This Policy covers our treatment of the personal information we collect from our donors and supporters. In this Policy we will outline the purposes behind our collection and use of donors’ and supporters’ personal information. In addition we will outline our policies concerning the collection, use, distribution and retention of this information. Finally, we will also set out our policies for addressing any concerns or complaints.
REQUESTS TO ADD, CHANGE OR DELETE
If at any time, you wish to add, change or delete your personal information that is retained by our office, please contact our Privacy Officers at:CITY IN FOCUS
2nd Floor – 107 East 3rd Avenue
Vancouver, BC V5T 1C7
Tel. 604- 687-7292
PRINCIPLE 1 – ACCOUNTABILITY
CITY IN FOCUS is responsible for personal information which we collect, use or distribute and any personal information in our custody or under our control. In order to fulfill our responsibility and comply with current legislation:
1.2 We shall make known the names of the Privacy Officers and contact information upon request.
1.5 Our policy is made available to our donors and supporters through our website www.cityinfocus.ca and the office at 2nd Floor – 107 East 3rd Avenue, Vancouver, BC
1.6 In the event that personal information is made available to a contracted third party, we will hold that party responsible to maintain comparable levels of protection of privacy while the information is in their control.
PRINCIPLE 2 – IDENTIFYING PURPOSES
2.1 CITY IN FOCUS is committed to ensuring that the purposes for which personal information is used are identified.
2.2 CITY IN FOCUS will only collect personal information from our donors and supporters that is necessary to fulfill the following purposes:
- To verify identity;
- To identify [donor, supporter] preferences;
- To deliver requested products and services;
- To provide counseling services;
- To contact our [donors, supporters] for fundraising (pledge forms);
- To ensure a high standard of service to our [donors, supporters];
- To meet regulatory requirements;
2.3 CITY IN FOCUS will make these purposes known to individuals at the time that personal information is being collected either orally, electronically or in writing.
2.4 Unless required by law, CITY IN FOCUS will notify and obtain the consent of an individual before using previously collected information for a new purpose.
PRINCIPLE 3 – CONSENT
3.1 CITY IN FOCUS will obtain reasonably informed consent of a donor or supporter to collect, use or disclose personal information except where we are authorized to do so without consent.
3.2 Consent can be provided orally, in writing, electronically or through an authorized representative. We will take reasonable steps to ensure that consent given is clearly understood.
3.3 Consent can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the donor or supporter voluntarily provides personal information for that purpose.
3.4 In general, the use of products and services by a customer, or the acceptance of employment or benefits by an employee, constitutes implied consent for CITY IN FOCUS to collect, use and disclose personal information for all identified purposes.
3.5 Consent may also be implied where a donor or subscriber is given notice and a reasonable opportunity to opt-out of his or her personal information being used for general operation and functioning of CITY IN FOCUS and the donor or supporter does not opt-out.
3.6 Subject to certain exceptions, donors and supporters can withhold or withdraw their consent for CITY IN FOCUS to use their personal information in certain ways.
3.7 A donor or supporter may not be able to withhold consent when withdrawal of consent would frustrate the performance of a legal obligation.
3.8 CITY IN FOCUS will not require consent to the collection and use of information in order to access goods or services unless that information is necessary to fulfill the purpose identified. In a situation where a donor’s or supporter’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 we will explain the consequences of withdrawing consent to assist the donor or supporter in making the decision.
3.9 The following are examples of when we may collect, use or disclose the personal information of a donor or supporter without their consent:
- 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 disclosure is required to comply with a court order;
- When the personal information is available from a public source (e.g. a telephone directory);
- When the personal information is available through observation at a public event to which you attended voluntarily;
- When the collection, use or distribution is necessary to determine your suitability to receive an honour, award or similar benefit;
- When we require legal advice from a lawyer;
- To protect ourselves from fraud
PRINCIPLE 4 – LIMITING COLLECTION
4.1 CITY IN FOCUS shall limit the collection of personal information to the purposes set out in this policy in compliance with our legal obligations.
4.2 CITY IN FOCUS will not collect personal information indiscriminately.
4.3 The purposes for collecting personal information shall be reasonably clear at the time of collection and we will not deceive or mislead our donors and supporters as to why information is being collected.
PRINCIPLE 5 – LIMITING USE, DISCLOSURE AND RETENTION
5.1 CITY IN FOCUS will only use and disclose personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes except where we are authorized to do so (see Principle 3 – Consent).
5.2 CITY IN FOCUS will not use or disclose donor’s or supporter’s personal information for any additional purpose unless we obtain consent to do so.
5.3 CITY IN FOCUS will not sell donor or supporter lists or personal information to other parties without consent.
5.4 CITY IN FOCUS will only retain personal information as long as it is needed for the purposes for which it was collected or consented to. CITY IN FOCUS will maintain reasonable schedules to ensure that personal information is reviewed on an ongoing basis to determine relevance and if retention is required.
5.5 When personal information collected is no longer relevant to its purpose or when it is permitted by law, the CITY IN FOCUS will ensure that it is deleted, destroyed or made anonymous. In general, all personal information shall be deleted, destroyed or made anonymous no later than seven years after the purpose for which it was collected has been completed unless the law requires otherwise.
5.6 If CITY IN FOCUS uses personal information to make a decision that directly affects the donor or supporter we will retain that personal information for at least one year to give the donor or supporter a reasonable opportunity to request access to it.
PRINCIPLE 6 – ACCURACY
6.1 CITY IN FOCUS is committed to ensuring the accuracy of its information and will take reasonable efforts to ensure that personal information is accurate and complete where it is necessary.
6.2 CITY IN FOCUS will update information when it is necessary or when an individual notifies us. Donors or supporters 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. This request should be directed to the Privacy Officers.
PRINCIPLE 7 – SAFEGUARDS
7.1 CITY IN FOCUS is concerned about the safety of our donors’ and supporters’ personal information. In order to address security concerns, we have developed the following safeguards:
- Physical security measures including locked cabinets, restricted access to areas where sensitive personal information is kept, security alarm systems, etc.;
- Organizational security measures including employee confidentiality agreements, sensitive information restricted to those involved, etc.;
- Technological security measures including use of passwords, firewalls and security encryptions
7.2 CITY IN FOCUS shall protect personal information disclosed to third parties by contractual agreement that stipulates the confidentiality and safeguard requirements that are comparable to our own.
7.3 We will use appropriate security measures when destroying personal information such as:
- Shredding any documents;
- Deleting any electronic records
7.4 CITY IN FOCUS will routinely review and update our security measures.
7.5 CITY IN FOCUS shall stress to both employees and volunteers the importance of safeguarding the confidential nature of personal information.
PRINCIPLE 8 – OPENNESS
8.1 CITY IN FOCUS is committed to making its privacy policies and procedures available and clear to all interested parties.
8.3 Any questions or concerns regarding our policy or procedure may be directed in writing to our Privacy Officers.
PRINCIPLE 9 – INDIVIDUAL ACCESS
9.1 Donors and supporters have a right to access their personal information, subject to limited exceptions including, but not limited to:
- Situations where disclosure may reveal the personal information of another individual;
- Situations where the health or safety of an individual may be jeopardized.
9.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought and should be forwarded to the attention of the Privacy Officers. 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. A reasonable fee may be charged for providing access to personal information, in which case we will inform the donor or supporter prior to proceeding.
9.3 We will endeavour to make all information provided easy to understand and explain any acronyms, abbreviations, etc. used.
9.4 We reserve the right to confirm the identity of the individual seeking access to personal information before complying with any access requests. In this event, information related to the donor’s or supporter’s identity would be used exclusively for the purposes of confirming access.
9.5 In certain situations, it may not be possible to provide access to all the personal information that is held and a request may be refused in whole or in part. For example, information may not be provided if to do so would reveal personal information about a third party or jeopardize the security of another.
9.6 If a request is refused in full or in part or if the information requested is not available, we will notify the donor or supporter in writing, providing the reasons for refusal and the recourse available to the donor or supporter. This notification will be kept on file.
9.7 In the event that information provided is shown to be incomplete or inaccurate, we will amend the donor’s or supporter’s personal information appropriately. When appropriate, we will transmit this correction to third parties with access to this information. When a challenge is not resolved to the donor’s or supporter’s satisfaction, we will destroy all personal information under our care and control.
PRINCIPLE 10 – CHALLENGING COMPLIANCE
The Privacy Officers shall receive and respond to all personal information requests including challenges or complaints.
It is CITY IN FOCUS’ policy that all complaints shall be investigated.
If a complaint is found to be justified, the Officers shall take appropriate measures, including, if necessary, amending this Policy.
The Privacy Officers may seek external advice where appropriate before providing a final response to individual complaints.
If the Privacy Officers are the subject of the complaint, the Board of Directors will address any complaints or concerns. If the Privacy Officers are unable to resolve the concern, the donor or supporter may also write to the Information and Privacy Commissioner of British Columbia.
CITY IN FOCUS’ procedure for dealing with complaints is as follows:
- Record the date and nature of a complaint when it is received
- Acknowledge receipt of the complaint promptly
- Review the matter fairly and impartially, providing to the individual where possible, access to all relevant records
- Notify the individual of the outcome of the investigation promptly and clearly
- Correct any inaccurate or incomplete information when possible
We may collect non-personal identification information about website visitors whenever they interact with our site. Non-personal identification information may include the browser name, the type of computer and technical information about website users means of connection to our site, such as the operating system and the Internet service providers utilized and other similar information.
Web browser cookies
How we use collected information
City In Focus collects and uses website user personal information for the following purposes:
To personalize user experience
- We may use information in the aggregate to understand how our Users as a group use the services and resources provided on our Site.
To improve our Site
- We continually strive to improve our website offerings based on the information and feedback we receive from you.
Commitment to Data Security
- Identifying purposes
- Limiting collection
- Limiting use, disclosure, and retention
- Individual access
- Challenging compliance
All directors, officers, associates, employees and volunteers of CITY IN FOCUS are required to comply with the Policy and may be given restricted access to personal information solely to fulfill the purposes as set out in this Policy.
All other persons or organizations who act for, or on behalf of, CITY IN FOCUS are also required to comply with the principles and the Policy and may be given restricted access to personal information solely to fulfill the purposes as set out in this Policy.
Privacy Contact Information
By e-mail: firstname.lastname@example.org
By Phone: 604-687-7292CITY IN FOCUS 2nd Floor -107 East 3rd Avenue Vancouver, BC V5T 1C7 Tel. 604- 687-7292
We reserve the right to make changes to this policy. Any changes to this policy will be posted.
Other Legal Information:
OFFICIAL CHARITABLE STATUS
City in Focus (City in Focus Foundation formerly known as Christian Leaders Foundation) is an official registered charitable organization with Canada Revenue Agency, an incorporated society of the province of British Columbia since November 1988 and in the state of Washington, USA. City in Focus is able to issue official Canadian and US tax receipts.
GOVERNANCE AND CONSULTANTS:
City in Focus is accountable to a Board of Trustees and employs various consultants.
- Board Chair – Alphil Guilaran
- Treasurer/Secretary – Sean Graham
- Auditor – SFH Accounting
- Legal – Alexander Holburn Beaudin & Lang LLP, Vancouver, BC