The Canadian CED Network is a national charitable organization. This Personal Information Protection Policy has been developed in compliance with Federal Legislation, the Personal Information Protection and Electronic Documents Act (PIPEDA), and the Personal Information Protection Act for the province of British Columbia.
Introduction
The Canadian CED Network is a charitable, not-for-profit association made up of members (organizationsand individual practitioners) who support and participate in its work and vision to build just, sustainable and inclusive communities. The Network does not engage in commercial activity as defined by the Federal Personal Information Protection and Electronic Documents Act and is not therefore subject to its provisions.
However, as a national association, the Network has voluntarily opted to create its own Personal Information Protection Policy that is in compliance with Federal legislation . In addition, because our national office is located in British Columbia , the Network has ensured that this policy is in compliance with the Personal Information Protection Act (PIPA) for that Province. That legislation does apply to non profit societies.
The Canadian CED Network is committed to providing our customers/members with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our customers/members, protecting their personal information is one of our highest priorities. While we have always respected our customers/members privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of the Federal Personal Information Protection and Electronic Documents Act (PIPEDA) and the Province of British Columbia ‘s Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004 , sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information. We will inform our customers/members of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances. This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting customers’/members’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our customers’/members’ personal information and allowing our customers/members to request access to, and correction of, their personal information. The main ways in which the Network collects, uses and discloses personal and/or contact information is:
- Through our membership database by which we record the personal or contact information of members to:
- verify their identity and status as members in good standing for participation in the Annual General Meeting
- provide information on Network events, activities, services, and other news
- process the information to the publisher of Making Waves , the journal on CED that is included in the membership fee
- contact members by phone to advise them of upcoming events
- survey members on CED issues and Network services
- solicit charitable donations and membership renewals
- Through our customer database of those who have participated in, or requested information on, Network services, activities and events but not become paying members. We use the personal and/or contact information in the customer database to:
- Provide information on Network events, activities, services and other news
- Solicit membership, donations and participation in Network events
- Survey people on CED issues and Network services
- Through our online directory of CED organizations which people use voluntarily to provide information on their organization to the public through an online entry form on our website. Members/customers of the Network may opt out at any time from receiving information/contact from the Network, and may verify/correct their information at any time. The Network does not sell or barter any personal information in its possession.
Definitions
Personal Information – means information, such as home address and phone number, 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 by the Board of Directors as having responsibility for
ensuring that the Canadian CED Network complies with this policy. At this time the Board has designated the Executive Director. The Privacy Officer manages implementation of this policy in:
- Information management practices, policies and procedures;
- Staff training
- Customer relations
- Policies and procedures
- Inquiry and complaint processes (including requests for access to and correction of personal information and general issues concerning personal information).
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and the customer/member 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 customer/member information that is necessary to fulfill the following purposes:
- To verify identity, we may collect name, home address and home telephone number
- To identify customer/member preferences;
- To open and manage an account;
- To deliver requested products and services
- To guarantee a travel or hotel reservation;
- To process Making Waves magazine subscriptions;
- To send out association information
- To survey members/customers on current issues;
- To contact our customers/members for fundraising;
- To ensure a high standard of service to our customers/members;
- To meet regulatory requirements;
Policy 2 – Consent
2.1 We will obtain customer/member 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 (orally, in writing, electronically, through an authorized representative) or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the customer/member voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a customer/member 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 customer/member 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), customers/members can withhold or withdraw their consent for the Canadian CED Network to use their personal information in certain ways. A customer’s/member’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 customer/member in making the decision.
2.5 We may collect, use or disclose personal information without the customer/member’s knowledge or consent in the following limited circumstances:
- When the collection, use or disclosure of personal information is permitted or required by law;
- In an emergency that threatens an individual’s life, health, or personal security;
- When the personal information is available from a public source (e.g. the CCEDNet Online Directory);
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt;
- To protect ourselves from 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 customer/member 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 verify their identity and status as members in good standing for participation in the Annual General Meeting
- To provide information on Network events, activities, services, and other news
- To process the information to the publisher of Making Waves, the journal on CED that is included in the membership fee
- To contact members/customers by phone to advise them of upcoming events
- To survey members/customers on CED issues and Network services
- To solicit charitable donations and membership subscriptions
3.2 We will not use or disclose customer/member personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell customer/member lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use customer/member personal information to make a decision that directly affects the customer/member, we will retain that personal information for at least one year so that the customer/member has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain customer/member 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 customer/member personal information is accurate and complete where it may be used to make a decision about the customer/member or disclosed to another organization.
5.2 Customers/members 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. A request to correct personal information should be forwarded to the Executive Director (for contact information please see end of document).
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 customers’/members’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of customer/member personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that customer/member personal information is appropriately protected: physically securing main headquarters office where personal information is held; the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access); contractually requiring any service providers to provide comparable security measures.
6.3 We will use appropriate security measures when destroying customers’/members’ personal information such as shredding documents, 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 Customers/Members Access to Personal Information
7.1 Customers/members have a right to access their personal information.
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought.
7.3 Upon request, we will also tell customers/members 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 If a request is refused in full or in part, we will notify the customer/member in writing, providing the reasons for refusal and the recourse available to the customer/member.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Executive Director is responsible for ensuring the Canadian CED Network compliance with this policy and the Personal Information Protection Act.
8.2 Customers/members should direct any complaints, concerns or questions regarding Canadian CED Network compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the customer/member may also write to the Information and Privacy Commissioner of British Columbia.
Privacy Officer of the Canadian CED Network
Michael Toye
Executive Director, The Canadian CED Network
59, rue Monfette, CP 119E
Victoriaville, QC G6P 1J8
Tel.: (819) 795-3056 Fax: (819) 758-2906
e-mail: mtoye at ccednet-rcdec.ca