Sooke School District (“we”, “us”, “our”, School District No. 62 (Sooke), or “the District”) is committed to protecting the privacy of individuals who access and interact with our websites.

This Website Privacy Policy is intended to provide notice of the District’s website privacy practices and to support compliance with the Freedom of Information and Protection of Privacy Act, R.S.B.C. 1996, c. 165 (“FOIPPA”).

Purpose 

This Website Privacy Policy describes how we collect, use, disclose, retain, and protect personal information through our Sites, and how individuals can access or request correction of such information.  This policy complements and is subject to the District’s “Access to Information and Protection of Privacy” policy and procedures and applicable law.

Scope 

This policy applies to personal information collected through the District’s public-facing websites and associated web-based services operated by or on behalf of the District (e.g. contact forms, feedback forms, subscriptions, event registrations, and similar online services). It does not cover personal information collected through other means (e.g. student record systems, HR systems, internal databases), except where those systems or services are accessed through, linked from, or integrated with a Site.

Definitions 

When used in this Policy, the following terms have the following meanings:

“Personal information”: Recorded information about an identifiable individual, other than contact information used to contact an individual at a place of business, and may include, for example, name, personal email address, phone number, postal address, student or parent/guardian information, and information submitted through online forms.

“Non-personal information / aggregated data”: Information that is anonymous, aggregated, de-identified, or otherwise not reasonably capable of identifying a specific individual, either alone or in combination with other information (e.g. number of visitors, pages visited).

“Cookies/session cookies”: Small text files or data packets stored on users’ devices that help with session behaviour, analytics, security, accessibility, or site functionality, including session cookies and, where required, persistent cookies.

Authority for Collection

The District collects personal information through its Sites only where authorized by FOIPPA or other applicable law, including where collection is authorized by or under an enactment or is necessary for and directly related to a District program or activity. The legal authority for collection may include FOIPPA section 26 and, where applicable, the School Act and other enactments authorizing District programs and services.

Voluntarily Provided Information 

We collect personal information only when you voluntarily provide it or where collection is otherwise authorized or required by law, such as when you:

• submit a contact or feedback form; 
• subscribe to newsletters; 
• register for events (if that functionality is provided); 
• send us an email inquiry; 
• otherwise interact with features of the Site that require input of personal information.

At or before the time of collection, unless otherwise permitted or required by law, we will provide a collection notice that states the purpose for collecting the information, the legal authority for collection, and the title, business address, and business telephone number of a District employee who can answer questions about the collection.

Automatically Collected / Technical Information 

When you visit the Site, we may collect technical information through cookies, log files, analytics tools, or security tools. This information may include personal information where it can identify an individual, directly or indirectly. This data may include, for example:

• your Internet service provider, IP address, and server; 
• length of your visit/session duration; 
• number of requests/pages visited; 
• browser type, operating system type; 
• referring / exit pages; 
• device type (desktop, mobile) and related information.

The Site may use session cookies, which are deleted when a user closes their browser session, and may use other cookies or analytics tools where necessary to support site functionality, security, accessibility, performance, or authorized analytics. Where cookies or analytics tools collect personal information, such collection is managed in accordance with FOIPPA and this Website Privacy Policy.

Users may disable cookies through their browser settings; however, doing so may limit functionality or usability of the Site.

Use of Personal Information 

We may use the personal information you provide, or that is otherwise collected through the Site, for the following purposes:

• to respond to your inquiries, requests, applications, registrations, or submissions;
• to send you relevant communications, if you consent or where otherwise authorized by law (e.g. newsletters or updates);
• to administer, secure, troubleshoot, evaluate, monitor, and improve the Site and its content;
• to compile aggregate statistics and reports in anonymized or de-identified form for the purposes of maintaining or improving the Site.
• to comply with legal, audit, records management, safety, security, or regulatory obligations.

Disclosure / Third Parties 

We will not disclose your personal information to third parties except as authorized or required by FOIPPA or other applicable law, including as follows:

• to trusted service providers (e.g. web hosting, email delivery, analytics, security, or technical support providers) who process information on our behalf, under contractual, confidentiality, privacy, and security obligations;
• when required or permitted by law, including under FOIPPA, court order, subpoena, regulatory requirement, or lawful investigation;
• to another public body, service provider, or third party where the disclosure is authorized or required under FOIPPA or other applicable law;
• with your consent, where consent is permitted and obtained in accordance with FOIPPA and applicable regulations.
• Where service providers process, store, or access personal information outside British Columbia or Canada, the District will do so only where authorized under FOIPPA and applicable regulations, and subject to appropriate contractual and privacy/security controls.

We are not responsible for the privacy practices or content of external websites to which our Site links. We encourage users to review the privacy policies of those external sites.  

Retention of Information 

Personal information is retained and disposed of in accordance with applicable legislation, approved records retention schedules, and District records management policies. Where personal information is used by or on behalf of the District to make a decision that directly affects an individual, the District will retain that information for at least one year after use, unless a longer retention period applies.

Access and Correction 

You have the right to request access to, and correction of, your personal information in the District’s custody or control, subject to applicable exceptions under FOIPPA. To make an access or correction request, contact the District’s Privacy Officer (see contact details below). The District may require verification of identity before providing access to or correcting personal information. There is generally no fee for requesting your own personal information; fees may apply to general records requests where permitted under FOIPPA.

Security Safeguards 

We have implemented reasonable administrative, technical, and physical security arrangements to protect personal information in the District’s custody or control against unauthorized access, collection, use, disclosure, alteration, disposal, or destruction. These measures may include, for example:

• secure network infrastructure, encryption, and secure configuration practices, where appropriate;
• access controls and user authentication; 
• regular security reviews, monitoring, audits, updates, and vulnerability management;
• staff training and confidentiality obligations. 

While we strive to protect your information, no internet or electronic system is completely secure. We cannot guarantee the absolute security of information sent via the internet. If a privacy breach occurs, the District will assess and respond to the breach in accordance with FOIPPA, District procedures, and applicable notification requirements.

Privacy Breaches

The District will take reasonable steps to contain, assess, and respond to suspected or confirmed privacy breaches involving personal information in its custody or control. Where required by FOIPPA, the District will notify affected individuals and the Office of the Information and Privacy Commissioner for British Columbia if a privacy breach could reasonably be expected to result in significant harm.

Changes to this Website Privacy Policy

We reserve the right to modify or update this Website Privacy Policy at any time. If substantive changes are made, we will post the updated policy on the Site together with the effective date. Continued use of the Site after changes are posted will be subject to the revised policy.

Contact / Inquiries

If you have questions, concerns, complaints, or requests related to this Privacy Policy or your personal information, please contact:

Privacy Officer / FOIPPA Coordinator

Sooke School District
Address: 3143 Jacklin Road, Langford BC, V9B 5R1
Phone: 250-474-9800
Email: foippa@sd62.bc.ca
Date Approved / Updated:
Effective Date: