PRIVACY POLICY

1. INTRODUCTION

1.1 The Public School Administrators’ Association of Nova Scotia (PSAANS) respects the privacy of individuals and is committed to promoting a culture of privacy that enables the protection of privacy and continuous improvement of privacy practices.

1.2 The purpose of this Policy is to:

(a) Establish a framework governing the collection, use, disclosure, protection, and destruction of information in the custody or control;

(b) Ensure that PSAANS complies with all applicable privacy laws governing personal information in its custody or control; and

(c) Ensure that all individuals working and studying within, for, or on behalf of PSAANS understand their responsibilities and are accountable for protecting personal information and respecting the privacy rights of individuals when carrying out their duties.

2. POLICY SCOPE

2.1 This Policy applies to:

(a) All individuals employed by PSAANS on a permanent, temporary, part-time, or contract basis;

(b) Service providers contracted to handle personal information in the custody or control of PSAANS;

(c) Volunteers, including members of the Board of Directors;

(d) Participants in the Instructional Leadership Academy (“ILA”), the Educational Leadership Development Program (“ELDP”), and all other professional learning opportunities and modules which may be offered from time to time (collectively the “Programs” and each a “Program”); and

(e) All personal information under the custody or control of PSAANS, including but not limited to:

(i) Information in all recorded formats, digital or paper, and in all storage locations;

(ii) Information related to staff, faculty, students, alumni, clients, members of the public, and other individuals involved in PSAANS operations and activities.

3. DEFINITIONS

3.1 Privacy Legislation means any and all applicable legislation pertaining to the collection, use, and disclosure of personal information, and includes, without limitation, the Personal Information Protection and Electronic Documents Act, SC 2000, c 5 (“PIPEDA”).

3.2 Personal Information has the same meaning ascribed to it in PIPEDA, which includes recorded information about an identifiable individual, such as their contact details, demographic characteristics, identifying numbers or symbols, biometric or genetic information, health-care history, education, finances, criminal or employment history.

3.3 Privacy Officer means the individual designated by the PSAANS Board of Directors to oversee this Policy.

4. POLICY

4.1 Accountability: PSAANS is accountable for managing personal information in its custody or under its control in accordance with applicable privacy laws, collective agreements, contracts, this Policy, and other applicable policies and procedures.

4.2 Accuracy: PSAANS shall make every reasonable effort to ensure that personal information in its custody or under its control is accurate and complete.

4.3 Minimal collection, use, and disclosure: PSAANS’ collection, use, or disclosure of personal information shall be limited to the minimum amount of personal information necessary to achieve the purposes identified at the time of collection.

4.4 Access: Access to personal information shall be restricted on a role-based and need-to-know basis.

5. PROCEDURE

5.1 Collection

(a) PSAANS collects personal information only as permitted by this Policy and applicable legislation, and only as necessary to:

(i)process registration;

(ii) administer the Programs, activities, benefits, and events;

(iii) receive, review, and investigate complaints or reports made pursuant to PSAANS policies;

(iv) conduct disciplinary processes pursuant to PSAANS policies;

(v) impose or uphold discipline;

(vi) monitor continuing competence of registrants;

(vii) fulfill its mandate; and

(viii) conduct governance and operations.

(b) PSAANS shall collect personal information when:

(i) The information relates directly to and is necessary for operating a Program, activity, benefit, or event organized by PSAANS;

(ii) The collection is expressly authorized by applicable legislation; or

(iii) The information is collected for the purpose of law enforcement.

(c) The purposes for which personal information is being collected shall be provided to the individual at the time of collection when it is collected directly from the individual.

(d) PSAANS will collect personal information directly from the individual the information is about unless there is a reasonable requirement to collect from another source and the indirect collection is permitted under Privacy Legislation.

(e) PSAANS shall obtain either express or implied consent prior to collection of personal information except in limited circumstances under Privacy Legislation where collection, use, or disclosure is permitted without an individual’s consent.

5.2 Use

(a) Personal information shall only be used:

(i) For the purpose for which the information was obtained or compiled or a purpose that has a reasonable and direct connection with the original purpose of collection, where the use is necessary for meeting a statutory duty or operating a Program, activity, or event of PSAANS;

(ii) When the individual has provided express or implied consent for the use of the personal information; or

(iii) For purposes expressly permitted, such as research and archival purposes, or as required by law.

Any Program participant, Board member, staff member, or member of the public who holds a genuine belief that personal information is being misused by someone within PSAANS is encouraged, and in the case of Board, executive, and staff members, required to bring the concerns to the attention of the Privacy Officer.

5.3 Disclosure

(a) Personal information shall only be disclosed to individuals or organizations outside PSAANS under the following circumstances:

(i) The disclosure is for the purpose identified at the time of collection or for a purpose consistent with the original purpose;

(ii) The individual that the personal information is about has consented to the disclosure; or

(iii) The disclosure is permitted by this Policy and its associated procedures or is expressly permitted or required by law.

(b) Disclosure of the following types of personal information is permitted without consent:

(i) A faculty or staff member’s personal information to third-party service providers as necessary to administer pay or benefits;

(ii) The names of individuals who received certificates or diplomas, the period of registration, the certificate or diploma awarded, and the Program;

(iii) Necessary personal information in emergency situations, if PSAANS believes, in good faith, that knowledge of that information is required to protect the health and safety of the individual or other persons;

(iv) Personal information required to comply with a court order or subpoena;

(v) Personal information that is permitted by law to be disclosed without consent or its disclosure is required by law.

(c) While contact information may be used internally to support PSAANS’ operational requirements, mailing lists and other contact information are not shared or sold to commercial or other outside interests.

(d) De-identified participant information may be used for statistical analysis, reporting, or general research by PSAANS.

5.4 Consent

(a) PSAANS and those acting on its behalf will ensure there is consent before collecting, using, and disclosing personal information. Consent may be expressed or implied.

(b) When performing functions pursuant to its governing legislation, certain employees and representatives, including but not limited to the registrar, investigator(s), and members of certain committees, are granted all of the powers, privileges, and immunities of a commissioner appointed under the Public Inquiries Act, which in turn permits them to compel evidence and produce documents. A person or committee exercising this authority does not require consent as it falls within the exception for statutory authorization.

5.5 Retention and Disposal

(a) Personal information shall be retained only as long as is necessary to achieve the purposes for which it was collected, or for legal or other legitimate business purposes, in accordance with this Policy and applicable Privacy Legislation.

(b) Personal information pertaining to employees, contractors, and Program participants is generally retained for seven (7) years following the end of the individual’s contractual or educational relationship with PSAANS.

(c) Personal information used to make a decision that directly affects an individual must be retained for a minimum of two (2) years from the date of the decision.

(d) Destruction of all personal information must be secure and take into account the context and sensitivity of the personal information.

(e) Participant personal information (i.e., name, date of birth, gender, address, billing information, etc.) is subject to secure disposal when no longer required for PSAANS operations.

6. POLICY BREACHES

6.1 All known or suspected privacy breaches must be handled in accordance with this Policy.

6.2 Individuals are entitled to make a formal privacy complaint to the Privacy Officer regarding PSAANS’ compliance with this Policy, associated procedures, and applicable Privacy Legislation.

6.3 Non-compliance with this Policy, its associated procedures, and applicable Privacy Legislation may be subject to penalties under PSAANS’ regulations, contracts, and provincial and federal law.

6.4 PSAANS is committed to continuous improvement. Therefore, PSAANS reserves the right to implement measures as deemed appropriate to better support or ensure compliance with this Policy going forward even if a policy breach has not occurred.

7. COMPLIANCE WITH LEGISLATION AND NO LIMITATION ON RIGHTS

7.1 This Policy is intended to ensure compliance with Privacy Legislation.

7.2 Nothing in this Policy does, or is intended to, discourage or limit anyone from exercising any legal rights under any applicable law.

8. COMPLIANCE WITH ALL PSAANS POLICIES

8.1 This Policy supplements, and does not replace, any other policies of PSAANS applicable to the conduct of students, employees, members of the Board of Directors, or PSAANS members generally.

9. TRAINING

9.1 PSAANS will ensure that all employees and contractors receive training to familiarize themselves with this Policy. PSAANS will also provide ongoing training to support compliance with this Policy.

10. POLICY ADMINISTRATION

10.1 PSAANS’ Board of Directors has oversight of this Policy. The Board of Directors has assigned administration of this Policy to the Executive Director.

10.2 This Policy will be reviewed and updated as needed, at least every three years.

10.3 If Members have any questions about this Policy, they may contact the Association’s Executive Director at execdir@psaans.ca.

10.4 The current version of this Policy can always be found in the Members Hub portion of www.psaans.ca.

10.5 Subject to requirements of law, PSAANS expressly reserves the right to change, modify, or delete portions of this Policy without notice.

Last updated: August 20, 2026