Attachment “B”
Registry Agent Employees
Code of Conduct
Regarding Access to and Release of Personal Information
Preamble
Registry Agents and their employees must keep all personal information contained within the Alberta Registries (Registries) databases, and obtained while providing Registries’ services, confidential. Personal information may only be accessed and released when providing the services listed in the Product Catalogue.
Definitions
1. “Code” - means this Code of Conduct for the Access to and Release of Personal Information.
2. “Registry Agent” - is an individual or corporation that has a contractual agreement with the provincial government to provide registry services on their behalf.
3. “Employee” - includes all individuals working in a Registry Agent’s office.
Application of the Code
1. This Code applies to all Registry Agent employees.
2. Access to and release of personal information to Registry Agent clients must be executed in accordance with the Registry Agent Policy and Procedure Manuals.
Registry Agent Employee Responsibilities Under the Code
A. Confidentiality
Registry Agent employees:
1. Are not to discuss nor disclose personal information obtained through Registries’ databases, or from clients, with any individual other than the client as outlined in the Policy and Procedures Manuals.
2. Are not to use the display features of any of the databases to browse for personal information of any individual other than as it relates to providing Registries’ services.
3. Are to take all reasonable steps to safeguard personal information to ensure that unauthorized persons will not have access to it and that a person who has authorized access will not make any unauthorized copies of personal information;
4. Are to notify Registries’ immediately of any unauthorized or inappropriate form of disclosure, use or possession of personal information by any person and promptly furnish Registries with full details of such unauthorized collection, disclosure, use or possession to the extent known.
B. System User IDs
Registries supplies Registry Agents employees with user IDs that allow access to Registries’ databases.
1. Registry Agent employees are responsible for the security of the user IDs and their passwords.
2. Registry Agent employees are not to allow use of their ID and password by another co-worker.
C. Use of Personal Information
1. A Registry Agent employee cannot use personal information, e.g. change of address, supplied by a client when completing a registry service, to solicit further personal or Agent business without the informed consent of the client.
D. Disclosure
A Registry Agent employee may release personal information only for the following purposes:
1. To a client who is requesting their own personal information.
2. According to policy set out in the Registry Agent Policy and Procedure Manuals.
3. Under Section 40 of the Freedom of Information and Protection of Privacy Act (FOIP) on the Office of the Information and Privacy Commissioner website - www.oipc.ab.ca.
E. Telephone Communication
1. Registry Agent employees will take precautions to avoid the risk of an unauthorized person overhearing a telephone conversation regarding a client’s personal information.
2. Registry Agent employees will, wherever possible, use a “closed door policy” while discussing a client’s personal information.
F. Facsimile Machines
1. Registry Agent employees are to ensure, when sending personal information to an individual via fax machines, the personal information is directed to the correct person and fax number.
2. Registry Agent employees are to stay in attendance at a fax machine until the transmission of a fax involving personal information is complete – see OIPC Guidelines for Facsimile Transmission on the Office of the Information and Privacy Commissioner website - www.oipc.ab.ca.
G. Transporting of Personal Information
1. Registry Agents employees must take precautions to avoid the risk of unauthorized disclosure when picking up and transporting all registry documents by ensuring these documents are kept in a sealed envelope and safeguarded at all times. Every effort should be made to ensure that all Registries related materials remain in the registry agent office.
H. Penalties and Consequences
1. Registry Agent employees who do not comply with the provisions of this Code may be subject to disciplinary action, up to and including dismissal.