PIPEDA — Canadian Privacy

Draft for approval. This text was prepared for review and approval by FCA and has not yet been published.

1. What is PIPEDA and how it applies

PIPEDA (Personal Information Protection and Electronic Documents Act) is the Canadian federal law on the protection of personal information in the private sector. It applies to the way Fredericton Christian Academy ("FCA"), in New Brunswick, collects, uses and discloses personal information in the course of its commercial activities, including the enrolment of international students. FCA applies the same principles to the personal information of students and families from any country.

2. The 10 principles of PIPEDA

FCA follows the 10 fair information principles of PIPEDA:

1. Accountability: we are responsible for the personal information under our control, and the Privacy Contact below oversees our compliance
2. Identifying purposes: we tell you why we collect information before or when we collect it
3. Consent: we require knowledge and consent for collection, use or disclosure; for minors, the consent of a parent or legal guardian
4. Limiting collection: we collect only what is necessary for the enrolment
5. Limiting use, disclosure and retention: we use information only for the stated purposes and keep it only as long as needed
6. Accuracy: we keep information accurate, complete and up to date, and families can correct their details
7. Safeguards: we protect information with appropriate security measures
8. Openness: our policies and practices are publicly available
9. Individual access: you may access your information upon request
10. Challenging compliance: you may challenge our compliance with these principles

3. How we handle your information

What we collect, who receives it, how long it is kept and the cookies we use are described in our Privacy Policy. Partners that send students to FCA are independent organizations that are responsible for the information they collect for their own purposes.

4. Transfers outside Canada

Student data is received from other countries, is stored on cloud infrastructure of Supabase, which runs on Amazon Web Services, in the sa-east-1 region, in São Paulo, Brazil, and is accessed by FCA in Canada and by authorized partners in other countries. FCA remains responsible for the information while it is processed by its service providers, and requires a comparable level of protection through access restricted by profile, short-lived signed links to files, automatic reading of documents on our own server and no use of third-party artificial intelligence services. Information that is processed or stored in another country is subject to the laws of that country, and its courts and authorities may be able to access it.

5. Access to your information

You may ask for access to the personal information we hold about you, and to know how it is used and to whom it has been disclosed. For a minor, the request is made by a parent or legal guardian. We may ask you to confirm your identity. We reply within 30 days after receiving the request; if we need more time, as PIPEDA allows, we will tell you the reason and when to expect the answer. Access is free in general. We may refuse part of a request only for the reasons that PIPEDA allows (for example, when it would reveal information about other people), and we will explain them. Families can correct their details at any time through their personal link.

6. Breaches of security safeguards

If a breach of our security safeguards creates a real risk of significant harm to you, we will report it to the Office of the Privacy Commissioner of Canada, notify the people affected, and keep a record of the breach, as PIPEDA requires.

7. Challenging compliance and complaints

If you think we have not respected these principles, write to us first so that we can look into it. You may also file a complaint with the Office of the Privacy Commissioner of Canada: priv.gc.ca

8. Privacy contact

Privacy Contact: [email protected]. General questions and support: [email protected] or [email protected] (WhatsApp +55 19 99964-9625).