Privacy Policy
1. Purpose
Privacy is important to us.
Tearfund Canada is committed to always handling personal information in a safe and secure manner, and ensuring the privacy of this information.
Consistent with our obligations to manage personal information openly and transparently, this policy aims to ensure compliance with relevant legal obligations, provide guidelines for the handling of information provided to Tearfund Canada, and provide information on privacy for Tearfund Canada’s supporters.
2. Scope
This policy guides Tearfund Canada’s handling of data impacted by Canadian Privacy Principles and relevant legislation.
3. Policy
3.1 What type of personal information do we collect?
We collect personal information from donors, potential donors, event participants, advocacy supporters, church supporters, and people that complete a Tearfund Canada form or sign up to receive Tearfund Canada communications.
The type of personal information that Tearfund Canada collects and holds will depend on the nature of involvement with our organisation.
Depending on the reason for collecting the personal information, the personal information collected by Tearfund Canada may include personal or sensitive information, as defined in Section 4 Definitions/ Terminology Classification.
Whilst an individual is not required to provide personal and/or sensitive information requested by Tearfund Canada, if it is chosen not to provide information as requested, it may not be practicable for Tearfund Canada to service the individual’s needs. For instance an individual may choose to donate or receive general information anonymously or under a pseudonym; however, Tearfund Canada is required to collect and store a minimum level of information in order to issue a tax-deductible receipt/statement.
In circumstances where Tearfund Canada receives unsolicited personal information (meaning, personal information received where Tearfund Canada has taken no active steps to collect the information), Tearfund Canada will usually destroy or de-identify the information as soon as practicable if it is lawful and reasonable to do so unless the unsolicited personal information is reasonably necessary for, or directly related to, Tearfund Canada’s functions or activities. For instance we usually retain unsolicited volunteer or employment applications and complaints or feedback.
3.2 How do we collect personal information?
Tearfund Canada staff, volunteers and contractors may collect personal information from individuals from time to time.
We will wherever practicable collect personal information directly from the owner of the personal information, including via phone, face to face, our website, email, SMS, electronic and hard copy forms, social media, and third party online portals.
On occasion, Tearfund Canada may collect personal information from a third party such as sector relevant coalitions. Tearfund Canada does not purchase marketing/information lists.
Tearfund Canada will generally obtain consent from the owner of personal information to collect their personal information. Consent may be provided in writing, orally or may be implied through a person’s engagement with Tearfund Canada.
We will endeavour to only ask for personal information if it is reasonably necessary for the activities that an individual is seeking to be involved in.
3.3 How does Tearfund Canada use personal information?
Tearfund Canada may collect, hold, use or disclose personal information for the following general purposes:
- to identify an individual;
- for the purpose for which the personal information was originally collected;
- for a purpose for which an individual has consented;
- for any other purpose where the information is used in aggregated form;
- for any other purpose authorised or required by an Canadian law; and
- for any other purpose authorised or required by a court or tribunal.
For the purpose of furthering Tearfund Canada’s mission, information collected is usually used for Tearfund Canada’s fundraising, charitable, aid, relief and development, advocacy, and related activities. This includes (but is not limited to) processing donations, issuing receipts and other Tearfund Canada material, contact management for Tearfund Canada staff and representatives, and analysis to personalise and improve Tearfund Canada’s supporter engagement.
Tearfund Canada may publish the images of supporters, staff, contractors and volunteers in publications, on social media, or in public advertisements, after obtaining informed consent where practicable.
If an individual has any concerns about their personal information being used by Tearfund Canada in any of these ways, they must notify the Privacy Officer of Tearfund Canada at connect@tearfund.ca
3.4 Disclosure
Tearfund Canada won’t pass information on to third parties except in the following circumstances:
- Information is given to financial institutions/intermediaries for normal bank processing in which case there is a contractual expectation of confidentiality;
- Information is given to communication service providers for bulk processing in which case there is a contractual expectation of confidentiality;
- The Canada Taxation Office or other government authority or Canada law or court order requires or authorises disclosure of information;
- An individual has consented to Tearfund Canada disclosing their personal information to a third party.
- Other parties including agents and contractors have agreed to keep information secure and confidential in line with the Personal Information Protection Act (PIPA).
When disclosing personal information to a third party, Tearfund Canada will take reasonable steps to ensure that the third party does not breach PIPA in relation to the information.
Tearfund Canada may disclose an individual’s personal information to a recipient overseas in accordance with the PIPA where:
- the individual has consented to the disclosure; or
- Tearfund Canada reasonably believes that the overseas recipient is subject to a law or binding scheme that protects the information in a way that is substantially similar to the way the information is protected under the PIPA or
- the disclosure is required or authorised by an Canadian law or a court order.
3.5 Direct marketing
From time to time Tearfund Canada may send supporters updates and information consistent with its mission and future development. Supporters are provided with the option to unsubscribe from communications and may contact Tearfund Canada’s Privacy Officer if they do not wish to receive such information.
3.6 How does Tearfund Canada store personal information?
Tearfund Canada ensures all reasonable steps are taken to protect the personal information it holds from misuse and loss and from unauthorised access, modification or disclosure. Supporters’ personally identifiable information is kept secure—through securely storing paper records, firewalls, password restricted access to computerised records, routine security risk assessments, and internal policies in relation to access to personal information. Only authorised employees and volunteers have access to this information.
3.7 Keeping details accurate and up-to-date
Tearfund Canada is committed to holding accurate and up-to-date personal information.
Individuals are encouraged to contact Tearfund Canada at any time to update their personal information. This can be done by contacting the Privacy Officer of Tearfund Canada.
Tearfund Canada will destroy or de-identify any personal information which is no longer required by the organisation for any purpose for which the organisation may use or disclose it, unless Tearfund Canada is required by law or under an Canadian law or a court order to retain it.
3.8 How individuals can access their personal information
If an individual wants to access a copy of their personal information that Tearfund Canada holds, in order to seek correction of such information they may do so by contacting Tearfund Canada’s Privacy Officer.
In accordance with the PIPA, Tearfund Canada may refuse access to personal information in a number of circumstances including where giving access to the information would pose a serious threat to the life, health or safety of a person, giving access would have an unreasonable impact on the privacy of a person, the information relates to existing or anticipated legal proceedings and would not be available under the discovery process, or denying access is required or authorised by an Canadian law or court order.
Tearfund Canada will handle all requests for access to personal information as quickly as possible.
3.9 How to contact Tearfund Canada
If an individual has any questions, comments or complaints about Tearfund Canada’s Privacy Policy or handling of information, please contact Tearfund Canada’s Privacy Officer on 1-800-567-8190 between 8:30 am and 4:30 pm (EST or EDT) Monday to Friday. Alternatively, they can send an email to connect@tearfund.ca or write to: Tearfund Canada’s Privacy Officer, PO Box 3220, Stn Industrial Park, Markham ON, L3R 9Z9
Tearfund Canada takes all feedback seriously and any feedback on Tearfund Canada’s privacy principles or handling of personal information will be investigated and assessed by the Privacy Officer. The feedback will be responded to within a reasonable time from initial receipt.
4. Definitions/Terminology Classification
Personal information means information or an opinion about an identified individual, or an individual who is reasonably identifiable: a) whether the information or opinion is true or not; and b) whether the information or opinion is recorded in a material form or not.
Sensitive information is a special category of personal information. Sensitive information means: a) information or an opinion about an individual’s (i) racial or ethnic origin, (ii) political opinions, (iii) membership of a political association, (iv) religious beliefs or affiliations, (v) philosophical beliefs, (vi) membership of a professional or trade association, (vii) membership of a trade union, (viii) sexual orientation or practices, (ix) criminal record, that is also personal information; b) health information about an individual, c) genetic information about an individual that is not otherwise health information; d) biometric information that is to be used for the purpose of automated biometric verification or biometric identification, or biometric templates.
