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Overview
 ____________________
is committed to protecting the privacy of its donors,
volunteers, employees, and other stakeholders.
We value the trust of those we deal with and of the public, and
we recognize that maintaining this trust requires us to be
transparent and accountable in maintaining the confidentially of
the personal information that you choose to share with us.
This privacy policy statement outlines the principles that
____________________ applies in order to ensure the
confidentiality and integrity of your personal information.
Definitions
Personal information – is information that is recorded in
any form, both fact and opinion, and that can be used to
distinguish, identify, or contact a specific individual. It does
not include business contact information and certain publicly
available information, such as names, addresses, and telephone
numbers as published in telephone directories.
Donor – is any individual or organization that contributes funds
to ____________________.
Employee – This policy’s definition of employee includes a
volunteer. Hence, this pertains to both paid and volunteer
workers for ____________________.
Principles
Accountability:
We are
responsible for the personal information under our control.
While senior management is ultimately accountable for the
protection of personal information, a designated Privacy Officer
is responsible for monitoring practices and procedures to ensure
compliance with the principles set out in this policy.
We are responsible for personal information in our possession or
custody, including information that has been transferred to a
third party for processing. We will use contractual or other
means to provide a comparable level of protection when a third
party is processing the information.
Purpose:
We will identify and document the purposes for which we
collect, use, or disclose personal information at or before the
time of collection.
The purposes will be limited to those which are related to our
business and which a reasonable person would consider
appropriate in the circumstances. We collect, use, and disclose
personal information concerning our donors for the following
reasons:
-
to establish a
relationship and to communicate with donors;
-
to understand who
our donors are and how we may improve our services to meet
their preferences and expectations;
-
to process a
donation, for example, to process a credit card transaction;
-
to issue and
deliver a donation tax receipt;
-
to distribute a
designated donation to another registered charity;
-
to recognize
contributions;
-
to respond to
requests for information;
-
to meet
requirements imposed by law.
We collect, use, and
disclose personal information concerning our employees and/or
volunteers for the following reasons:
-
to recruit, train,
recognize, and retain highly qualified and motivated employees
and volunteers;
-
to establish and
maintain harmonious employer-employee relations;
-
to administer
united way policies and procedures;
-
to manage and
promote the philanthropic activities of united way;
-
to administer
compensation and benefits;
-
to meet
requirements imposed by law.
If we plan to use
personal information we have collected for a purpose not
previously identified, we will identify and document this
purpose before such use.
We will make a reasonable effort to specify the identified
purposes, orally or in writing, to the individual from whom the
personal information is collected either at the time of
collection or after collection but before use. We will state the
identified purposes so that an individual can reasonably
understand how the information will be used or disclosed.
Consent
Personal information will only be collected, used, or
disclosed with the knowledge and consent of the individual, or
as required by law.
The way in which we seek consent, including whether it is
express or implied, may vary depending upon the sensitivity of
the information and the reasonable expectations of the
individual. An individual can withdraw consent at any time,
subject to legal or contractual restrictions and reasonable
notice. We will inform individuals of any implications of
withdrawing consent.
Typically, we will seek consent for the use or disclosure of
information at the time of collection. In certain circumstances,
consent may be sought after the information has been collected
but before use (such as where we want to use information for a
purpose not previously identified).
Limiting Collection
We will limit the amount and type of personal information
collected to that which is necessary for our identified purposes
and we will only collect personal information by fair and lawful
means.
Limiting Use, Disclosure, and Retention
Personal information will not be used or disclosed for
purposes other than those for which it was collected, except
with the consent of the individual or as required by law.
Personal information will be retained only as long as necessary
to fulfil the identified purposes.
Personal information which has been used to make a decision
about an individual will be retained long enough to allow the
individual access to the information after the decision has been
made and, in the event of an access request or a challenge, long
enough to exhaust any recourse an individual may have under the
law. Where personal information is no longer required to fulfil
the identified purposes, it will be destroyed, erased, or made
anonymous.
Accuracy
We will use our best efforts to ensure that personal
information, including information that is disclosed to third
parties, is as accurate, complete, and up-to-date as is
necessary for the purposes for which it is to be used.
Safeguards
We will protect personal information with safeguards
appropriate to the sensitivity of the information.
Our safeguards will protect personal information against loss or
theft, as well as unauthorized access, disclosure, copying, use
or modification, regardless of the format in which the
information is held. We will make our employees and volunteers
aware of the importance of maintaining the confidentiality of
personal information, and we will exercise care in the disposal
or destruction of personal information to prevent unauthorized
parties from gaining access to the information.
Our methods of protection will include physical measures (for
example, locked filing cabinets and restricted access to
offices), organizational measures (for example limiting access
on a "need-to-know" basis), and technological measures (for
example, the use of passwords and encryption).
Openness Concerning Policies and Practices
We will make readily available to donors and employees
specific information about our policies and practices relating
to the management of personal information.
The information we will make available will include: how to gain
access to personal information; the type of personal information
held by us, including a general account of its use; general
information concerning our policies; what personal information
is made available to other United Ways or a donor’s designated
agencies; and how to contact our Privacy Officer.
Individual Access
Upon written request, we will inform an individual of the
existence, use, and disclosure of his or her personal
information and we will give the individual access to that
personal information. An individual can challenge the accuracy
and completeness of his or her personal information and have it
amended as appropriate.
We will respond to an individual’s written request within a
reasonable time (generally within 30 days). We will assist any
individual who informs us that they need assistance in preparing
a request. We may require an individual to provide sufficient
information to permit us to provide an account of the existence,
use, and disclosure of personal information.
While our response will typically be provided at no cost,
depending on the nature of the request and the amount of
information involved, we reserve the right to impose a cost. In
these circumstances, we will inform the individual of the
approximate cost to provide the response and request direction
from the individual on whether or not to proceed with the
request. Requested information will be provided or made
available in a form that is generally understandable. Where
possible, we will indicate the source of the information.
In providing an account of third parties to which we may have
disclosed personal information about an individual, we will
attempt to be as specific as possible.
If an individual successfully demonstrates the inaccuracy or
incompleteness of personal information, we will amend the
information as required. If a challenge is not resolved to the
satisfaction of the individual, we will record the substance of
the unresolved challenge. Where appropriate the amended
information or the existence of the unresolved challenge, as the
case may be, will be transmitted to third parties having access
to the information in question.
In certain situations, we may refuse a request or not be able to
provide access to all the personal information we hold about an
individual. Exceptions to the access requirement will be limited
and specific, as permitted or required by law. Where permitted,
the reasons for denying access will be provided to the
individual upon request.
Recourse
Any individual can address a challenge concerning our
compliance with any of the Privacy Principles to our Privacy
Officer.
We will investigate all written complaints. If we find a
complaint to be justified, we will take all appropriate
measures, including, if necessary, amending our policies and
practices. |
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