PRIVACY AND PERSONAL INFORMATION POLICY

This section of the policy sets out the Foundation’s policy on privacy matters, particularly in respect of personal information of donors.

 

Principles

 

At the Foundation the privacy of the personal information of our donors, prospective donors, employees, and other stakeholders has always been an important aspect of how we conduct our business. We value the trust of those with whom we deal as well as with the public at large and we recognize that maintaining this trust requires that we be open and accountable in how we treat information entrusted to us. As a result, the Foundation has developed this policy both to ensure compliance with privacy legislation as well as to inform our stakeholders of our continuing commitment to the protection of their personal information.

All of the Foundation personnel are authorized to access personal information in our files only as required for the conducting of legitimate and appropriate Foundation business. In addition, we have instituted safeguards to ensure that the information retrieved is not disclosed or shared beyond its immediate requirements.

This policy adheres to the federal Personal Information Protection and Electronic Documents Act (PIPEDA).

 

Definition

 

Personal information includes any factual or subjective information, recorded or not, that could be used to distinguish, identify, or contact an individual. This includes information in any form such as personal e-mail address, credit card numbers, home addresses, and so on. It does not include certain publicly available information such as that normally found on a business card, such as name, title, company, business address, business e-mail address, business telephone or fax number. Also not deemed to be personal information are certain publicly available data such as names, addresses, and telephone numbers as published in telephone directories.

 

Practices

 

1. Accountability

The Executive Director of Development or other person so designated by the board shall serve as the Foundation’s Chief Privacy Officer. All employees, volunteers, and members of the Board of the Foundation are required to comply with this Privacy Policy. At times, the Foundation staff may be delegated to act on behalf of the Chief Privacy Officer or to take responsibility for occasional collection, use, and/or disclosure of personal information.

 

1. Declaration of Privacy Responsibilities

During their orientation to their various responsibilities to the Foundation, all individuals who have or may have access to confidential donor information (including personal, fiscal and geographical information) are required to acknowledge that they have read and will agree to adhereto this Policy.

 

1. Identifying Purposes

Before, or at the time of the collection of personal data, the Foundation must identify the purposes for which personal information is being collected. Information collected will be used only for the original purpose for which it was collected, unless required otherwise by law:

1. a) to establish and maintain a responsible relationship with donors;
2. b) to register participants at events in support of the Foundation;
3. c) for purposes identified to individuals or purposes obvious to individuals, in respect of particular collections of personal information;
4. d) to meet legal and regulatory requirements;
5. e) to share information about Grandview Children’s Centre and the Foundation, including but not limited to the Annual Report, event invitations, newsletters, and updates concerning Grandview Children’s Centre and its needs;
6. f) to manage and develop the Foundation’s operations.

 

4: Consent

 

In the collection, use or disclosure of personal information, knowledge and consent of the individual so involved is required. This consent must be meaningful and easily understood. Nonetheless, in certain circumstances, such as an emergency or as required by law, the Foundation may disclose personal information without the interested individual’s knowledge or consent.

 

1. No Publication without Consent

Donor names shall be held in strict confidence, unless a donor consents to the publication of his, her or its name. Requests by a donor for anonymity shall be honoured.

 

1. Grandview Children’s Centre Client and Volunteer Solicitation

The Foundation receives contact information of volunteers and clients and their families from Grandview Children’s Centre. Formal requests from individuals to be excluded from mailings or other communications will be respected and acted on promptly.

 

1. Third Party Use of Personal Information

The Foundation, from time to time, may use third parties to process mailings. This requires sending name and address information, usually segmented into specific gift level categories, to a mail house that addresses, prints, sorts, and co-ordinates distribution of these mailings. In all cases, the third party vendor must sign a confidentiality agreement promising that it will take every precaution to protect personal information in its possession and to destroy it upon completion.

Further, data sent by the Foundation to a third party vendor will be encrypted to ensure protection. The vendor will be required to act likewise in sending data to the Foundation.

 

1. Limiting Collection

Personal information collected is limited to the purpose for which it was collected, except with the consent of the individual and as permitted by law. Should there be an additional use for which the information may be employed, individuals affected must be notified and their concurrence formally secured.

 

1. Limiting Use, Disclosure and Retention

Personal information will be used only for the purpose for which it was collected except with the consent of the individual or as required by law. The Foundation shall retain personal information only as long as necessary for the fulfillment of those original purposes. When personal information is no longer required for the fulfilling of those purposes it will be permanently erased from the electronic records or shredded if it exists in hard copy.

 

1. Accuracy

The Foundation shall take steps to ensure that personal information is accurate, complete, and as up-to-date as possible. To ensure the up-to-date accuracy of the personal information held in the Foundation’s files, it is the responsibility of the donor to advise the Foundation of any changes to their personal information.

 

1. Safeguards

The Foundation shall protect personal information by security safeguards appropriate to the sensitivity of the information and the means by which it is stored.

 

11.1. The Foundation shall establish appropriate safeguards to protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction. Employees shall be made aware of the importance of maintaining the confidentiality of personal information.

 

11.2. The Foundation shall establish appropriate safeguards to protect personal information disclosed to third parties, for example by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

COMPLAINT POLICY

The Foundation is committed to responding in a prompt and respectful manner to any complaints or concerns received from our donors and/or the general public.

 

Definitions

 

Donors include current, past and prospective donors and any individual, company or group with an interest in the work of the Foundation.

General public includes any individual or group from the community at large who has filed an expression of concern.

Complaint includes any received expression of dissatisfaction on the part of an individual, company or group related to the actions of the Foundation.

 

Administration

 

It is expected that the majority of complaints or concerns will be administrative matters that the Executive Director of Development is in a position to address immediately and to the complainant’s satisfaction within the existing systems in place in the Foundation. These may include, among other possibilities, a request to limit the number of solicitations annually, to discontinue solicitations, to correct an address or other contact information, to request that the donor not be solicited by telephone, to request information, or to inquire as to the status of a receipt. The Foundation staff person handling the complaint will ensure that the necessary procedures are followed to address the complaint.

 

As a matter of operational principle, any complaints will be immediately referred to the Executive Director of Development, and, if still unresolved, to the Chair of the Board. In the event that a complainant remains dissatisfied after being referred to the Executive Director of Development, the complainant will be informed that an appeal may be made in writing to the Foundation’s Board of Directors, addressed to the Chair of the Board of the Foundation.

 

In the event of a complaint about or relating to the Executive Director of Development, any such complaint (including if the complaint is made directly to the Executive Director of Development) must be immediately referred to the Foundation Chair.

 

Procedure

 

This procedure provides the guidelines for addressing a complaint to the Foundation.

 

1. An acknowledgement of receipt of the complaint will be made within five business days. The determination of the Foundation will be provided to the complainant in writing within ten business days of the date of the receipt of the written complaint.
2. All contact information required by a complainant to move the complaint to the next level will be provided without prejudice by the Executive Director of Development.
3. Complaints or concerns that are of an administrative matter may be considered events requiring simple quantitative tracking. Complaints of a more substantive nature – including subsequent complaints from the same complainant on the same matter, and complainants not immediately satisfied with the resolution proposed – will be documented in writing and the complainant will have access to such documentation.
4. The Executive Director of Development will provide the Foundation Board of Directors with an annual report of all documented complaints and their outcomes, including, where appropriate, changes to systems or procedures taken to reduce the incidence of similar complaints in the future.

TRANSPARENCY POLICY

The Foundation wishes to adhere to the highest levels of governance in the conduct of its affairs, including the principles of transparency set out in this section of the Policy.

 

Principle

 

To ensure confidence in the Foundation in the pursuit of its objectives, donors have the right to the following.

1. Information regarding the Foundations objectives, methods for obtaining objectives, and the intended use of donated resources in furthering objectives.
2. Assurance that their donations will be used for the stipulated purpose and appropriate confidentiality measures are adopted.
3. Identify those serving on the Foundation Board and the position of individuals seeking donations.
4. Access to the Foundation’s financial statements.

 

Financials

 

The foundation’s financial affairs will be conducted in a responsible manner, consistent with the ethical obligations of stewardship and all applicable law. All donations will be used to support the foundations’ objectives, as registered with CRA. All restricted or designated donations will be used for the purposes for which they were given unless the charity has obtained legal authorization to use them for other purposes.

Annual financial reports are necessary to achieve transparency and accountability to donors and the public. The reports should:

1. Be factual and accurate in all material respects;
2. Disclose the gross amount of fundraising revenues (receipted and non-receipted);
3. Disclose the total amount of fundraising expenses (including salaries and overhead costs);
4. Financial statements should be prepared in accordance with Part III of the Chartered Professional Accountants of Canada Handbook – Accounting, which sets out generally accepted accounting principles for not-for-profit organizations in Canada, in all material respects.

The Finance Committee of the Board of Directors shall be responsible for monitoring and reporting to the Board of Directors with respect to all matters pertaining to the financial integrity of the Foundation.

 

Compensation of the Foundation’s Fundraising Staff

 

The Foundation observes the following compensation practices:

(a) fundraisers who are employed by the Foundation are compensated on the basis of their experience, expertise and the time requirements of the position in light of the current employment market; and

(b) the Foundation does not, directly or indirectly, pay finder’s fees, commissions or other payments based on the number of contributions received or the value of funds raised.