Lakeside Church – Haliburton, hear after referred to as LCH, is a not-for-profit religious organization with a volunteer board of directors whose purpose is to:
- To preach and advance the teachings of the Christian faith and the
religious tenets, doctrines, observances and culture associated with that faith.
- To establish and maintain and support a house of worship with services conducted in accordance with the tenets and doctrines of the Christian faith.
- To support and maintain missions and missionaries in order to propagate the Christian faith.
- To establish and maintain a religious school of instruction for children, youth and adults.
1.1 The Ten Principles of PIPEDA Summarized
- Accountability: organizations are accountable for the personal information they collect, use, retain and disclose in the course of their activities, including, but not limited to, the appointment of a Chief Privacy Officer;
- Identifying Purposes: organizations are to explain the purposes for which the information is being used at the time of collection and can only be used for those purposes;
- Consent: organizations must obtain an Individual’s express or implied consent when they collect, use, or disclose the individual’s personal information;
- Limiting Collection: the collection of personal information must be limited to only the amount and type that is reasonably necessary for the identified purposes;
- Limiting Use, Disclosure and Retention: personal information must be used for only the identified purposes, and must not be disclosed to third parties unless the Individual consents to the alternative use or disclosure, or as required by law
- Accuracy: organizations are required to keep personal information in active files accurate and up-to-date;
- Safeguards: organizations are to use physical, organizational, and technological safeguards to protect personal information from unauthorized access or disclosure.
- Openness: organizations must inform their donors and members and train their employees about their privacy policies and procedures;
- Individual Access: an individual has a right to access personal information held by an organization and to challenge its accuracy if need be; and
- Provide Recourse: organizations are to inform donors, members and employees of how to bring a request for access, or complaint, to the Chief Privacy Officer, and respond promptly to a request or complaint by the individual.
“Personal information” means any information about an identifiable individual. It may include without limitation, information relating to identity, nationality, age, gender, address, telephone number, e-mail address, date of birth, marital status, education, skills, and donations as well as certain personal opinions or views of an Individual.
“Business information” means business name, business address, business telephone number, name(s) of owner(s), officer(s) and director(s), job titles, business registration numbers (GST, HST and source deductions). Although business information is not subject to PIPEDA, confidentiality of business information will be treated with the same security measures by LCH staff, members and Board members, as is required for individual personal information under PIPEDA.
“Individual” means any person who provides personal information to LCH in the process of volunteering, donating or becoming a member of LCH.
“Member” means a person who has completed membership requirements and is in good standing with LCH
“Application” means an application form or related forms completed by the individual(s) to become member or volunteer with LCH.
“Data base” means the list of names, addresses, telephone numbers and related information of individuals held by LCH in the forms of, but not limited to, computer files, paper files, and files on computer hard-drives.
“File” means the information collected in the course of processing an application, as well as information collected/updated to maintain /service the account.
“Express consent” means the individual signs the application, or other forms containing personal information, authorizing LCH to collect, use, and disclose the individual’s personal information for the purposes set out in the application and/or forms.
“Implied Consent” means the organization may assume that the individual consents to the information being used, retained and disclosed for the original purposes, unless notified by the individual.
“Third Party” means a person or company that provides services to LCH in support of the programs, benefits, and other services offered by LCH, such as other lenders, credit bureaus, persons with whom the individual does business, but does not include any Government office or department to whom LCH reports in the delivery of such programs, benefits or services.
Personal information is collected in order to track volunteers and their skills, track donations, provide receipts and communicate information. The individual is the main source of information but LCH may also ask to obtain information directly from a third source where the individual does not have the required information. Only that information which is required for these purposes will be collected.
An individual’s express, written consent will be obtained before or at the time of collecting personal information. The purposes for the collection, use or disclosure of the personal information will be provided to the individual at the time of seeking his or her consent. Once consent is obtained from the individual to use his or her information for those purposes, LCH has the individual’s implied consent to collect or receive any supplementary information that is necessary to fulfil the same purposes. Express consent will also be obtained if, or when, a new use is identified.
An individual can choose not to provide some or all of the personal information at any time.
An individual can withdraw consent to LCH’s use of personal information at any time by making such request in writing.
5.1 Use of Personal Information
Personal information will be used for only those purposes to which the individual has consented with the following exceptions, as permitted under PIPEDA:
LCH will use personal information without the individual’s consent, where:
- the organization has reasonable grounds to believe the information could be useful when investigating a contravention of a federal, provincial or foreign law and the information is used for that investigation;
- an emergency exists that threatens an individual’s life, health or security;
- the information is for statistical study or research;
- the information is publicly available;
- the use is clearly in the individual’s interest, and consent is not available in a timely way;
- knowledge and consent would compromise the availability or accuracy of the information, and
- collection is required to investigate a breach of an agreement.
5.2 Disclosure and Transfer of Personal Information
Personal information will be disclosed to only those LCH employees, members of LCH committees, and the Board of Directors that need to know the information for the purposes of their work.
Personal information will only be disclosed to third parties with the individual’s knowledge and consent.
PIPEDA permits LC to disclose personal information to third parties, without an individual’s knowledge and consent, to:
- a lawyer representing LCH;
- collect a debt owed to LCH by the individual;
- comply with a subpoena, a warrant or an order made by a court or other body with appropriate jurisdiction;
- a law enforcement agency in the process of a civil or criminal investigation;
- a government agency or department requesting the information; or,
- as required by law.
PIPEDA permits LCH to transfer personal information to a third party, without the individual’s knowledge or consent, if the transfer is simply for processing purposes and the third party only uses the information for the purposes for which it was transferred. LCH will ensure, by contractual or other means that the third party protects the information and uses it only for the purposes for which it was transferred.
Personal information will be retained in files as long as the file is active and for such periods of time as may be prescribed by applicable laws and regulations.
A file will be deemed inactive if the individual requests removal or is deceased or has ceased to become a member and is inactive for 2 years
LCH endeavours to ensure that any personal information provided by the individual in his or her active file(s) is accurate, current and complete as is necessary to fulfill the purposes for which the information has been collected, used, retained and disclosed. Individuals are requested to notify LCH of any change in personal or business information.
Information contained in inactive files is not updated.
Organizational Safeguards: Access to personal information will be limited to Members of the LCH committee(s) and/or Board of Directors, who are not permitted to copy or retain any personal information on individuals or donors and must return for destruction all such information given to them to review once the purpose for being provided with this information has been fulfilled.
Employees and members of LCH committee(s) and/or Board of Directors are required to sign a confidentiality agreement binding them to maintaining the confidentiality of all personal information to which they have access.
Physical Safeguards: Active files are stored in locked filing cabinets when not in use. Access to active files is restricted to LCH authorized members and authorized third parties.
All inactive files or personal information no longer required are shredded prior to disposal to prevent inadvertent disclosure to unauthorized persons.
Technological Safeguards: Personal information contained in LCH computers and electronic databases are password protected. Access to any of the LCH’s computers also is password protected. LCH’s Internet router or server has firewall protection sufficient to protect personal and confidential business information against electronic attacks.
An Individual who wishes to review or verify what personal information is held by LCH, or to whom the information has been disclosed (as permitted by the Act), may make the request for access, in writing, to the LCH’s secretary. Upon verification of the individual’s identity, the Chief Privacy Officer will respond within 60 days.
If the individual finds that the information held by LCH is inaccurate or incomplete, upon the individual providing documentary evidence to verify the correct information, LCH will make the required changes to the individual’s active file(s) promptly.
If an individual has a concern about LCH’s personal information handling practises, a complaint, in writing, may be directed to the LCH’s Chief Privacy Officer.
Upon verification of the individual’s identity, LCH’s Chief Privacy Officer will act promptly to investigate the complaint and provide a written report of the investigation’s findings to the individual.
Where LCH’s Chief Privacy Officer makes a determination that the individual’s complaint is well founded, the Chief Privacy Officer will take the necessary steps to correct the offending information handling practise and/or revise LCH’s privacy policies and procedures.
Where LCH’s Chief Privacy Officer determines that the individual’s complaint is not well founded, the individual will be notified in writing.
If the individual is dissatisfied with the finding and corresponding action taken by LCH’s Chief Privacy Officer, the individual may bring a complaint to the Federal Privacy Commissioner at the address below:
The Privacy Commissioner of Canada Email address: www.privcom.gc.ca.
112 Kent Street, Ottawa,
Ontario K1A 1H3
Rev 2 07/31/2013