Personal Information Policy

Canadian Actors’ Equity Association (Equity) is committed to protecting the personal information of its members, permittees, employees, contractors, engagers, and users of Equity’s websites and online services (collectively, “Individuals”), in connection with Equity’s activities across Canada. Equity is dedicated to meeting the requirements of applicable Canadian privacy laws, including, as applicable depending on jurisdiction and activities, the Personal Information Protection and Electronic Documents Act (PIPEDA), Alberta’s Personal Information Protection Act, British Columbia’s Personal Information Protection Act, and Québec’s Act respecting the protection of personal information in the private sector (as amended by Law 25), as well as any other applicable privacy requirements.

Equity is responsible for ensuring compliance with this policy and applicable privacy legislation. Equity has designated a Privacy Officer who may be contacted as set out below.

Definitions

For the purposes of this policy:
“Personal information” means information about an identifiable individual, which may include contact details, member identifiers, employment and engagement information, benefits information, or other information collected in connection with Equity’s activities.

“Sensitive information” means personal information that, due to its nature or context, requires heightened protection (for example, financial information, health information, and identifying information such as gender identity, ethno-cultural identity, or disability).

“Service provider” means a third party engaged by Equity to provide services on Equity’s behalf, which may include benefits administrators, technology providers, and professional advisers.

“De-identified” information means information that no longer identifies an individual and cannot reasonably be used, alone or in combination with other information, to identify an individual.

“Anonymized” information means information that has been irreversibly de-identified in accordance with applicable law.

How and why does Equity collect personal information?

Personal information is collected from Artists engaged under Equity contracts to support the administration of the applicable scale agreement or engagement policy. Equity also collects personal information from and about Individuals as reasonably necessary to operate its programs and services, to manage membership and permittee relationships, to administer benefits, to manage human resources, to maintain website and online services, to communicate with Individuals, to comply with legal and regulatory requirements, and for other purposes identified at or before the time of collection. Equity collects only the personal information necessary to fulfill these purposes.

Members are also responsible for sharing and maintaining accurate, up-to-date personal information with Equity, in accordance with the Constitution & Bylaws

Lawful basis and consent

By engaging with Equity and entering into contractual relationships, members consent to the collection, use, and disclosure of personal information as outlined in this policy, except where otherwise required by law. In some cases, Equity may rely on implied consent or on another lawful basis permitted by applicable privacy laws (for example, to meet legal obligations, to respond to emergencies, or for purposes consistent with those identified at collection). Where required, Equity will seek express consent. Members may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice, and Equity will inform Individuals of any implications of such withdrawal.

Collection limitation and data minimization

Equity limits collection to what is necessary for the identified purposes and collects personal information by fair and lawful means. Wherever feasible, Equity will collect personal information directly from the individual and will use de-identified or anonymized information when appropriate to achieve the intended purpose.

With whom does Equity share personal information?

Required

Equity shares personal information with its designated RRSP provider and Health & Insurance plan provider, as required to open and administer member accounts.

Equity may also disclose personal information to comply with legal and/or tax obligations, or in the event of a life-threatening emergency.

Equity may disclose personal information to service providers and professional advisers who assist Equity in carrying out the purposes described in this policy (for example, technology hosting, data processing, analytics, communications, payment processing, benefits administration), and such service providers are permitted to access personal information only as necessary to provide services to Equity and are required to protect it. Where personal information may be transferred, processed, or stored outside of Canada (including in the United States), it may be subject to the laws of those jurisdictions; Equity will provide appropriate notice where required by applicable law.

Optional

Members may log in to their myEquity profile to manage their contact information sharing preferences:

Equity Councillors — for outreach purposes (Default: shared)
Engagers — for work opportunities (Default: not shared)

Use and disclosure limitations

Equity uses and discloses personal information only for the purposes identified in this policy or at the time of collection, for purposes reasonably related to those purposes, or as otherwise permitted or required by applicable law. Equity does not sell personal information. Where required by applicable law, Equity will obtain additional consent before using personal information for a materially different purpose.

Identifying Information

Equity maintains strict confidentiality of identifying personal information (e.g. gender identity, ethno- cultural identity, disability) collected through surveys or other means. This information is reported only in aggregated, non-identifying formats.

Safeguards, Storage, and Retention

Equity maintains appropriate physical, administrative, and electronic safeguards to protect personal information from unauthorized access, disclosure, loss, alteration, or misuse, proportionate to the sensitivity of the information. Equity restricts access to personal information to those employees, representatives, and service providers who need to know the information to perform their duties. Equity maintains policies and training to support responsible handling of personal information.

Personal information is retained only as long as necessary to fulfill the purposes for which it was collected and to meet legal and regulatory requirements. Information that is no longer required is securely destroyed.

Breach response

In the event of a privacy breach, Equity will take steps to contain the incident, assess the risk of harm, and notify affected Individuals and relevant regulators where required by applicable law.

Your Right to Access Your Information

You have the right to request access to the personal information Equity has about you. You also have the right to know whether Equity has disclosed your personal information to third parties.

How to access your information

To request access to your personal information, submit a written request to Equity’s Privacy Officer and describe as specifically as possible the information you would like to access. Providing some context for your request may help us identify the information you are looking for. Equity will respond to requests as soon as reasonably possible and will let you know if additional time is required.

In some cases, Equity may charge a reasonable fee to retrieve and provide access to physical records held in off-site storage. If a fee applies, we will provide an estimate in advance.

Upon request, Equity will also provide a list of organizations to which your personal information has been disclosed.

Equity may refuse access to personal information where:

the information is protected by solicitor-client privilege;
providing access could adversely affect the security of the Association;
providing access could reasonably be expected to threaten the life or security of another individual;
the information was generated as part of a formal dispute resolution process; or
providing access would likely reveal personal information about another individual.

Equity may refuse access to personal information on the grounds listed above.

Correction and additional rights

Individuals may request correction of their personal information if it is inaccurate or incomplete. Where required by applicable law (including in Québec), Individuals may have additional rights, which may include data portability, the right to request cessation of dissemination or de-indexing, and the right to be informed of automated decision-making where used and to request information about the personal information used to render such decisions.

Cookies and Online Technologies

Equity’s websites and online services may use cookies and similar technologies to operate the site, remember preferences, and understand usage. Where required by applicable law, Equity will provide notice and obtain consent for the use of non-essential cookies. Individuals can manage cookie preferences through their browser settings or available site tools, noting that disabling certain cookies may affect site functionality.

Accountability and Governance

Equity is responsible for personal information in its custody or control and has implemented policies, procedures, training, and contractual safeguards with service providers to protect personal information. Questions about this policy or Equity’s privacy practices may be directed to the Privacy Officer, whose contact details are provided below.

Retention and destruction

Equity retains personal information for as long as necessary to fulfill the purposes identified in this policy and to meet legal and regulatory obligations, after which the information will be securely destroyed, erased, or de-identified in accordance with applicable law.

Breach and complaint process

If you believe your privacy has been compromised or you wish to make a complaint about Equity’s handling of your personal information, please contact Equity’s Privacy Officer using the information below. Equity will investigate complaints and respond within a reasonable time. If your concern cannot be resolved, you may escalate your complaint to the Office of the Privacy Commissioner of Canada or, where applicable, to the relevant provincial privacy regulator.

How to contact Equity’s Privacy Officer

Jing Zhao, CPA, PLP
Director of Finance & Administration
[email protected]

Updates to this policy

This policy may be updated from time to time to reflect changes in Equity’s practices or in applicable laws. Where required by applicable law, Equity will provide notice of material changes. The continued use of Equity’s services after an update indicates acceptance of the revised policy.

Scope and applicability

This policy applies to personal information in Equity’s custody or control relating to Individuals in connection with Equity’s activities across Canada, including activities carried out online and offline, in the course of commercial activities and other activities where applicable privacy laws apply. Where there is a conflict between this policy and applicable law, the latter will prevail. Where the applicability of any statute or regime is uncertain, Equity will comply with applicable privacy laws depending on jurisdiction and activities.