[POLICY STATEMENT: SGM Canada recognizes the importance of privacy and is committed to the protection of personal information and being accountable and transparent about its practices in the management of personal information. SGM Canada’s privacy policy incorporates the provisions legislated in the Personal Information Protection and Electronic Documents Act (Part 1, PIPEDA, Ontario Government Bill 159), and uses ten principles of the Canadian Standards Association Model Code for the Protection of Personal Information (CAN/CSA-Q830-96 published in 1996 as a National Standard for Canada) as a basis for the privacy policy.
To ensure the privacy of our donors, it is SGM Canada’s policy that the rental or exchange of our donor lists is not permitted. SGM Canada meets all legislated requirements with regard to privacy and also complies with established ethical guidelines for charitable activities including the Donor Bill of Rights and the Association of Fundraising Professionals Code of Ethics and Standards of Professional Practice.
DEFINITIONS Personal Information: Any information that identifies or distinguishes an individual. Personal information does not include public domain information, nor does it apply to corporations. It does not include name, title, or business address or telephone number of an employee of an organization. Public Domain: Information accessible to the public including information obtained from the phone book, magazines, newspapers, databases and publications where the individual has provided the information. Personal information from public databases and registries, court orders and business or professional directories may be used if use and disclosure directly relate to the purpose for which the information was compiled for.
PRIVACY PRACTICES
1. Accountability: SGM Canada is responsible for all personal information under its care, including information which may be transferred to third parties for processing. SGM Canada has implemented the following to ensure compliance with this policy.
- A designated privacy officer is accountable for the overall compliance with the policy and act as the intermediary for privacy and security questions or concerns.
- All staff, volunteers and student placements related to SGM Canada are responsible to ensure that personal information is protected at all times in accordance with this policy. Each person is expected to keep up to date with current policies regarding privacy, report problems or breach of privacy and implement any improvements.
- Every staff member, volunteer and student will be required to sign a confidentiality agreement.
- The privacy policies and practices will be available publicly.
- A procedure for receiving and responding to inquiries of complaints will be publicly available.
- Third parties that manage SGM Canada data will be required to sign a contract or comparative means to outline level of protection required.
2. Identifying Purposes
The SGM Canada collects information for the following purposes:
- To comply with Canada Revenue Agency requirements for processing donations and receipts
- Contact donors regarding future campaigns and special events.
- Inform partners of SGM Canada and SGM Lifewords global family initiatives, stories and prayer requests
- To request support for SGM Canada and SGM Lifewords global family initiatives
- Donor recognition purposes
Before or at the time of collection, the SGM Canada will identify the purposes for which personal information is collected, used and disclosed. If personal information will be used for a purpose not previously identified, SGM Canada will identify the purpose prior to use and provide an opportunity for individuals to opt-out of the activity.
3. Consent
SGM Canada is committed to ensuring individuals are knowledgeable and consent to the collection, use or disclosure of private information.
- SGM Canada will make reasonable efforts to ensure that individuals are advised of the purposes for the collection, use and disclosure of personal information.
- A purpose statement and opt-out option will be included on all materials, response cards and events information cards.
- In general, the receipt of a donation constitutes implied consent to collect, use and disclose personal information for the identified purposes unless instructed otherwise.
- Donors wishing to withdraw their consent to use their personal information in this manner or to change previously provided personal information, may contact us at (905) 683-6482 or via email at [email protected].
- Donors wishing to remain anonymous may do so by so indicating at the time of making a donation. Otherwise, we will assume they have given their consent to the publication of their names in the manner described above.
SGM Canada may disclose private information without consent in the case of an emergency regarding life, health or security of an individual, or if required to comply with a subpoena, warrant or court order, or required to do so by law.
4. Limiting Collection
SGM Canada is committed to limiting the collection of personal information to what is necessary for the fundraising purposes.
- Both the amount and type will be limited to the minimum amount necessary to satisfy the purpose for collection.
- As much as possible, personal information will be collected directly from the individual. However, SGM Canada may collect personal information from other sources to assist in achieving its mission and better serving donors
5. Limiting Use, Disclosure and Retention
SGM Canada does not use or disclose personal information for any purposes other than those for which it was collected for or as permitted by donors through their implied or express consent.
- SGM Canada does not sell, barter, rent or lease its donor lists.
- Employees, volunteers and any student placements are only authorized to access private information if their duties require the information.
- Personal information is kept only as long as it remains necessary or relevant in maintaining an established donor relationship or as required by law. Information which is no longer required will be destroyed, erased or made anonymous.
6. Accuracy
SGM Canada is committed to ensuring information is as accurate, complete and up-to-date as is necessary for the identified purposes for which it is to be used.
- Individuals may requests changes to their personal information. SGM Canada may retain original information for reference purposes.
- SGM Canada will update personal information about donors when necessary to fulfill its purposes, to better serve the donor or as requested by the donor.
7. Safeguards
SGM Canada protects personal information and uses appropriate security measures for each format in which the information is held.Employees are trained in measures of protection including:
- Physical measures such as locking filing cabinets and offices
- Organizational measures such as limiting access to private information on a need-to-know basis
- Technological measures including use of passwords, encryption and audits for the data base and website
8. Openness
SGM Canada will make its privacy policy and practices readily available to the public in various formats. The privacy policy and practices will be available on the SGM Canada website (sgmcanada.ca), and by paper format. To obtain a copy of the privacy policy, or for questions, concerns or complaints please call (905) 683-6482.
9. Individual Access
SGM Canada will allow donors access to their personal information and encourages donors to review, correct and update their personal information.
- Upon written request and authentication of a donor’s identity, SGM Canada will provide them with the personal information under its control within a reasonable timeline.
- In some situations, SGM Canada may not be able to provide access to certain personal information (i.e. if disclosure would reveal personal information about another individual, the personal information is protected by solicitor/client privilege, the information was collected for the purposes of an investigation or where disclosure of the information would reveal confidential commercial information that could harm the competitive position of SGM Canada and/or SGM Lifewords global family initiatives.
- When accounting for the third parties to whom personal information has been disclosed, SGM Canada will attempt to be as specific as possible, but may only be able to provide a list of organizations to which information may have been disclosed about the individual.
- If a record is found to be incomplete or inaccurate, SGM Canada will make amendments.
10. Challenging Compliance
An individual may challenge compliance with SGM Canada’s handling of private information with the Chief Privacy Officer. SGM Canada will maintain and make publicly available procedures for addressing and responding to all inquiries and complaints regarding the handling of personal information.
- The Chief Privacy Officer will address, discuss and document the issue as soon as possible.
- The Chief Privacy Officer may seek external advice where appropriate before providing a final response to the individuals challenging compliance.
- If a complaint is found to be justified, appropriate measure will be taken and if necessary the policies and procedures will be amended.
- The individual who challenged the compliance will be notified of the outcome of the investigation.
11. Privacy Violations
Individuals who fail to comply with this policy will be subject to disciplinary actions, up to and including termination. Examples of violations include, but are not limited to:
- Accessing information that is not required for job purposes
- Misusing or disclosing information without proper authorization
- Disclosing personal passwords for accessing data records