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
United Way is committed to protecting the privacy of all individuals. United Way will collect and use personal information necessary to process donations and payments; to redirect a donation or any part of a donation to another charity as instructed by a donor; to confirm renewal of giving and maintain a donation history; to issue tax receipts; to keep a donor informed about giving opportunities and the work of United Way; to acknowledge and recognize donations and to comply with federal and provincial regulatory guidelines and reporting requirements. Where United Way process donations on behalf of other United Ways, the information collected will be shared with your local United Way for these purposes. United Way appoints a privacy officer to handle all queries and concerns.
This policy outlines United Way of Kingston, Frontenac, Lennox & Addington’s (UWKFLA) commitment to respecting the privacy of personal information of individual persons and explains how UWKFLA collects, uses, protects and discloses personal information. This includes the personal information of donors, prospective donors, board members, volunteers, individuals who engage with us on community initiatives, and our staff.
This policy governs the activities of UWKFLA. UWKFLA is an autonomous organization, legally separate from United Way of Canada and other United Ways. While all United Ways share a commitment and respect for personal information privacy, details on how each United Way does so can be obtained by contacting the United Ways individually.
Our Commitment to Protecting Your Privacy
UWKFLA recognizes a reliance on the support of thousands of individuals who engage in support of their community. It is recognized that information is precious, and supporters trust UWKFLA to treat their information with respect for their privacy and a commitment to protecting the confidentiality of data. It is essential to protect the privacy of the personal information individuals may choose to share with the organization or that may be gathered by other lawful means.
What is Personal Information?
Personal information refers to information about an identifiable individual, but excludes certain business contact information, specifically name, title, business address or telephone number of an employee of an organization. From time to time, UWKFLA may, acting reasonably, collects information about identifiable individuals from published or public sources for the purposes of developing relationships with individuals.
The areas in which UWKFLA collects and uses personal information in accordance with this policy are principally, but not limited to:
UWKFLA’s work to improve social conditions involves working with individuals acting on their own initiative or as representatives of community agencies, governments and other partner organizations that share common social objectives. UWKFLA gathers and uses personal information to keep individuals informed about relevant UWKFLA activities and work, and with permission may share personal information with others who share similar social objectives and a desire for networking.
UWKFLA will collect and use personal information necessary to process donations and payments, redirect a donation or any part of a donation to another charity as instructed by the donor, issue tax receipts, confirm renewal of giving and maintain a donation history, keep donors informed about giving opportunities and the work of UWKFLA, acknowledge and recognize donations, and comply with federal and provincial regulatory guidelines and reporting requirements.
Workplace Campaign Participation
UWKFLA supports organizations who run internal employee giving campaigns. UWKFLA may be provided with employee names, business contact information and other employee-related information in order to provide personalized campaign pledge tools to carry out a workplace campaign. UWKFLA will work with organizations delivering workplace campaigns to determine data needs that ensure an optimal experience for employees and which also meets the organization’s personal data management policies. The data provided to UWKFLA is used only for the purposes of setting up the pledge tools. If the employee chooses to make a donation, UWKFLA will retain personal information provided directly by the donor and any associated workplace employment information required to manage the donation.
In some situations, the workplaces run campaigns that reach beyond employees to include other related individuals such as retirees or contractors. UWKFLA follows the same practices in working with organizations in these situations as with employees.
UWKFLA will collect and use personal information to establish and maintain the volunteer relationship, assist volunteers in performing their volunteering roles and responsibilities, and keep them informed about relevant UWKFLA activities and the work of UWKFLA.
UWKFLA will collect and use personal information necessary to communicate with individuals about events, contests and promotions in which they participate, communication concerning related transactions, information about UWKFLA and other events that they may be interested in, recognize participation and award prizes, and comply with federal and provincial regulatory guidelines and reporting requirements.
UWKFLA collects and uses personal information to establish, maintain, administer and, in some cases, terminate the employment relationship including ongoing obligations regarding benefits, medical history and group RRSPs.
OUR PRIVACY PROCEDURES
The following procedures reflect our pledge to protect the privacy of your personal information:
We are responsible for all personal information in our possession, including any personal information transferred to third parties for handling or administrative purposes.
We collect, use and disclose personal information only for certain purposes that we identify to you. The purposes for which personal information is collected will be identified at the time the information is collected.
With your consent, we collect information about you for various purposes, including the following:
- Establish your identity.
- Administer your involvements with us, including your donations, event participation, community engagements, volunteering, or employment, and contact you about your continued involvement.
- Know who our donors, volunteers and other supporters are in order to manage and develop our resources to fulfill our mission to serve the greater good of the community.
- Respond to your information requests.
- Periodically, as we are able, send you literature on United Way or invite you to events or information sessions that are aligned with your interests.
- Thank you and, with your consent, publicly recognize your financial or non-financial contributions.
- Share information with other individuals or organizations only with your consent, including organizations which you redirect donations to, volunteer at on our behalf, or interact with on our behalf.
- Generate statistics and aggregate reporting to help us and our partner organizations understand where we can have greater impact on the community.
- Meet legal and regulatory requirements.
We obtain personal information about you lawfully and fairly. We collect, use or disclose your personal information with your permission, except where otherwise required or permitted by law.
You may withdraw your permission to the use and disclosure of your personal information at any time. We will comply, subject to legal, contractual or technical restrictions. For example, if you ask to not receive any mail from us, we take steps to suppress donation requests or general information, but we will still mail you a tax receipt for a donation or send you a statement of your outstanding payments against your pledged donation. Due to printing and distribution schedules, you may continue to receive some communications that were in process before we received your request. If there are various options to how we may handle your request, we will explain the options so that you can choose how you wish us to handle your request.
Personal information collected will be limited to that required for the purposes identified by us.
Limiting Use, Disclosure and Retention
We use your information for the purposes identified to you. When we intend to use your personal information for a purpose not identified to you when the information was collected, we will identify the new purpose and obtain your permission prior to use.
We do not sell your personal information.
We disclose your personal information in the following circumstances:
- We collect and use personal information to process donations and payments, issue tax receipts, confirm renewal of giving, maintain a donation history, keep donors informed about giving opportunities and our work, acknowledge, recognize and thank donors, and comply with federal and provincial regulatory guidelines and reporting requirements.
- UWKFLA is respectful of the donor’s right to privacy and works with the individuals responsible for employee campaigns to limit with whom we share the information, and to only share information necessary for the purposes of the campaign. United Way respects and works within the requirements of your organization’s internal policies on access and use of employee personal information.
- We share information with other United Ways for donations designated to another United Way community. We disclose your information only to the specific United Way involved in your donation.
- In all other situations, we will disclose your personal information only with your consent, or as otherwise required or permitted by law.
We will keep your personal information only as long as it is necessary to satisfy the purposes for which it was obtained, or as required by law. We have guidelines and procedures for the retention and destruction of personal information. When we destroy personal information, we will use safeguards to prevent unauthorized parties from gaining access to that information during the process.
We maintain appropriate procedures to ensure that personal information in our possession is as accurate and up to date as is necessary for the purposes for which it is to be used. We rely on you to provide us with any changes to your personal information, and in particular to your contact information.
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. If your personal information is inaccurate or incomplete, we will make the necessary changes.
We maintain appropriate technical and organizational safeguards to protect your personal information against loss, theft, unauthorized access, disclosure, copying, use or modification.
Access to your personal information is restricted to UWKFLA employees, agents and authorized service providers who need the information to fulfill the purpose for which the information was collected. UWKFLA will protect your personal information by safeguards that are appropriate to the sensitivity of that information and the format of the information, whether electronic or physical.
Our procedures include physical security measures, organizational measures including security clearances and limiting access on a “need-to-know” basis, and technological measures such as the use of passwords and encryption. When it comes to the handling of electronic records, UWKFLA adheres to Payment Card Industry Data Security Standards (PCI DSS).
You may ask whether we hold any personal information about you, see your information and ensure that it is accurate. UWKFLA may ask that you submit your request in writing. UWKFLA will need to confirm your identity prior to disclosing any information to you as a result of your request.
You also have the right to know how we collected your personal information and how we are using it. We will inform you of the specifics to the best of our abilities.
You may register a privacy-related complaint by emailing UWKFLA’s Privacy Officer. We will investigate all complaints. If an objection is justified, we will take all appropriate steps to repair the situation, including reviewing and changing our policies and practices if necessary.
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.