Legal

Yael’s Indaba Charitable Initiative Society

Personal Information Protection Policy

 

At Yael’s Indaba Charitable Initiative Society (“the Society”), we are committed to providing our Supporters with educational information on cancer and on how to become involved to support the Society’s mission.  As providing this service may involve the collection, use and disclosure of some personal information about our Supporters, protecting their personal information is one of our highest priorities.

This Personal Information Protection Policy, in compliance with the British Columbia Personal Information Protection Act (PIPA), outlines the principles and practices we will follow in protecting supporters’ personal supporters’ personal information and allowing our supporters to request access to, and correction of, their personal information.

Scope of this Policy 

This Personal Information Protection Policy applies to the Society and any service providers collecting, using or disclosing personal information on behalf of the Society.

Definitions

Personal Information –means information about an identifiable individual.  Personal information does not include contact information (described below).

Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.  Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that the Society complies with this policy and PIPA.

Supporter – any individual who provides personal and/or contact information to the Society through its programs.

Policy 1 – Collecting Personal Information

1.1 Unless the purposes for collecting Personal Information are obvious and the Supporter voluntarily provides his or her Personal Information for those purposes, we will communicate the purposes for which Personal Information is being collected, either orally or in writing, before or at the time of collection.

1.2 We will only collect Personal Information that is necessary to fulfill the following purposes:

• To identify supporter preferences;
• To understand the informational needs of our supporters;
• To deliver requested products and services;
• To send out charity information;
• To contact our supporters for fundraising;
• To ensure a high standard of service to our supporters; and
• To meet regulatory requirements.

 

1.3 We may collect information about individuals when they visit our website.  We use cookies and other technologies to collect this information.  The following are examples of information we may collect with these technologies:

• Your browser type and operating system.
• Web pages you view.
• Links you click.
• IP address.
• Site you visited before coming to our site.
• Emails from the Society that you open and/or forward
• Offers or links you connect to via emails from the Society.

 

Policy 2 – Consent

2.1 We will obtain Supporter consent to collect, use or disclose Personal Information (except where, as noted below, we are authorized to do so without consent).

2.2 Consent can be provided in writing or electronically or it can be implied where the purpose for collecting using or disclosing the Personal Information would be considered obvious and the Supporter voluntarily provides Personal Information for that purpose.

2.3 Consent may also be implied where a Supporter is given notice and a reasonable opportunity to opt-out of his or her Personal Information being used for mail-outs, the marketing of new services or products, fundraising and the Supporter does not opt-out.

2.4 Subject to certain exceptions (e.g., the Personal Information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), Supporters can withhold or withdraw their consent for the Society to use their Personal Information in certain ways.  A Supporter’s decision to withhold or withdraw their consent to certain uses of Personal Information may restrict our ability to provide a particular service or product.  If so, we will explain the situation to assist the Supporter in making the decision.

2.5 We may collect, use or disclose Personal Information without the Supporter’s knowledge or consent in the limited circumstances such as the following:

• When the collection, use or disclosure of Personal Information is permitted or required by law;
• To protect ourselves from fraud or suspected fraud;
• To investigate an anticipated breach of an agreement or a contravention of law.

 

 

Policy 3 – Using and Disclosing Personal Information

3.1 We will only use or disclose Supporters’ Personal Information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:

• To conduct Supporter surveys in order to enhance the provision of our services;
  • To contact our Supporters directly about information, products and/or services that may be of interest;
  • To understand how Supporters arrived at our site; and
  • To further improve our website and/or information, product and/or service offerings.

3.2 We may share your information with our third-party service suppliers, including those who work on behalf of the Society, to deliver the information, products and/or services you have requested from the Society.  We may also share your information when required by law, and / or public authorities.

3.3 We will not sell Supporter lists or Personal Information to other parties.

Policy 4 – Retaining Personal Information

4.1 If we use a Supporter’s Personal Information to make a decision that directly affects the Supporter, we will retain that Personal Information for at least one year so that the Supporter has a reasonable opportunity to request access to it.

4.2 Subject to policy 4.1, we will retain a Supporter’s Personal Information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

 

Policy 5 – Ensuring Accuracy of Personal Information

5.1 We will make reasonable efforts to ensure that a Supporter’s Personal Information is accurate and complete where it may be used to make a decision about the Supporter or disclosed to another organization.

5.2 Supporters may request correction to their Personal Information in order to ensure its accuracy and completeness.  A request to correct Personal Information must be made in writing and provide sufficient detail to identify the Personal Information and the correction being sought.  The request must be sent in writing or electronically to the Privacy Officer, per the contact information at the end of this Personal Information Protection Policy.

5.3 If the Personal Information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the Personal Information in the previous year.  If the correction is not made, we will note the Supporter’s correction request in the file.

Policy 6 – Securing Personal Information

6.1 We are committed to ensuring the security of Supporters’ Personal Information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

 

6.3 We will use appropriate security measures when destroying a Supporter’s Personal Information such as deleting electronically stored information.

6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing Personal Information security.

Policy 7 – Providing Supporters Access to Personal Information

 7.1 Supporters have a right to access their Personal Information, subject to limited exceptions.

7.2 A request to access Personal Information must be made in writing and provide sufficient detail to identify the Personal Information being sought. The request must be sent in writing to the Privacy Officer, in accordance with the contact information at the end of this Personal Information Protection Policy.

7.3 Upon request, we will also tell Supporters how we use their Personal Information and to whom it has been disclosed if applicable.

7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

7.5 A minimal fee may be charged for providing access to Personal Information.  Where a fee may apply, we will inform the Supporter of the cost and request further direction from the Supporter on whether or not we should proceed with the request.

7.6 If a request is refused in full or in part, we will notify the Supporter in writing, providing the reasons for refusal and the recourse available to the Supporter.

Policy 8 – Questions and Complaints:  The Role of the Privacy Officer

8.1 The Privacy Officer is responsible for ensuring the Society’s compliance with this policy and the Personal Information Protection Act.

8.2 Supporters should direct any complaints, concerns or questions regarding the Society’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the Supporter may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for the Society’s Privacy Officer:

Privacy Officer

Yael’s Indaba Charitable Initiative Society

225-425 Carrall Street

Vancouver, BC, V6B 6E3

Canada