To safeguard the personal information entrusted to Heifer International Canada (“HIC”) and to comply with the Personal Information Protection and Electronic Documents Act (“PIPEDA”), and any other applicable legislation, HIC is committed to the following principles:
2. Identifying purposes
4. Limited collection
5. Limiting use, disclosure, and retention
9. Individual access
10. Challenging compliance
1.1 At HIC we respect your privacy and we understand that donors, prospective donors, users of the HIC website and others who have contact with our organization offline need to be in control of their personal information. “Personal information” is any information that can be used to distinguish, identify or contact an individual. The personal information that HIC collects when engaged in fundraising and processing donations includes, but is not limited to: name, address, telephone number, e-mail address and credit card information. The Policy describes HIC practices and policies for collecting, using and disclosing personal information in the course of raising and administering funds to support HIC projects. It may be updated from time to time to reflect development in our practices, new technology or in the law. Updated versions will be made available in the same way as the Policy, including by posting on the website. Please check the website to see the current version of the Policy.
1.2 HIC has designated Gord Enns to be HIC’s Personal Information Compliance Officer (“Officer”). Any inquiry, request or concern related to privacy matters should be made in writing to HIC. Gord Enns may be contacted at:
ATTENTION: Privacy Officer
Heifer International Canada
By e-mail at: email@example.com
1.3 A printed copy of the Policy may be requested by mail or e-mail at the above address.
1.4 For a copy of PIPEDA or to contact the Privacy Commissioner of Canada, please visit the Office of the Privacy Commissioner of Canada’s Internet website at www.privcom.gc.ca.
2. Identifying Purpose
2.1 HIC collects information by mail, telephone or electronic means:
• To build relationships with supporters and donors
• To request your support of HIC’s mission
• To request your support of HIC sponsored events
• To provide information about HIC’s website and HIC’s work around the world
• To provide supporters and donors with products and/or services
• To meet legal and regulatory requirements
3.1 HIC will endeavour to obtain express consent wherever possible and appropriate, unless in the Officer’s opinion having regard to the information’s sensitivity and the Policy’s purpose and intent, implied consent is reasonable in the circumstances.
3.2 You may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice.
3.3 You may have your name removed from HIC telephone, mail or electronic lists at any time and upon reasonable notice.
4. Limited collection
4.1 When supporters and donors visit the HIC website, HIC collects some non-identifying basic information. This includes total number of visitors, pages viewed, and other non-identifying information. HIC uses this aggregate information to improve our site and to make the donor experience on our website as smooth as possible.
4.2 Donations and purchases made on-line to HIC are secure. When donors make a donation on-line, HIC asks for the donor’s name, address, daytime phone, e-mail address, and credit card information.
5. Limiting, use, disclosure, and retention
5.1 HIC uses personal information to process donations, request further donation(s), and to verify credit card data. HIC uses the mailing address to send tax-deductible receipt(s) and to keep supporters informed about what we are doing in different parts of the world through our publications. HIC may also use contact information provided in connection with honour cards to communicate with certain honourees for marketing, educational, informational, and other purposes.
5.2 HIC will discontinue contacting you upon your oral or written request directed to HIC, its fundraiser or other agents.
5.3 HIC may disclose personal information to a third party organization engaged to perform functions on HIC’s behalf. Any disclosure of information is made on a confidential basis. HIC maintains contracts with third party servicers to protect donor information and to ensure the information is used for the sole purpose for which it was disclosed and in accordance with PIPEDA and any other applicable legislation. Upon your request, we will discontinue disclosure of your personal information to a third party organization, subject to legal or contractual restrictions and reasonable notice.
5.4 HIC, which is part of Heifer Project Internationals’ Global Action Network (collectively the “Heifer Network”), may disclose donor information to other members of the Heifer Network. Heifer Project International is a nonprofit 501(c)(3) organization headquartered in the United States, and your personal information may be stored with Heifer Project International, or with other third party service providers, in the United States. Any such disclosure of donor information within the Heifer Network is made on a confidential basis. Contracts within the Heifer Network are used to protect donor information and to ensure the information is used for the sole purpose for which it was disclosed and in accordance with PIPEDA and any other applicable legislation. Upon your request, we will discontinue disclosure of your personal information to the Heifer Network, subject to legal or contractual restrictions and reasonable notice.
6.1 HIC will reasonably ensure that your personal information is accurate, complete, and up to date.
6.2 If you notify HIC of any inaccuracies or incompleteness of personal information, we will amend the information accordingly in a timely manner.
7.1 HIC will protect your personal information with appropriate security safeguards. Protection methods include:
• physical measures, for example, locked filing cabinets and restricted access to offices;
• organizational measures, for example, security clearance and limiting access on a “need-to- know” basis; and
• technological measures, for example, the use of passwords and encryption IT.
7.2 HIC uses password protocols and encryption software to protect personal and other information we receive when a service is paid and/or donations are made on-line. Our software is routinely updated to maximize protection of such information.
7.3 To allow an item to be kept in the shopping basket as donors browse through any catalogues HIC may make available online, HIC uses “cookies”, which store information in the web browser. The “cookies” that HIC uses are only used to process any orders.
7.4 HIC also logs information such as the web browser’s IP address and browser types. This information is used for analysis purposes and to provide better service for users.
7.5 HIC’s website may include links to other websites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage you to be aware that you are leaving our site and it is important that you read the privacy policies of any other site that collects personally identifiable information.
7.6 Please be aware that information voluntarily disclosed online in discussion areas and other public areas of our website or on HIC-sponsored pages on social media sites can be collected, used and disclosed by third parties. Any submissions made to discussion areas or other public areas on our website or on HIC-sponsored pages on social media sites are done at the user’s risk and with the understanding that such information may be accessible to third parties. We cannot control or be responsible for any damages that may arise from such user activity.
7.7 HIC shall ensure that all personal information is destroyed, erased, or made anonymous as soon as the purpose for which it was collected is no longer relevant, or as permitted by law. There shall be an automatic review of the need to continue retaining personal information annually. Except as required to be retained by law, all personal information shall be deleted, erased, or made anonymous no later than seven years after the purpose for which it was collected has been completed.
8.1 HIC is open about its policies and practices regarding the management of personal information. The policies and information about the related practices are available from the Officer and include:
• the name or title and address of the Officer who is accountable for HIC’s policies and practices and to whom complaints or inquiries can be forwarded;
• the means of gaining access to personal information held by HIC;
• a description of the type of personal information held by HIC, including a general account of its use;
• a copy of any brochures or other information that explain HIC’s policies, standards, or codes; and
• what personal information is made available to related organizations (e.g., organizations that are affiliated).
9. Individual Access
9.1 Upon written request, HIC will inform you whether HIC holds personal information about you and will provide you access to this information, subject to any applicable legal restrictions. HIC will also account for the use that has been made or is being made of this information and give an account as to the third parties to whom it has been disclosed.
9.2 If you are requesting your personal information you may be required to give sufficient information to permit HIC to provide an account of the existence, use, and disclosure of personal information. This information shall be used only for the purpose for which it was obtained.
9.3 HIC will endeavour to respond to your request within a reasonable time and at minimal or no cost to you.
10. Challenging Compliance
10.1 HIC shall develop procedures to receive and respond to complaints or inquiries about the policies and practices regarding the handling of personal information. The compliance procedures shall be easily accessible and simple to use.
10.2 The Officer shall inform individuals inquiring about lodging complaints that relevant complaint procedures exist.
10.3 The Officer shall investigate all complaints. If a complaint is found to be justified, the Officer shall take appropriate measures, including, if necessary, amending this Policy and general policies and practices pertaining to personal information entrusted to HIC.