Privacy Policy

1. Scope and Accountability

This policy applies to personal information under PWCLC's control, including information collected through the website, email, newsletter, booking process, discovery conversations and client engagements.

Under PIPA, personal information is information about an identifiable individual. Business contact information used to contact someone in their professional role is generally excluded from PIPA's definition of personal information. Confidential organizational information may also fall outside that definition. PWCLC nevertheless treats both with care and protects them in accordance with its professional and contractual confidentiality commitments.

Paul Williams is PWCLC's Privacy Officer and is responsible for this policy, privacy questions, access and correction requests, and complaints.

2. Information PWCLC May Collect

• Contact and professional information, such as name, email address, telephone number, role, organization and preferred contact method.
• Inquiry and booking information, including messages, scheduling details and the leadership or organizational situation a prospective client chooses to describe.
• Engagement information, including agreements, correspondence, working notes, feedback and information voluntarily shared during coaching, advisory, facilitation, workshops or team-development work.
• Administrative and billing information needed to prepare proposals, contracts, invoices, payment records and business records.
• Newsletter information, such as name, email address, consent record and subscription preferences.
• Website and technical information, such as IP address, browser and device information, dates and times of visits, referring pages and interactions needed to operate, secure and understand use of the website.

PWCLC limits collection to information that a reasonable person would consider appropriate for the identified purpose. Please do not submit sensitive personal or confidential organizational information through a general website form. A more appropriate and secure method can be arranged when needed.

3. How Information Is Used

• Respond to inquiries and determine whether an engagement may be a suitable fit.
• Schedule meetings and communicate before, during and after an engagement.
• Design and deliver executive advisory, leadership-team development, strategic facilitation, workshops and speaking engagements.
• Administer proposals, agreements, invoices, payments and business records.
• Send White Space or other requested communications where valid consent or another lawful basis exists.
• Operate, secure, troubleshoot and improve the website and business systems.
• Meet legal, regulatory, insurance, accounting and professional obligations, and establish or defend legal rights when necessary.

PWCLC does not use personal information for a new purpose without obtaining consent unless PIPA permits or requires the use.

4. Consent and Choice

PWCLC obtains consent appropriate to the nature and sensitivity of the information and the purpose for which it is collected, used or disclosed. Consent may be express or may be implied where the purpose is obvious and the individual voluntarily provides the information.

Consent may be withdrawn on reasonable notice, subject to legal, contractual and practical limits. PWCLC will explain any likely consequences of withdrawal and will stop the affected collection, use or disclosure unless it is otherwise permitted or required by law.

5. Client and Organizational Confidentiality

The trust placed in PWCLC is central to the work. Personal information and confidential organizational information shared in an engagement are not disclosed to other clients, prospective clients, newsletter subscribers or the public.

• In an individually focused engagement sponsored by an organization, the information reported to the sponsor is agreed in advance. The substance of private conversations is not disclosed or attributed without the participant's express authorization, except where disclosure is permitted or required by law.
• In team engagements, PWCLC establishes clear expectations at the outset about confidentiality, participation, information flow and what may be reported to the senior leader or organizational sponsor.
• Sessions are not recorded without the express knowledge and consent of everyone involved.
• Testimonials, case examples and identifying details are not published without permission. Anonymized examples are used only when there is no reasonable prospect of identifying the individual or organization.

6. Limited Disclosure and Service Providers

PWCLC does not sell, rent or trade personal information or confidential organizational information. Limited information may be processed by service providers that support website hosting, forms and customer relationship management, email, scheduling, video meetings, document storage, accounting, payments, information technology and security.

Service providers receive only the information reasonably necessary to perform their function and are expected to protect it and use it only for the authorized purpose. PWCLC remains responsible for personal information under its control, including information processed on its behalf.

PWCLC may also disclose information with consent, to professional advisers who owe confidentiality obligations, or where disclosure is permitted or required by law, including to respond to lawful process, investigate an alleged breach, protect legal rights, or address a serious safety concern. Only the information reasonably necessary for the purpose is disclosed.

AI tools may be used to support tasks (e.g., note-taking, data analysis, graphic design, scheduling and other administrative work), and may process information related to a client engagement in doing so. PWCLC does not use AI tools to make decisions about individuals, and selects tools with reasonable data-handling and confidentiality protections.

7. Website, Cookies and Technical Data

The website uses operational technologies provided by its website, form, scheduling and security providers. These technologies may process IP address, device and browser information, timestamps, referring pages and site interactions to deliver pages, submit forms, prevent abuse and understand aggregate website performance.

PWCLC does not use website information for third-party behavioural advertising. Non-essential analytics or tracking technologies will not be enabled without appropriate notice and choice. Visitors can also control cookies through their browser settings, although disabling essential cookies may affect website functions.

8. Newsletter and Electronic Communications

PWCLC sends White Space and other promotional electronic communications only where consent or another lawful basis exists. Each commercial electronic message identifies PWCLC and includes a working unsubscribe option. Unsubscribe requests are processed promptly and within the period required by Canada's Anti-Spam Legislation (CASL). Service-related communications needed to administer an active engagement are not promotional messages.

9. Processing Outside British Columbia

Some service providers may store or process information outside British Columbia or Canada. In those circumstances, information may be subject to the laws and lawful access requirements of the jurisdiction where it is processed. PWCLC uses reasonable measures to select and configure service providers appropriately and to limit the information they receive.

10. Security

PWCLC uses reasonable administrative, technical and physical safeguards appropriate to the sensitivity of the information. These safeguards are intended to reduce the risk of unauthorized access, collection, use, disclosure, copying, modification, loss or disposal. No method of transmission or storage is completely secure, but PWCLC reviews its practices and responds promptly to suspected privacy or security incidents.

11. Retention and Secure Disposal

PWCLC retains personal information only while it continues to serve the identified purpose or is needed for legal, contractual, insurance, accounting or legitimate business purposes. Where personal information is used to make a decision that directly affects an individual, it is retained for at least one year as required by PIPA. When information is no longer required, it is securely destroyed or de-identified.

12. Access and Correction

An individual may submit a written request to access personal information under PWCLC's control, receive information about how it has been used and disclosed, or request correction of an error or omission. PWCLC may need to verify identity before responding. Requests are handled in accordance with PIPA, generally within 30 days, subject to permitted extensions and exceptions.

13. Questions and Complaints

Questions, access or correction requests, consent withdrawals and privacy complaints should be directed to:

PWCLC will acknowledge and investigate privacy complaints and will communicate the outcome and any appropriate corrective action. If a concern is not resolved, an individual may contact the Office of the Information and Privacy Commissioner for British Columbia.

14. Changes to This Policy

PWCLC may update this policy when its services, systems, service providers or legal obligations change. The current version and effective date will be posted on the website. Material changes will be brought to the attention of affected individuals where appropriate.