Moorelands Kids is committed to respecting the privacy rights of all individuals by ensuring that their personal information is collected, used and disclosed in an appropriate manner.
Moorelands Kids collects personal information about participants in its programs to be able to communicate effectively with, and provide services to, these participants and the community served by Moorelands Kids. Moorelands Kids collects personal information about donors, sponsors and benefactors. This facilitates communication with such individuals, which in turn enables Moorelands Kids to undertake fundraising to support its programs and services. Moorelands Kids also collects personal information about its employees and volunteers for purposes of personnel management and administration. The Personal Information Protection and Electronic Documents Act (“PIPEDA”) is federal legislation governing the collection, use and disclosure of personal information, amongst other things, which came into effect in Ontario on January 1, 2004. The principals established in the personal information policy of Moorelands Kids correspond to the principals set out in the Canadian Standard Association’s Model Code for the Protection of Personal Information, and conform with the requirements of PIPEDA. Moorelands Kids may review and revise the personal information policy from time to time. In the case of amendment, a notice will be posted on www.Moorelands Kids.ca, or published in appropriate Moorelands Kids’ publications.
APPROVED BY THE BOARD OF DIRECTORS JANUARY 22, 2020
For the purposes of this Policy:
“Personal Information” means any information provided to, or collected by, Moorelands about an identifiable individual including any information about its job applicants, participants, donors, volunteers, employees, contract personnel, committee members and directors.
- PRINCIPLES & PROCEDURES
3.1 PRIVACY PRINCIPLES
The principles established in this Policy correspond to the 10 fair information principles set out in PIPEDA which establish the rules for the collection, use and disclosure of Personal Information, as well as for providing access to Personal Information.
Principle 1: Accountability
Moorelands is responsible for all Personal Information under its control. The Board of Directors (the “Board”) will designate an individual, known as the “Privacy Officer”, who will be accountable for compliance with this Policy. The Executive Director of Moorelands shall be the Privacy Officer.
Moorelands is committed to protecting Personal Information, and accordingly, will include an appropriate level of protection in contractual arrangements with third parties or obtain appropriate assurances from third parties who receive Personal Information from Moorelands.
Moorelands will ensure that all job applicants, participants, donors, volunteers, employees, contract personnel, committee members and directors and any other individual whose Personal Information is in the custody and control of Moorelands have, upon their request, the opportunity to review and update their Personal Information on file with Moorelands. All such persons may direct questions and concerns to the Privacy Officer.
Principle 2: Identifying Purposes
Moorelands will identify the purposes for which it collects, uses and discloses Personal Information.
Common purposes for the collection, use and disclosure of Personal Information include:
i. to maintain complete and accurate files on all participants in its programs;
ii. to maintain complete and accurate files on all donors;
iii. to provide services to the participants in our programs, to communicate effectively with those participants and to communicate and work with third parties providing goods and services to those participants and programs;
iv. to solicit support, both through fundraising efforts and otherwise, from donors and volunteers, and to communicate effectively with such individuals, which enables Moorelands to fulfil its objectives and mandate;
v. to solicit job applications, assess an applicant’s suitability and to process such applications;
vi. to comply with lawful requests from governmental agencies such as Canada Revenue Agency and the Ontario Human Rights Commission; and
vii. to maintain complete and accurate personnel files.
Written notification of such purposes will be communicated by posting this Policy and/or a policy statement on www.Moorelands.ca, by notice published in appropriate Moorelands’ publications, or in such other manner as is feasible in the circumstances.
Moorelands may identify additional purposes for the collection, use and disclosure of Personal Information. Moorelands will communicate such additional purposes by the same methods of notice set out above.
Principle 3 – Consent
Moorelands will obtain the consent of individuals for the collection, use or disclosure of their Personal Information. Moorelands will make every effort to obtain express consent from an individual, although there may be circumstances where Moorelands will determine that implied consent has been given by an individual. Express consent can be given in writing or orally; implied consent will not be in writing, but the circumstances relating to the provision of implied consent shall be such that a reasonable person would conclude that the individual has consented, or would consent, if asked, to the collection, use or disclosure of his or her Personal Information.
There may be situations where consent is given orally, either in person or over the telephone. If Moorelands obtains oral consent from an individual, a note of that consent should be recorded by Moorelands and, if applicable, be included in the file of the participant, donor or other interested individual providing such oral consent.
Moorelands shall include on the application form (whether physical or electronic) for its programs an express statement that the individual signing the form is consenting to the collection, use and disclosure of his or her Personal Information. On any form (whether physical or electronic) used in fundraising, Moorelands shall include a statement that the consent of the individual who completes the form for the collection, use and disclosure of their Personal Information provided on the form may be implied by Moorelands.
The consent of an individual may be withdrawn at any time. Moorelands generally requires such withdrawal to be in writing, but will recognize verbal communication of withdrawal of consent when it is appropriate to do so in the circumstances.
Principle 4 – Limitations on the Collection of Personal Information
Moorelands will only collect Personal Information which is necessary for the purposes which have been identified in this Policy. Personal Information shall be collected by fair and lawful means, and will not be collected for unspecified or improper purposes.
Principle 5 – Limitations on the Use, Disclosure and Retention of Personal Information
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 providing the Personal Information or except where use or disclosure is required or permitted under a legal duty or right.
Moorelands will establish appropriate procedures for the retention and destruction of Personal Information.
Principle 6 – Accuracy
Moorelands will make every reasonable effort to ensure that Personal Information collected by it and under its control will be as accurate, complete and up-to-date as necessary for the purposes for which the information is to be used.
An individual providing Personal Information will have the opportunity to do so in an accurate and complete manner. Moorelands will develop a procedure to enable an individual to update their Personal Information on file, upon request.
Principle 7 – Safeguards
Moorelands maintains adequate procedural and technical security to protect Personal Information under its control and will implement security measures appropriate to the sensitivity of the information.
Moorelands shall ensure that its employees keep all Personal Information confidential and comply with the security standards established by Moorelands.
Moorelands shall require third parties to whom Personal Information is disclosed to commit to an appropriate level of security in respect of such information in compliance with the standards established by Moorelands.
On the disposal or destruction of Personal Information, Moorelands shall take the necessary precautions to prevent third parties from accessing such information and to maintain the confidentiality of such information.
Principle 8 – Openness
Moorelands will make readily available, to any interested individual, this Policy and information about its practices relating to the management of Personal Information. Moorelands will facilitate access to this Policy, and will make available information concerning the identity of its Privacy Officer, and the means by which a person can communicate with the Privacy Officer. Moorelands will also ensure that individuals are given access to their Personal Information.
Principle 9 – Individual Access to Personal Information
An individual providing Personal Information to Moorelands has the right to access such information, and the right to ensure the accuracy and completeness of such information. An individual will be able to address the accuracy and completeness of their Personal Information and have it amended, if inaccurate or incomplete.
Moorelands will respond promptly to any request by an individual for access to their Personal Information.
Moorelands will maintain a complete record of third parties to whom Personal Information has been disclosed, and will make such record available to an individual whose Personal Information has been so disclosed.
Principle 10 – Questions and Concerns Regarding Compliance with this Policy
An individual providing Personal Information to Moorelands may address any question, concern or complaint regarding Moorelands’ compliance with this Policy to the Privacy Officer.
Moorelands will establish a procedure for processing any complaint relating to this Policy to ensure that all complaints are dealt with in an objective, fair and expeditious manner.
- CHANGES TO POLICY
Moorelands may make changes to this Policy from time to time. Any changes to this Policy will be posted on www.moorelands.ca, and will indicate the “last updated” date at top of this Policy and/or will be set out in a privacy statement.