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Campusdirect Privacy Code

[Note 1: This Code applies to the personal information activities related to the Campusdirect project of the Canada School of Public Service.]
[Note 2:  The words, "collection", "disclosure", "personal information" and "use" are defined in Annex 1: Definitions.]

1. Creation and collection of personal information will be minimized.
   Personal information created or collected by Campusdirect will be limited to the minimal information directly required to effectively and efficiently carry out the purposes for which the information is collected.
2. Before creating or collecting personal information, Campusdirect will notify the individual, in a clear and complete manner, of:
   • why the information is being created or collected;
   • how Campusdirect will utilize the information; and
   • any uses or disclosures Campusdirect will make of the personal information.
3. Personal information, once created or collected, will be stored by Campusdirect in a safe and secure manner in accordance with government legislation and policy and good industry practices.
4. Use and disclosure of personal information will be minimized. In its operations and any reporting or statistical information activities, Campusdirect will utilize and present information, wherever possible, in an aggregate manner that protects the anonymity of the relevant individuals. Aggregate numbers and data used should be sufficiently large to ensure that it is reasonably impossible to identify the specific individuals involved. Actual personal information as collected from individuals will only be used or disclosed where it is impossible or impractical to utilize aggregate information.
5. Both the amount of personal information used by the Campusdirect "need to know group" and the number of people within that group will be minimized.
   
   When use of personal information is required, either on its own or as the basis for aggregate or anonymous information, the use will be limited to:
• the minimal information directly required to fulfill the purpose of the use; and
• the minimal number of people directly required to use that information.
6. Campusdirect will only disclose personal information if, before the disclosure:
• Campusdirect has notified the individual, in a clear and complete manner, of the disclosure; and   
• the individual has clearly made an informed and direct consent to the disclosure.
7. Personal information will be held and retained by Campusdirect for the minimal time required for the effective and efficient management of Campusdirect. In no cases will this time be less than the minimum retention period for personal information specified under the Privacy Act. Upon expiry of the retention time, the information will be securely destroyed.
8. All personal information created, held or collected by Campusdirect is protected under the federal Privacy Act. Campusdirect will provide individuals access to their personal information in accordance with that Act.
9. Campusdirect will take appropriate action against unlawful or unacceptable activities on Campusdirect electronic tools, such as message boards, forums or "chat rooms".  Unlawful or unacceptable activities include those listed in the federal Policy on the Use of Electronic Networks available at the Treasury Board of Canada Secretariat's Web site.
10. All Campusdirect personnel, including contractors using or having access to personal information, will comply with this Code. They will be informed of this Code and either given a paper copy or directed to an electronic version of it.
11. Campusdirect will periodically review:
• the personal information collected in Campusdirect to ensure that it remains necessary to collect that information;
• the purposes for which the personal information is being collected and the adequacy of the relevant consents; and
• this Code to ensure that it addresses all relevant privacy risks and issues.

Annex 1.  Definitions

For the purposes of this Code,

1. "Collection" of personal information means the gathering, acquiring, recording or obtaining personal information from any source, including third parties, by any means, including oral, electronic or written;
2. "Disclosure" of personal information is making any personal information collected by Campusdirect available, including by viewing, to anyone outside the Campusdirect "need to know" group for that information.
3. "Personal Information" is considered to be:
• an individual's name and contact information;
• use by a specific individual of a credit card and the credit card information;
• the products or services accessed by a specific individual  and the details on the individual's participation in each activity;
• a specific individual's learning activities and the details of the individual's participation in those activities;
• learning tools utilized by a specific individual and the details on the individual's use of those tools.
• communications by an individual to Campusdirect, and from Campusdirect to the individual, relating to any of the specific individual's information listed above.

Note:  Reporting of aggregate numbers will be treated as disclosures of personal information where the reported numbers and data are small enough for a person viewing the numbers to be able to identify the specific individuals whose data is used to create the aggregate numbers.  

4. "Use" of personal information is considered to be any action, including viewing, in relation to personal information that has been collected by Campusdirect taken by a person in the Campusdirect "need to know" group for that information.

   Note:   The "need to know" group is anyone within Campusdirect and CSPS Finance who reasonably needs to take that action for:

   • the purposes of the effective and efficient management of Campusdirect;  and
   • the purposes for which the information was collected.