United Way of KFL&A
417 Bagot Street
Kingston, ON K7K 3C1
Tel (613) 542-2674 ext 1102
United Way of Kingston, Frontenac, Lennox & Addington is committed to protecting the privacy of the personal information of its donors, members, employees, and other stakeholders. We value the trust of those with whom we deal with, and of the public, and recognize that maintaining this trust requires that we be transparent and accountable in how we treat the information that you share with us.
During the course of our various projects and activities, we frequently gather and use personal information. People from whom we collect such information expect that it will be carefully protected and that any use of this information is subject to consent. Our privacy practices are designed to achieve this.
Personal information is any information that can be used to distinguish, identify or contact a specific individual, except business information and publicly available information. We maintain appropriate procedures to ensure that personal information in our possession is accurate and up to date.
You are entitled to seek a correction of your personal information if you believe that the information in our possession is not correct. If you believe any of the information we have collected about you is incorrect or incomplete, you have the right to ask us to change it or delete it.
United Way of Kingston, Frontenac, Lennox & Addington is committed to protecting your privacy. We take every step to ensure the confidentiality of your information is maintained. The information you or your employer provides to us is used to help us in our campaign, process and receipt your donation and respond to any of your information requests.
Whether you are a donor to our workplace campaign or donate directly as an individual, your information is not shared with other organizations.
Additionally, in the following areas, we do not share any personal information:
- Designation – where a portion of your gift is directed to another United Way or another charity, we may provide the amount of your donation. We do not provide your name or personal information to another organization.
- Leadership/Friends of the Way Donors – United Way may publicly recognize Leadership/Friends of the Way donor names. If you prefer to remain anonymous, please indicate this in the box provided on your pledge form.
We adhere to the following ten principles:
- Accountability – Responsible for the personal information under its control and shall designate an individual who is responsible for the organization’s compliance.
- Identify Purposes – The purposes for which the information is collected should be identified on or at the time of collection of the information.
- Consent – The knowledge and consent of the individual is required for collection, use or disclosure of personal information in a commercial activity.
- Limiting Collection – Information is to be collected for specific purposes and can only be used for those purposes.
- Limiting Use, Disclosure & Retention of Personal Information – Personal Information can only be used, disclosed and retained for the purposes for which it was collected.
- Accuracy – Personal information shall be accurate, complete and up to date.
- Safeguards – Protect personal information against loss or theft as well as unauthorized access, disclosure, copying, use or modification.
- Openness – Privacy policies must be made readily available to anyone.
- Individual Access – Have the right to know what personal information about them has been collected, how it is being used, to whom it has been disclosed, to challenge the accuracy and completeness and have it corrected.
- Challenging Compliance – Individuals should be able to address any challenges concerning compliance to the designated individual in the organization who is accountable for the organization’s compliance.
Canada Anti Spam Legislation
As of July 1, 2014 Canada’s Anti-Spam Legislation (CASL) http://www.crtc.gc.ca/eng/casl-lcap.htm came into effect. The CASL imposes new requirements for ‘commercial electronic messages (CEMs)’. One of the new requirements is to have the express or implied consent from any recipients.
Not-for-Profit Charity Exemptions
Under section 3(g) of the Governor-in-Council Regulations (GiC) for CEMs sent by or on behalf of a registered charity, as defined under the Income Tax Act, where the primary purpose of the CEMs is to raise funds for the charity are exempt for the purpose of the CASL.
Examples of CEMs where the primary purpose is raising funds can include (but are not limited to), event notification emails to purchase tickets where the proceeds from the ticket sales flow to the registered charity, newsletters sent by a registered charity which provides information about the charities activities or an upcoming campaign (while not containing any information that encourages the recipient to participate in a commercial activity).
An existing non-business relationship, as defined under CASL, is created when a person makes a donation or gift to the registered charity, or performs volunteer work or attends a meeting organized by the charity. A registered charity would have implied consent to send CEMs [where the primary purpose is not to raise funds for the charity] to this person for two years following the event that starts the relationship (e.g. gift or donation made).
Also, under the section 66 transitional provision, consent to send CEMs is implied for a period of 36months beginning July 1, 2014, where there is an existing business or non-business relationship that includes the communication of CEMs. During the transitional period, the definition of existing non-
business relationship is not subject to the limitation period of 2 years mentioned above. Note however, that this three-year period of implied consent will end if the recipient indicates that they no longer consent to receiving CEMs.
United Way of Kingston, Frontenac, Lennox & Addington
To comply with CASL, the United Way will
- Ensure that we offer an “unsubscribe” feature for all newsletters
- Ask for consent if there is any commercial promotion, not related to fundraising
- United Way will only send CEMS to participants going back two years as per the implied consent section outlined above for event Friends and Next Gen events)
Imagine Canada has played a leadership role in working with the CRTC to provide guidance to Canadian charities on understanding the regulations and their requirements. For information on those guidelines, please visit CRTC releases anti-spam guidance for charities.