Privacy Policy | City of Greenwood

The City of Greenwood is committed to protecting the privacy and personal information of our residents, visitors, and users of our website and services. As a municipal government in British Columbia, we collect, use, disclose, and protect personal information in strict compliance with the Freedom of Information and Protection of Privacy Act (FOIPPA) and other applicable laws, including the Personal Information Protection Act (PIPA) where relevant for private-sector interactions. This Privacy Policy explains our practices regarding personal information handled through our website (https://greenwoodcity.com/), online services, and related interactions.

Personal information is defined under FOIPPA as recorded information about an identifiable individual, excluding business contact information. We only collect personal information necessary for providing municipal services, responding to inquiries, and fulfilling legal obligations. This policy applies to our website and does not extend to external sites linked from our pages.

By using our website or providing personal information to us, you consent to the practices described in this policy. If you do not agree, please refrain from using our online services.

Collection of Personal Information

We collect personal information only when relevant and necessary for the delivery of City programs, services, or website functionalities. Collection occurs under the authority of Section 26 of FOIPPA, primarily for purposes such as processing requests, administering programs, and improving services.

Types of Personal Information Collected

Direct Collection: When you submit forms, inquiries, applications, or transactions (e.g., permit applications, event registrations, job applications, or feedback surveys), we may collect details such as your name, address, email, phone number, and other relevant information needed to respond or process your request.
Anonymous Browsing: If you are simply browsing our website, no personal information is collected unless you voluntarily provide it. You remain anonymous during general navigation.
Session and Usage Data: We automatically collect non-personal information about your visit, including:
- IP address (a unique number assigned to your device or internet service provider).
- Browser type, operating system, and device information.
- Date, time, and duration of your visit.
- Pages viewed, order of access, and interactions (e.g., clicks on links).
- Referring website (if you arrived via a link) and exit website (if you leave via a link).
Cookies and Analytics: Our website uses session cookies (temporary files stored in your browser's memory and deleted upon exit) to enhance functionality, such as maintaining session state for forms or tracking navigation patterns. We do not use persistent cookies unless specified. We may employ tools like Google Analytics to aggregate anonymous data on site usage trends, which helps us improve content and performance. Cookies do not store personally identifiable information like your name or email. For more on Google Analytics privacy practices, visit their website.
Online Transactions: For services like payments (e.g., utility bills, permits, or tickets), we collect payment details through secure third-party processors. The City does not store credit card information; only transaction status is retained for records.
Social Media and Engagement: If you interact with our official social media channels (e.g., X, Facebook), any personal information you voluntarily post is your responsibility. We may collect contact details for follow-up on comments or inquiries but do not systematically gather data from these platforms.

We collect personal information directly from you whenever possible. If collected indirectly (e.g., from another public body for service delivery), it will comply with FOIPPA exceptions.

Prior to collection, we will notify you of the purpose, legal authority (FOIPPA Section 26), and a contact for questions, unless an exception applies (e.g., law enforcement).

Use of Personal Information

Personal information is used solely for the purpose it was collected or for a consistent purpose under FOIPPA. Examples include:

Responding to inquiries or providing services (e.g., processing a building permit).
Administering programs, such as recreation registrations or community events.
Analyzing aggregate data to improve website usability and municipal services.
Fulfilling legal obligations, such as audits or reporting.

We do not repurpose information without your consent. For instance, contact details provided for a service request will not be used for unrelated marketing.

Usage is limited to City staff on a "need-to-know" basis. IP addresses and analytics data are used anonymously and not linked to identifiable individuals unless required for security purposes.

Disclosure of Personal Information

We disclose personal information only as authorized by FOIPPA, such as:

To fulfill the original collection purpose (e.g., sharing with a contractor for service delivery).
With your consent.
To comply with legal requirements (e.g., court orders, law enforcement).
Internally, to authorized staff for program administration.
To other public bodies if necessary for coordinated services.

We do not sell, rent, or trade personal information. Disclosures to service providers (e.g., IT vendors or payment processors) are governed by contracts requiring FOIPPA compliance, including privacy protections and Canadian data storage where possible.

If personal information is stored or accessed outside Canada (e.g., via cloud services), it will be assessed through a Privacy Impact Assessment (PIA) under FOIPPA Section 69 to ensure adequate safeguards, as required by FOIPPA and OIPC guidelines.

Consent

Your consent is required for the collection, use, or disclosure of personal information beyond the original purpose, subject to FOIPPA exceptions. Consent is implied when you voluntarily provide information via our website (e.g., submitting a form). For sensitive information, we may seek explicit consent.

You can withdraw consent at any time by contacting us, though this may limit our ability to provide certain services. Providing information online is optional; alternatives like in-person, mail, or phone are available.

Protection and Security of Personal Information

The City implements reasonable security measures to protect personal information from unauthorized access, use, disclosure, alteration, or destruction, as required by FOIPPA Section 30. These include:

Physical Safeguards: Secure storage facilities, locked cabinets, and restricted access to offices.
Technical Safeguards: Firewalls, encryption (e.g., SSL for online transactions), passwords, multi-factor authentication, and regular software updates.
Administrative Safeguards: Staff training on privacy, policies for data handling, and incident response procedures. Access is role-based and audited.

Personal information is stored on secure servers within Canada, unless a PIA justifies otherwise. We conduct regular reviews and PIAs for new systems or changes to ensure compliance with OIPC guidelines.

In case of a privacy breach, we will notify affected individuals and the Office of the Information and Privacy Commissioner (OIPC) as required by FOIPPA.

Retention and Disposal

Personal information is retained only as long as necessary to fulfill its purpose, meet legal requirements, or allow access requests (at least one year for decision-affecting records under FOIPPA). Retention follows provincial records schedules, such as the Administrative Records Classification System (ARCS) and Operational Records Classification Systems (ORCS).

Once no longer needed, information is securely disposed of (e.g., shredded paper, permanently deleted digital files) to prevent unauthorized recovery, in line with FOIPPA and provincial standards.

Access, Correction, and Complaints

Under FOIPPA, you have rights regarding your personal information:

Access: Request access to your records, subject to limited exceptions. Submit a formal Freedom of Information request via our website or contact us.
Correction: If you believe factual information is inaccurate (e.g., address or date of birth), request a correction. We will review and update if warranted; opinions may be annotated but not altered.
Complaints: If you suspect improper handling, contact us first. If unsatisfied, complain to the OIPC at [email protected] or PO Box 9038 Stn. Prov. Govt., Victoria, BC V8W 9A4. Visit www.oipc.bc.ca for details.

To exercise these rights, provide identification and details of your request.

Links to External Websites and Third Parties

Our website may link to external sites for convenience. We are not responsible for their privacy practices, content, or security. Review their policies before providing information.

Changes to This Privacy Policy

We may update this policy to reflect changes in practices, technology, or legislation. Revisions will be posted here with the effective date. Check periodically for updates.

This policy is effective as of October 21, 2025.