Scope of this Policy
This Policy sets out the principles that will be observed by Covenant House Vancouver (hereinafter “CHV”) with respect to the collection, use and disclosure of information about any identifiable individual who is or was a donor, prospective donor, or client.
Definitions for terms in this policy
For the purposes of this policy:
- CHV means Covenant House Vancouver.
- CHV Services include, but are not limited to, providing clothing, counselling, education, food, housing, medical attention, shelter and vocational services to youth who are homeless, trafficked or at risk.
- Collect (personal information) – To gather, receive, or obtain personal information from any source outside CHV, by any means.
- Client – A person who uses, or applies to use, CHV products or services.
- Disclose (personal information) – To make known or reveal personal information by any means.
- Donor – An individual who has in the past or may in the future make donations to CHV.
- Personal information – Means any information about an identifiable individual, except the individual’s name, business address, business phone number and business email address, and includes, but is not limited to, the individual’s address, birth date, gender, employment, bank account number, credit card number, donation history, or other financial information. In addition, personal client information may also include, but is not limited to, demographic information, health-related information, services accessed, supports received, and meetings with support staff. With respect to any specific individual, CHV may or may not have personal information within these enumerated categories.
- Third party – A person, organization or association other than CHV or an employee of CHV or a volunteer working at CHV.
- Use (personal information) – To review, access, employ or apply personal information for any purpose by and within CHV.
Principle 1: CHV’s accountability
CHV is responsible for all personal information under its control. Its Privacy Officer is accountable for CHV’s compliance with the principles described in this Policy.
The CHV Privacy Officer may be contacted at:
Covenant House Vancouver
Attention: Privacy Officer
1280 Seymour St
Vancouver, BC V6B 3N9
Telephone: (604) 685-5437
Facsimile: (604) 685-5324
Under this Principle, CHV is responsible for personal information in its physical possession or custody, as well as for personal information that is transferred by CHV to a third party for processing. CHV will use contracts with such third parties to require them to give an appropriate level of protection to the personal information while it is being processed.
CHV has established and implemented:
- policies and procedures to protect personal information;
- policies and procedures to receive and respond to complaints and inquiries;
- staff training and information programs to explain this Policy and related privacy policies and practices; and
- practices to ensure that clients and other individuals who contact CHV have access to this policy.
Principle 2: Identifying purposes
The purposes for which personal information is collected will be identified and documented by CHV at or before the time the information is collected.
Depending on the specific circumstances, CHV may collect personal information concerning donors for one or more of the following purposes:
- to administer and maintain accounts relating to donations;
- to facilitate fundraising in order to provide CHV services;
- to communicate with donors and potential donors concerning CHV and CHV services;
- to comply with legal and regulatory requirements; and
- to trade or rent fundraising or donor lists.
CHV may collect personal information about donors in a number of ways, including:
- personal communications with the donor effected by a Board member, volunteer or employee;
- accessing information which is publicly available;
- accessing information on a donor list created or maintained by another charitable organization;
- renting a mailing list created or maintained by another organization;
- exchanging mailing lists with other registered charities;
- internet research;
- responses to post office mailings;
- responses to newspaper inserts and mail drops;
- receipt of information about memorials, pledges, bequests concerning CHV;
- communications from tax, estate and investment planners; and
- information generated by third party events such as social functions, entertainment, contests and the like.
CHV may collect personal information concerning youth for one or more of the following purposes:
- Identify the youth and assess if they meet the requirements for programs and services;
- Provide quality programs and effective individualized and youth-focused services to the youth;
- Register youth in the Program Services database;
- Provide information to other organizations and/or individuals with the express consent of the youth (such as referral for services);
- Evaluate CHV services and conduct research to better understand the issues impacting the youth and improve services.
Circumstances might arise where CHV wishes to collect or use personal information for a new purpose. If that occurs, CHV will take reasonable steps to ensure that the individual concerned is informed of the new purpose and gives their consent to the collection or use of personal information for that purpose.
Principle 3: Consent
The knowledge and consent of the individual, express or implied, are required for the collection, use or disclosure of personal information by CHV, except where inappropriate.
Except when the under-noted limited exceptions apply, CHV will obtain the express consent of the individual for the purposes for which their personal information will be collected, used or disclosed. CHV will state the purposes in a form that the individual can reasonably be expected to understand.
Based on past donation history CHV may use personal information to contact donors in a number of ways, including the following:
- personal communications with donors by a Board member, volunteer or employee;
- direct mailings to donors with newsletters, requests for donations;
- direct mailings to prospective donors;
- contacting donors by telephone/e-mail to thank them for their donation;
- contacting donors by telephone/e-mail to conduct donor research; and
- trading or renting donor or other fundraising lists
All of which are intended to advance the objectives of CHV by encouraging individuals to make donations to support CHV services.
CHV staff involved in obtaining the consent of individuals to the collection, use or disclosure of their personal information will be appropriately trained with respect to this policy.
Withdrawal of consent
An individual may withdraw their consent to collection, use or disclosure at any time, subject to legal or contractual restrictions and reasonable notice. CHV will inform the individual of the implications of such withdrawal of consent.
In appropriate circumstances, CHV will seek individual consent to the collection, use and disclosure of personal information by notifying individuals that they will be deemed to consent unless they expressly inform CHV to the contrary. CHV will ensure the individual is entitled to use a convenient method for such notification to CHV, including email, voicemail and other communication facilities that enable the client to communicate on a 24-hour basis with CHV.
Whatever mechanism is employed by CHV to seek express consent, it will fairly and reasonably draw the individual’s attention to the issue of consent.
Disclosure to service providers and other third parties
CHV may transfer personal information to a third party for processing. In that regard, CHV will ensure such party will provide a comparable level of protection while the information is being processed by such party. This includes any trading or rental of fundraising or donor lists.
In circumstances where the individual’s consent is not required, CHV may lawfully collect and use personal information without the knowledge or consent of the individual where:
- collection of the personal information is clearly in the interests of the individual and consent cannot be obtained in a timely way;
- it is reasonable to expect that collection of the personal information with the knowledge or consent of the individual would compromise the availability or accuracy of the information and the collection is reasonable for purposes of an investigation or a proceeding;
- the information is already publicly available and specified in the regulations;
- the collection is required or authorized by law.
With respect to disclosure of personal information without express or implied consent, CHV, as permitted by law, may disclose personal information without the knowledge or consent of the individual if such disclosure:
- is required by or allowed for without consent by a treaty and the treaty is made under an Act or Regulation of British Columbia or Canada;
- is necessary to comply with a subpoena, warrant or order by a court or other agency with jurisdiction to compel the production of personal information;
- is to a public body or a law enforcement agency in Canada to assist an investigation of an offence under the laws of Canada or a province of Canada, for example, WorkSafe BC;
- is disclosed to respond to an emergency that threatens the health or safety of an individual or the public, as long as the individual is notified of the disclosure, such as mailing to their last known address;
- is needed to contact next of kin or a friend of an injured, ill or deceased individual;
- is to a lawyer representing CHV;
- is to an archival institution if the collection of the personal information is reasonable for research or archival purposes.
CHV will notify an individual that a subpoena, warrant or court order for the production of their personal information has been received, if the law allows it. It may notify clients by telephone or by letter to the client’s last known address.
Principle 4: Limiting collection
CHV will limit the amount and type of personal information collected to that which is necessary for the purposes identified by CHV.
Although CHV will collect personal information primarily from the individuals concerned, with the individual’s consent, CHV may also collect donor information from external sources such as other charities or other organizations which create or develop mailing lists, or as otherwise indicated in Principle 2 above. If personal information is collected from a third party, CHV will note their identity unless there is a lawful reason for not doing so.
CHV will collect personal information about youth primarily from the youth or authorized representative. Staff will not collect information about youth that was gathered outside of their performance of CHV duties. Internet searches for information about youth will only occur with express authorization from the directors of Program Services.
Principle 5: Limiting use, disclosure and retention
CHV will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes.
Personal information used by CHV to make a decision that directly affects an individual will be retained for at least one year after using it to allow the individual to have a reasonable opportunity to obtain access to the information.
CHV will retain personal information only as long as necessary for the identified purposes and for legal or business purposes.
CHV specifies in its policies and procedures the shortest and longest periods of time it will keep personal information. Some of these time periods may be determined by legislation.
CHV will destroy, return or make anonymous, any personal information no longer needed for its identified purposes or for legal requirements.
Principle 6: Accuracy
CHV will keep personal information as accurate and complete as is necessary for the purposes for which it is to be used.
CHV will generally rely on individuals to provide updated information, such as changes to addresses and other contact information. CHV will update personal information as is necessary to fulfill the purposes for which the information was collected.
If an individual successfully demonstrates to CHV that personal information is inaccurate, incomplete, out of date or irrelevant, CHV will revise the personal information. If necessary, CHV will disclose the revised personal information to third parties which were provided with inaccurate or out-of-date information to permit them to revise their records as well. Where CHV disagrees with making the requested correction, CHV will annotate the personal information with the correction that was requested but not made.
Principle 7: Safeguards
CHV will make reasonable security arrangements to protect personal information.
Security arrangements are employed to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, modification, or disposal. CHV shall protect personal information regardless of the format in which it is held.
The nature of CHV’s safeguards will vary depending on the sensitivity of the personal information that has been collected, the amount, distribution and format of the information, and the method of storage. The more sensitive personal information will be safeguarded at a higher level of protection.
The methods of protection employed by CHV will include:
- physical measures, including locked filing cabinets and restricted access to offices
- organizational measures, such as security clearances and limiting access on a “need to know” basis
- technological measures, such as the use of passwords, multifactor authentication and encryption
All staff and volunteers will be required to conform to CHV’s policies and procedures concerning the security of personal information.
When CHV discloses personal information to third parties, CHV will ensure that these third parties have sufficient safeguards for all personal information in a way that is satisfactory according to CHV’s policies and which complies with PIPA.
Principle 8: Openness
CHV will be open about its policies and procedures with respect to management of personal information. CHV will ensure individuals are able to acquire information about CHV’s policies and procedures without unreasonable effort. CHV will make this information available in a form that is generally understandable.
The information made available by CHV will include:
- the name of the Privacy Officer and contact information; and
- the means of gaining access to personal information held by CHV.
If you would like access to a copy of our Privacy Policies, please visit our website or contact our Privacy Officer at email@example.com.
Principle 9: Individual access
Upon a request in writing, CHV will confirm the requestors identity and will inform an individual of the existence, use, and disclosure of their personal information. The individual will be notified about whether they will be given access to all or part of their personal information, and where, when, and how it will be given, except where the law requires or permits CHV to deny access.
A request for access by an individual to their personal information will be made in writing.
CHV will assist any individual who informs CHV that they need assistance in preparing such a written request to CHV.
CHV may require the individual to provide sufficient information to permit CHV, with a reasonable effort, to provide an account of the existence, use, and disclosure of personal information. The information provided by the individual in response to CHV’s request will be used only for this purpose.
CHV will respond to a request within 30 days after receipt of the written request. CHV may extend the time limit for an additional maximum of 30 days if:
- meeting the time limit would unreasonably interfere with the activities of CHV, or
- the time required to undertake any consultations necessary to respond to the request would make the time limit impractical to meet, or
- an individual does not give enough information to allow CHV to find the requested personal information or document.
If deemed necessary, CHV may request the BC Privacy Commissioner to approve an extension beyond 30 days to respond to the request.
In any of the above cases, CHV will, no later than 30 days after the date of the request, send a notice of extension to the individual, advising them of the new time limit and the reasons for extending the time limit.
CHV may respond to an individual’s request at a cost to the individual if CHV informs the individual of the estimate of the fee in advance.
Where CHV responds by refusing a request, CHV will inform the individual in writing of the refusal and setting out the reasons. The individual may challenge CHV’s decision.
An individual may challenge the accuracy and completeness of the personal information collected, used, or disclosed by CHV about that individual as outlined in Principle 6.
For the reasons outlined in PIPA, CHV may deny access by an individual to their personal information.
Where CHV is entitled to withhold access to personal information, and that information is severable from other information for which access is requested, CHV will provide access to the personal information after severing such information.
CHV will not record in a donor’s individual file when personal information was disclosed to government agencies as required by law; for example, reporting to Canada Customs and Revenue Agency.
Principle 10: Challenging compliance
An individual will be able to direct a challenge concerning compliance with the above principles to the designated individual or individuals accountable for CHV’s compliance.
The individual accountable for CHV’s compliance is the Privacy Officer.
CHV will investigate all complaints made to it in writing. If CHV’s investigation determines that a complaint is justified, CHV will take appropriate measures, including, if necessary, amending its policies and practices.
Questions regarding privacy at CHV, as well as any questions or concerns regarding CHV’s compliance with this policy, may be directed to the Privacy Officer at firstname.lastname@example.org.