise communicate or interact with us, including if you sign up for our mailing lists, newsletter distribution list, complete forms, we may collect and maintain records of your contact details, communications and interactions, and your posts or submissions.
- Promotional and Marketing Information. If you agree to receive marketing communications from us, we may collect your name, email address, phone number, preferences, and if relevant, information about your account and profile. If you participate in special activities, offers, programs, or promotions we offer, we may also collect certain contact details, your age, and any other information that may be required by law.
- Preferences and Other Requests. We may also collect information about your preferences, including communications preferences, preferences related to your use of the Services.
- Activity and usage information. When you visit the website, and when you communicate with us, we may collect a certain amount of personal information about you. Specifically, SWITCH BC may collect the following non-limited information regarding visitors to the website: information concerning the type of device, internet browser, language or computer operating system you are using, your IP address, your location, the domain name of your internet service provider, access times, referring website information, and other information you provide to us. To the extent required by applicable law, we will obtain your consent before collecting such information from you.
Your Say and other discussion boards:
- Your Say is SWITCH BC’s engagement platform. It is used to connect with people working in health care and obtain input as we develop, expand or enhance programs. When you register for Your Say or participate in a discussion board (whether an open forum or invitation only board) we collect the information that you choose to provide, including your registration information and your views, comments and opinions.
OHS Resource Centre:
The OHS Resource Centre is intended to streamline Joint Occupational Health and Safety (JOHSC) work. We may collect the following information in order to provide the Centre’s services to SWITCH BC clients. Please carefully read this section.
- Information that is reasonably required to register you as a user. This may include, but is not limited to: name, contact information (e.g. email address, phone number(s), address, or other similar identifiers), preferred means of communication, employer and job title, union or association affiliation, JOHS Committee position.
- OHS Resource Centre activity and usage information. When you visit the Resource Centre and when you communicate with us, we may collect a certain amount of personal information about you. Specifically, SWITCH BC may collect the following non-limited information regarding visitors to the Centre: information concerning the type of device, internet browser, language or computer operating system you are using, your IP address, your location, the domain name of your internet service provider, access times, referring website information, and other information you provide to us. To the extent required by applicable law, we will obtain your consent before collecting such information from you.
- Information about Third Parties. As a user of the Centre, you may in the course of your usage enter your feedback or information about safety issues, including personal information of third parties. You represent and warrant that you will only enter personal information if you have the legal authority to do so (including consent where consent is legally required). You represent and warrant that you will practice data minimization principles and only input the limited personal information required for the purpose of using the Centre’s services.
II. PURPOSE AND LEGAL BASIS FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
SWITCH BC may collect, use and disclose your personal information for the following non-limited purposes:
- to administer SWITCH BC’s Services;
- to authenticate your identity;
- to operate, customize and improve the quality of the Services;
- to tailor content we may send to you or display or to personalize your experiences and offerings;
- to monitor your compliance with any of your agreements with SWITCH BC, including your use of the Services;
- to provide newsletters, electronic messages and information you request;
- to assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and to operate our business and administer our business, accounting, auditing, compliance, recordkeeping, and legal functions;
- to conduct financial, tax and accounting audits, audits, and assessments of our operations, including our privacy, security, and financial controls, as well as for risk and compliance purposes;
- to maintain appropriate business records and enforce our policies and procedures;
- to protect SWITCH BC, yourself and others from fraud and error and to safeguard SWITCH BC’s business interests;
- to obtain legal, accounting or other professional advisory advice; or
- otherwise with your consent or as required or authorized by applicable law.
To fulfill the above purposes, SWITCH BC may disclose personal information about individuals on a selective basis to third parties as required or permitted by law or as consented to from time to time by the individual. The organizations to which SWITCH BC may disclose personal information include, but are not limited to:
- government agencies;
- insurance companies;
- professionals advising or working on behalf of SWITCH BC such as lawyers, actuaries and benefit consultants;
- vendors and service providers, such as IT and website hosting, marketing and market research providers, including the PHSA, customer support, data storage, data analytics providers, auditors, consultants, and legal counsel; and
- affiliates and business associates of SWITCH BC, as reasonably required in connection with the operations of SWITCH BC.
We may also disclose your personal information in the following circumstances:
- In Support of Business Transfers. If we are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may disclose or transfer the personal information we have collected from you with or to the other company in accordance with applicable laws. We may also disclose certain personal information as necessary prior to the completion of such a transaction or other corporate transaction such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants;
- To Meet Compliance and Legal Obligations. We may also disclose personal information to third parties to the extent required by applicable law and legal obligations. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators, government entities, and law enforcement, or as otherwise required by law or legal process.
- Security and Protection of Rights. Where we believe doing so is necessary to protect SWITCH BC our rights and property, or the rights, property, and safety of others. For example, we may disclose personal information to (i) prevent, detect, investigate, and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Centre, (ii) situations involving potential threats to the health, safety, or legal rights of any person or third party, or (iii) enforce, detect, investigate, and take action in response to violations of our Terms of Use. We may also disclose personal information related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
- OHS Resource Centre: The personal information you enter into the Centre will be collected, used and disclosed by the relevant employers, unions and JOSH Committee members as applicable in the circumstances. SWITCH BC may collect and disclose information about you to its customers in aggregated and de-identified form.
- Your Say and other discussion boards. The personal information you enter will be aggregated and reported to applicable health care partners in de-identified form.
- Other Disclosures. We may disclose personal information in other ways not described above that we notify you of or that we obtain your consent for, or that are otherwise authorized or required by law.
III. COOKIES, TRACKING AND ANALYTICS
To the extent permitted by applicable law and, where required, with your consent, SWITCH BC and our third-party providers may use cookies, pixels, clear GIFs/pixel tags, JavaScript, local storage, log files, and other tracking technologies (referred to herein as “cookies”) to collect browsing, activity, device and similar device and usage information within our Services. We may also combine this “usage data” with other personal information we collect about you for the purposes set further under this Policy.
- A “cookie” is a unique, alphanumeric identifier that we transferred to your computer’s hard drive through your web browser for record-keeping purposes and to customize your SWITCH BC website, or social media site experience. Some cookies can enhance your user experience by, for example, making it easier for you to navigate and log in to our Site(s), saving your preferences and personalizing your online experience), while other cookies are used to support the security and performance of the Services, or allow us to track aggregate and statistical information about user activity within the Services.
- “Pixels” (sometimes referred to as tags, pixel tags or clear GIFs) and other technologies are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, pixels are embedded invisibly on web pages. SWITCH BC may use pixels (also referred to as web beacons, web bugs or pixel tags) in connection with our Services to, among other things, track the activities users of our Services, help us manage content, and compile statistics about usage of our Services. We and our service providers also use clear GIFs in HTML emails to you, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
SWITCH BC also uses the information collected via cookies for the purposes of helping to improve its website, social media sites and Services.
Most web browsers automatically accept cookies, but if you prefer, you can edit your browser options to block them in the future. The Help portion of the toolbar on most browsers will tell you how to prevent your computer from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Some of the Services may not work properly if you disable cookies. Most web browsers automatically accept cookies, but you can usually change your browser settings to prevent accepting new cookies, notify you whenever you are sent a new cookie or disable cookies altogether (see the Help portion in the toolbar of your browser). This gives you the opportunity to decide whether or not to accept new cookies or disable cookies. Although you are not required to accept all cookies when you visit our Services, you may be unable to use all of the functionality of the site if you reject certain cookies.
Cookies can be first party cookies or third party cookies.
- First-party cookies are set by SWITCH BC. These cookies are primarily used to ensure the technical functionality and security of the website.
- Third-party cookies are set by someone other than the website you are visiting, such as by our partners and service providers. We use external platforms to monitor and evaluate the use of the website, e.g. by way of Google Analytics.
There are two types of cookies which last for different lengths of time:
- Session cookies are stored for the time you use the Site(s) and are deleted when you close your browser.
- Persistent cookies are stored on your device for a certain period or (where earlier) until you manually remove them.
Types of cookies. The types of cookies that SWITCH BC uses are set out in Cookie Preference Centre. You can choose which of these to consent to other than strictly necessary cookies which are required in order for the Site(s) to operate.
- Necessary. SWITCH BC set these types of cookies in response to actions made by you which amount to a request for services, such as setting your (privacy) preferences, remembering items in your shopping cart, logging in or completing forms.
- Third Party Performance & Analytics. SWITCH BC may work with analytics service providers (such as Google Analytics) who use cookies, pixels, and other tracking technologies to collect usage data about our Services and provide us with reports and metrics that help us evaluate usage of our Services and enhance performance and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
- Social Media Cookies. We use social media cookies which allows you to share certain pages of our website on social media. This includes Facebook, Twitter and LinkedIn cookies.
Changing your Cookie Preferences Settings are generally browser and device specific, which means that you may need to set the preference for each browser and device you use to access our Services. In addition, if you delete or block cookies, you may need to reapply these preferences to each browser and/or device you use to visit the Services.
- Cookies Preference Centre. You can use the link above to access the preference centre at any time and change your preference settings for cookies.
- Browser Settings You can set your browser to block certain cookies or notify you when a new cookie is set. You can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies altogether. If you disable certain cookies, you will still be able to browse the Site, but some features may not function properly or be available to you.
- Tracking and Profiling Technologies. Notwithstanding any provision to the contrary in this Policy, we will only collect your personal information using technology which allows you to be located, profiled or tracked (i) after having informed you of our intent to use such technologies and (ii) if you choose to activate such technologies.
V. CROSS-BORDER TRANSFERS
In general, SWITCH BC stores personal information within Canada. In certain circumstances, SWITCH BC may transfer your personal information outside of your jurisdiction of residence to fulfill any of the above purposes, including to service providers located in the United States and other jurisdictions outside of Canada who may be subject to applicable disclosure laws in those jurisdictions in accordance with applicable law.
VI. RETENTION
SWITCH BC retains your personal information for the period of time required to meet the purposes identified in this policy, except as required or authorized by applicable law, after which time your personal information is securely destroyed.
VII. SECURITY
We have implemented reasonable precautions aimed to protect the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our best efforts, no data security measures can guarantee security.
Personal information is retained and destroyed by the Company in accordance with the applicable laws and its document and data retention practices.
VIII. YOUR PERSONAL INFORMATION RIGHTS
ACCURACY
SWITCH BC required to take reasonable steps to ensure that your personal information in our possession is accurate and complete. You may request that SWITCH BC correct an error or omission in your personal information that is under our control.
If you request a correction to your personal information and SWITCH BC is satisfied on reasonable grounds that there is an error or omission in your personal information, we will correct the personal information as soon as reasonably possible and, if applicable, send the corrected personal information to each third party to whom the personal information was disclosed. If we do not correct the information, we will annotate it to show that the request was made.
REQUESTS FOR ACCESS
You may have a right to access to your personal information held by us. These rights are not absolute but subject to limits in applicable law.
Where a request to access your personal information is refused, we will notify you in writing, document the reasons for refusal and outline further steps which are available to you. If a request for correction of your personal information is refused, we will annotate our records to show that the correction was requested but not made.
VIII. CONTACT OUR PRIVACY OFFICER; UPDATES TO THIS POLICY
Any questions or concerns regarding the application of this policy should be directed to our Privacy Officer, at hello@switchbc.ca.
This Policy is subject to amendment from time to time.