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At the Children’s Bridge Foundation, we understand that personal privacy is a critical issue for our members, donors, and employees. This privacy policy outlines our principles and procedures regarding the confidentiality and security of personal information given to us by members, donors and employees.

This privacy policy outlines the principles the Children’s Bridge Foundation applies when protecting the personal privacy of members, donors, and employees. We believe that ensuring the accuracy, confidentiality, and security of the personal information we hold is both a legal and ethical obligation.

Scope

This policy applies to The Children’s Bridge Foundation. It outlines the principles and commitments we make to our members, donors, and employees, to protect their personal information.

Definitions

The “Children’s Bridge Foundation” is a Canadian Registered Charity. Our Charitable Registration Number is 895155208.

“Collection” is the act of gathering, acquiring, or obtaining personal information from any source, by any means.

“Consent” involves voluntary agreement with what is being done or proposed. Consent may be expressed in writing, verbally, or tacitly. Implied consent exists when the Foundation can reasonably infer consent based upon the action of the member, donor or employee.

“Member” (for the purposes of this policy) mean anyone who makes use of the services, programs, and activities of The Children’s Bridge Foundation.

“Donor” means anyone who contributes financial or material resources to the work of the Children’s Bridge Foundation.

“Employee” means anyone who contributes their time and talent to the work of the Children’s Bridge Foundation, whether on a paid or voluntary basis. This definition includes a volunteer solely for purposes of this policy and the Personal Information Privacy Act (PIPA) and is not applicable to the definition of employee under any other statute or law or common law or for any other purpose.

“Disclosure” is the act of making personal information available to others.

“Use” is the treatment and handling of personal information by and within the Children’s Bridge Foundation.

“Personal Information” is information about an identifiable individual that is recorded in any form, excluding the person’s name, business title, business address and business phone number.

“Third-Party” is an individual or organization other than the Children’s Bridge Foundation, and its members, donors and employees.


Section 1: The Accountability of the Children’s Bridge Foundation

1.0 The Children’s Bridge Foundation is accountable for the protection of the private information of members, donors, and employees.

1.1 The Children’s Bridge Foundation is committed to ensuring that appropriate security measures are used in the transfer of sensitive private information. When using email or wireless communication, we advise members, donors, and employees that complete confidentiality and security are not assured.

1.2 The Children’s Bridge Foundation is not accountable for any damages suffered when a member, donor, or employee transmits personal information through email or wireless communication, or when the Children’s Bridge Foundation transmits such information at the request of the member, donor, or employee.

1.3 The Children’s Bridge Foundation has developed policies and procedures to: protect personal information; receive and respond to complaints and inquiries; train staff regarding the policies and procedures; communicate the policies and procedures to our members, donors, and employees.


Section 2: Identifying the Purposes of Personal Information

2.0 The Children’s Bridge Foundation will communicate the purposes for which information is being collected, either orally or in writing.

2.1 The Children’s Bridge Foundation collects personal information for the following reasons only:
  • To provide information regarding programs and services.

  • To maintain donor records and issue charitable tax receipts.

  • To maintain adequate stewardship or care for our human and financial resources.

  • To provide services that will meet the needs of our members, donors and employees.

  • To adequately promote the mission and outreach services of our organization.

  • To verify the identity of a member, donor, or employee.



Section 3: Consent from Members, Donors and Employees

3.0 The Children’s Bridge Foundation will obtain consent from members, donors, and employees for the collection, use or disclosure of any personal information except where detailed in this Privacy Policy. We will make reasonable efforts to ensure that members, donors, and employees will understand how their personal information will be used and disclosed.

3.1 The consent of a member, donor, or employee can be written, spoken, or implied. A member can withdraw consent at any time, but such withdrawal may also inconvenience the member, donor, or employee (i.e. charitable tax receipts). If law requires such information, the Children’s Bridge Foundation may decline to deal with a member, donor, or employee who has withdrawn their consent to the required information.


3.2 Consent may be given orally, in writing, or electronically. For example, consent can be expressed over the telephone, though this is only for the most minimally sensitive level of personal information. In other cases, where a form is required to be completed, one might consent by means of a check-off box. In some cases donors may wish to fill in an electronic form indicating consent. It may also be that members and donors are asked for permission to have their home addresses or phone numbers on a list of members or participants in a program

3.3 The Children’s Bridge Foundation may collect, use, or disclose personal information without the member, donor, or employee’s knowledge or consent in the following exceptional circumstances:

  • When such collection, use or disclosure is permitted or required by law.

  • When using such information is required in an emergency that threatens an individual’s life, health, or personal security.

  • When certain information is publicly available.

  • When we require legal advice from a lawyer.

  • When we need to collect a debt from a member, donor, or employee.

  • When we need to deal with an anticipated breach of law.

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Section 4: Limits for Collecting Personal Information

4.0 The Children’s Bridge Foundation will only collect personal information for the purposes identified. We will use methods that are lawful, and will not collect information indiscriminately.

Section 5: Limits for Using, Disclosing and Keeping Personal Information

5.0 Personal information will only be used or disclosed for the purposes for which it was collected. If such information is to be used for additional purposes, we will seek new consent to do so.

5.1 The Children’s Bridge Foundation will not sell membership, or donor lists to Third Parties.

5.2 The Children’s Bridge Foundation may occasionally use membership, or donor lists to conduct surveys in order to provide better programs and services, or to do research for future planning.


Section 6: Accuracy

6.0 The Children’s Bridge Foundation will make reasonable efforts to ensure that any personal information collected is accurate, complete, and current. In most cases, it will rely on the members, donors, and employees to keep certain information current, complete, and accurate.
6.1 Members, donors, and employees may request amendments to the records at the Children’s Bridge Foundation, to ensure the accuracy and completeness of their personal information. If the amendment request pertains to information that remains in dispute, the Children’s Bridge Foundation will note the person’s opinion in the file.


Section 7: Safeguarding Personal Information

7.0 The Children’s Bridge Foundation is committed to the safeguarding of the personal information of members, donors, and employees in order to prevent loss, theft, unauthorized access, disclosure, duplication, use, or modification.

7.1 Depending on the sensitivity of the personal information, the Children’s Bridge Foundation may employ appropriate security measures to protect the information. The measures may include, for example, the physical security of offices, locked filing cabinets, and electronic security measures such as computer passwords.
7.2 The Children’s Bridge Foundation will use appropriate security measures when disposing of personal information, computers no longer in use, and other storage devices. This will, for example, involve the shredding of paper records containing personal information, and the reformatting of computers and storage systems no longer in use.


Section 8: Availability of Policies and Procedures

8.0 The Children’s Bridge Foundation is open about the policies and procedures it uses to protect the personal information of members, donors, and employees. Information about these policies and procedures will be made available in written format in plain language. However to ensure the integrity of our security procedures, we may refuse to publicly disclose certain information.

8.1 The Children’s Bridge Foundation will make the following information available:

  • The name, title, and address of the Privacy Officer who can respond to requests for information on personal information policies and procedures, and to whom complaints or inquiries can be forwarded;

  • A description of the type of personal information held by the Children’s Bridge Foundation, including a general account of its use; and

  • A copy of any brochures or other information that explain the policies and procedures



Section 9: Providing Access to Personal Information

9.0 Members, donors and employees have a right to have access to their personal information held by the Children’s Bridge Foundation. Upon request, the Foundation will, within a reasonable time period, tell the member, donor, or employee what personal information it has, what it is being used for, and to whom it has been disclosed if applicable and within the time period for which records are available.

9.1 Members, donors or employees may be asked to be specific about the information they would like to have access to, and to submit their request in writing to the Privacy Officer of the Children’s Bridge Foundation.

9.2 Members and donors will be required to provide personal information to identify themselves to enable the Children’s Bridge Foundation to provide an account of the existence, use and disclosure of personal information.

9.3 The Children’s Bridge Foundation will make the information available within 30 days, or provide written notice of extension where additional time is required to fulfill the request. The notice of extension note will advise of the new time limit, the reasons for extending the time, and of the right of the member, donor, or employee to make a complaint to the provincial Privacy Commissioner regarding the extension.

9.4 The information will be made available at a reasonable cost that will vary with the type and amount of information requested. If the information is extensive, the Children’s Bridge Foundation will inform the member of the cost, and request further direction from the individual as to whether or not the Children’s Bridge Foundation should proceed with the request.

9.5 If a request for information is refused, the Children’s Bridge Foundation will notify the individual in writing, documenting the reasons for refusal and resources for redress available to the member, donor or employee. These reasons may include that it is unreasonably costly to provide, that the information could threaten the security of another individual, or that it was information generated in a formal dispute resolution process, or that the information contains references to other individuals, or that the information cannot be disclosed for legal or security reasons, or that it is information that is subject to solicitor-client or litigation privilege.

9.6 If the information is demonstrated to be inaccurate or incomplete, the Children’s Bridge Foundation will amend the information as required.


Section 10: Compliance and Complaints

10.0 Members, donors or employees are to direct any complaints, concerns or questions regarding this privacy policy in writing to the Privacy Officer of The Children’s Bridge Foundation. If the Privacy Officer is unable to address the individual’s concerns, the issue can be referred to the executive committee of the Children’s Bridge Foundation Board of Directors. If any of the individuals in these positions are in conflict regarding the individual making the complaint, they should be excused from participation in the appeal committee and the Board of Directors should appoint a substitute. If this appeal process does not resolve the matter, the complainant is always able to write to the Provincial Privacy Commissioner’s office.


Contact Information:

Gerald Yemensky, LLB
Privacy Officer
The Children’s Bridge Foundation
1400 Clyde Avenue, Suite 208
Ottawa, Ontario
K2G4H3
Phone: (613) 727-9698
E-mail: yemensky@magma.ca
Ann Cavoukian, Ph.D.
Commissioner
Information and Privacy Commissioner/Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario
M4W 1A8
Phone: 1-800-387-0073
Fax: (416) 325-9195
Website: http://www.ipc.on.ca


 
 
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