Principle 10: Challenging compliance

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An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals responsible for the organization’s compliance.

An individual will be able to address a challenge concerning compliance with the above principles to the designated individuals accountable for Population Data BC’s compliance.

 

Policies

Related Procedures

Policy 10.1

Concerns regarding Population Data BC’s compliance with its privacy policy may be sent directly to the Privacy Officer of Population Data BC. All communication of this nature will be reviewed by the Executive Director, the Privacy Officer, and the Systems and Security Manager.  If deemed necessary, they will be brought to the attention of the Head of UBC's School of Population and Public Health and the Office of the University Counsel.  Where challenges are found to be justified, they will be addressed directly. This may include changing practices if needed.

Procedure 10.1

  1. All complaints will be logged and reviewed by the Privacy Officer to determine whether the complaint constitutes a breach or omission in Population Data BC’s policies and procedures, and to consider improvements in its processes.

  2. Should the Privacy Officer’s response not be satisfactory, complaints can be escalated to the Executive Director, then to the Head of UBC’s School of Population and Public Health or to the Office of the University Counsel.

  3. Population Data BC will work with the Office of the Information and Privacy Commissioner to improve Population Data BC’s policies and procedures where areas for improvement are identified.

Policy 10.2

Internal complaints about suspected breaches of Population Data BC’s privacy policies and procedures will be reviewed by Population Data BC’s Privacy Officer and the Executive Director.

Procedure 10.2

  1. Population Data BC personnel concerned about possible breaches of Population Data BC’s privacy policies and procedures can either directly inform Population Data BC’s Privacy Officer or  their direct supervisor, who will be responsible for bringing the matter to the attention of the Privacy Officer.

  2. The Privacy Officer will review the complaint and, where appropriate, strategies for improvement will be developed in consultation with the Executive Director and unit Leads. 


Page last revised: November 3, 2014