Privacy Policy
Purpose
The Canadian Pride Historical Society (the Society) values its relationship with its volunteers, stakeholders, and contractors, and is committed to protecting their privacy rights. The Society is therefore committed to maintaining the accuracy, confidentiality, and security of their personal information. This privacy policy outlines the Society’s commitment to responsibly collecting, using, disclosing, and safeguarding all personal information entrusted to it.
All volunteers and contractors who may be privy to this information in their work with/for the Society must abide by this Privacy Policy. A violation of the standards set out in this policy constitutes misconduct, and appropriate disciplinary measures will be taken.
The Society is accountable for the protection of all personal information within the Society’s possession or control, including any personal information that has been transferred to a third party for regulatory, legal, or processing purposes. The Society will require a comparable level of protection of this information from its third-party relations.
Application
Consent
If the Society identifies other purposes for which the personal information may be used, the Society will seek the individual's consent prior to such use. The Society will advise that it is the individual's right to refuse permission for the Society to use personal information for any new purposes.
The Society will seek and obtain informed consent before or when it collects, uses, or discloses personal information about an individual. An individual must provide explicit consent to the collection, use, and disclosure of personal information, either in writing or through other verifiable means. The Society has the right to refuse providing a good or service if an individual does not consent to providing their personal information that is required in order for the society to provide said good or service.
Collection
The Society limits the amount and type of personal information it collects to that which is necessary for the business. Personal information will be collected using procedures that are fair, transparent, and lawful.
The information that the Society collects from individuals includes name, address, telephone numbers and email addresses, demographic information, and credit card or banking information as needed. For digital interactions, the Society may collect IP addresses, browser type, and access times to enhance service delivery and security.
The Society will make its policies and practices relating to the protection of personal information available to all volunteers and individuals who conduct business with the Society.
Retention
All personal information will be kept on record for a maximum of three years or when it is no longer needed to provide a good or service, at which point the information will be destroyed. An individual may request that their information be destroyed earlier than three years. The request must be sent to the Society in writing and must indicate in detail what information they wish to have destroyed. Secure disposal methods, such as shredding or permanent deletion, will be used to ensure personal information cannot be reconstructed.
The Society adds the email addresses of donors and all individuals who share their email information with the Society through relevant forms in its contact list, unless donors and individuals specifically request not to be added.
Rights of the individual
An individual may request information about our use of their personal information and any disclosure of that information to persons outside the Society. In addition, they may request a correction of an error or omission in their personal information. Any refusal to provide what has been requested, either partially or in full, must be accompanied by a valid reason. The individual may appeal any information refusal to the Board. The Society will respond to any information request within 21 calendar days, barring exceptional circumstances, which will be communicated to the requester. The Society has the right to charge a fee for an information request, except for when an error is being corrected on personal information.
Rights of donors
The society may collect information from donors through personal information shared on its web platform, forms, donations, interviews, and other such sources. Where possible, such as before oral interviews, the details of the collection, storage, usage, and sharing of such information will be shared with the donors. Donors also retain their right to privacy, and the Society will not publicly acknowledge them unless expressly permitted to do so. However, the Society will disclose donors where required by law, such as to the Canada Revenue Agency.
The society does not share personal data, except where required to do so by law, in accordance with consent provided, or with service providers such as the Society’s banking partner, in accordance with law.
All individuals who are privy to the personal information of donors are subject to confidentiality obligations as stated in the Confidentiality Policy.
Donor information collected to fulfil obligations to donors and comply with regulatory requirements includes:
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The names and addresses of donors in order to issue a charitable tax receipt as required by the Canada Revenue Agency.
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Contact information, such as given phone numbers and email addresses, for communication with the Society.
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Correspondence with donors and instructions for donors regarding donations to the Society.
Privacy Officer
The Society is responsible for the protection of the personal and sensitive information it holds. To this end, the Society has designated a person to fulfill the function of Privacy Officer (PO). The Privacy Officer shall be responsible for, namely:
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Ensuring that applicable legislation is implemented and complied with. Said legislation includes the Personal Information Protection and Electronic Documents Act, and the Canada’s Anti-Spam Legislation (CASL);
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Handling complaints or inquiries from individuals;
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Informing and advising on legal requirements for the protection of personal information;
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Cooperate with the relevant supervisory authority or authorities (i.e. -, the Office of the Privacy Commissioner of Canada, and the Canadian Radio-television and Telecommunications Commission); and
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Regularly reviewing CPHS’s Privacy Policy and personal information protection practices to ensure continued compliance with relevant federal and provincial legislation.
Cybersecurity Protocols
The Society will implement cybersecurity protocols to safeguard digital personal information, including password encryption, regular software updates, and access control measures. Regular training on cybersecurity for volunteers will also be conducted.
Contact
The Privacy Officer shall address any concerns emanating from clients, members, or other individuals in relation to privacy. In addition, the PO will address all requests from individuals pertaining to the access, correction, disposal or otherwise exercise of privacy rights. The Privacy Officer may be contacted at raguilar@cphs.ca.
Breach
In the event of a significant breach, the Privacy Officer must notify affected individuals and relevant authorities within 72 hours, following applicable legislation. As a matter of course, any breaches to the policy shall be addressed by the Progressive Discipline Policy.