National Film Board of Canada (NFB ) Privacy Policy

Last Update: February 2025

Responsibility: Access to Information and Privacy (ATIP) Coordinator

 

1. Overview and Legal Framework

The National Film Board of Canada (NFB) is governed by the Privacy Act, R.S.C., 1985, c. P-21 (the “Act”) and related regulations, which set out the rules for the collection, use, disclosure, retention, and disposal of personal information by federal institutions. The NFB is committed to ensuring that personal information is handled responsibly and transparently in compliance with the Act.

The Act also provides individuals with the right to access and correct their personal information held by federal institutions, including the NFB, subject to certain exceptions.

 

2. Definitions

Personal Information: Information about an identifiable individual that is recorded in any form. Examples include but are not limited to contact details, demographic information, employment and educational history, financial transactions, medical records, identifying numbers and personal opinions, as defined under Section 3 of the Act.

Certain types of information are excluded under the Act, such as:

• Information about an individual acting in their professional capacity (e.g., job title, work address).
• Information about individuals who have been deceased for over 20 years.

 

3. Collection of Personal Information

• In the course of its day-to-day operations, the NFB collects or receives personal information from employees and individuals involved in its activities, as well as from other governmental organizations, when necessary to carry out its mandate.
• The NFB collects personal information only when it is directly related to its programs or activities.
• Wherever possible, personal information is collected directly from the individual, unless the individual consents to indirect collection or a law authorizes otherwise.

 

4. Use and Disclosure of Personal Information

The NFB uses personal information solely for the purposes for which it was collected or for a consistent purpose, as defined by the Act.

Exceptions to Disclosure Without Consent:

Under Section 8(2) of the Act, personal information may be disclosed without the individual’s consent in specific circumstances, such as:

• For the purpose for which it was originally collected or for a consistent purpose.
• To comply with federal laws, court orders, or subpoenas.
• To an investigative body for the enforcement of laws or lawful investigations.
• To Library and Archives Canada for archival purposes.
• When public interest in disclosure outweighs potential invasion of privacy.
• When the disclosure clearly benefits the individual.

 

5. Retention and Disposal of Personal Information

• • An individual’s personal information is retained for at least two (2) years after it was last used for administrative purposes, in order to provide the concerned-individual with an opportunity to exercise their rights under the Act. This retention period may be reduced with the written consent of the concerned-individual. 
• • Once the retention period expires, personal information is securely disposed of following approved methods, such as shredding or secure deletion.

 

6. Accuracy and Security of Personal Information

• The NFB takes reasonable steps to ensure that personal information is accurate, complete, and up-to-date for administrative purposes.
• Personal information is protected through:
  • Technological safeguards: Multi-factor authentication, encryption of data, anonymization, audit logging, monitoring and firewalls.
  • Physical safeguards: Secure filing cabinets, restricted access, and locked storage.
  • Access to personal information is limited to employees who need it to perform their job duties. Unauthorized access, use, or disclosure is prohibited and may result in disciplinary action.

 

7. Access to and Correction of Personal Information

Individuals have the right to:

• Access personal information about themselves that is under the NFB’s control.
• Request corrections to their personal information if it is inaccurate, incomplete, or outdated.
• Add a notation to their file if a correction request is denied.

To make a request, individuals must contact the NFB’s ATIP Coordinator in writing, providing 

sufficient detail to locate the requested information.

 

8. Exceptions to Access

Access to personal information may be denied in specific situations, such as:

• When the information is protected by solicitor-client privilege.
• When disclosure could compromise an investigation or endanger the safety of individuals.
• When the information relates to a third party and disclosure would violate their privacy.

 

9. Roles and Responsibilities

• NFB Employees: Responsible for adhering to the Privacy Act and this policy when collecting, using, or disclosing personal information.
• ATIP Coordinator: Ensures compliance with privacy laws, processes access and correction requests, and addresses privacy-related inquiries.

 

10. Recourse and Complaints

If an individual is dissatisfied with how their personal information is handled, they may:

• File a complaint with the NFB’s ATIP Coordinator.
• Submit a complaint to the Office of the Privacy Commissioner of Canada, which has the authority to investigate privacy-related concerns.

 

11. Contact Information

For questions, requests, or complaints, please contact:

Access to Information and Privacy Coordinator

Email: ATIP-AIPRP@nfb.ca