Intent
Protecting the privacy and confidentiality of personal information is important to how the Lakehead Social Planning Council conducts its operations: collecting, using, and disclosing personal information appropriately, responsibly, and ethically, is fundamental to the organization’s mandate.
The organization strives to protect and respect personal information of its clients, employees, community partners, and so on in accordance with all applicable statutory requirements. All employees must abide by the procedures and practices set out below while handling personal information.
Guidelines
This policy applies to all employee personal information in the organization’s care, custody, and control.
Personal information is any factual or subjective identifying information about an individual or group of individuals. This can include name, date of birth, address, income, e-mail address, social insurance number, gender, performance evaluations, financial information, and more.
Consent occurs and is considered obtained by Lakehead Social Planning Council when an individual provides express consent orally, in writing, or through an applicable online action. Before being asked to provide consent, individuals will be provided with the reasons their personal information is being collected, how it will be used, and any disclosure or possible disclosure of the information.
Implied consent is granted by the individual where consent may reasonably be inferred from the action or inaction of the individual. Where possible, this should always be followed up by a Lakehead Social Planning Council representative to obtain explicit consent.
Appropriate Use
Lakehead Social Planning Council collects and uses personal/private information solely for the purpose of conducting business and developing an understanding of its clients. The organization hereby asserts that personal information may only be used for the sole purpose for which it is intended.
Policy Statements
Lakehead Social Planning Council assumes full accountability for the personal/private information within its possession and control. The organization has appointed the Executive Director for oversight of all privacy matters and legal compliance with privacy laws.
Individuals whose personal/private information is being collected are at all times entitled to know how the organization uses this information and that the use of any personal/private information collected is limited to only what is needed for those stated purposes. If necessary, Lakehead Social Planning Council will obtain individual consent if personal/private information is to be used for any other purpose.
Under no circumstances will the organization sell, distribute, or otherwise disclose personal/private information, including personal contact information or employee lists, to third parties, unless required to do so by law.
The organization will retain personal/private information only for the duration it is needed for conducting its business and ensuring statutory compliance. Once personal/private information is no longer required, it will be destroyed promptly, safely, and securely.
The organization will take every reasonable precaution to protect personal/private information with appropriate security measures, physical safeguards, and electronic precautions. The organization maintains personal/private information through a combination of paper and electronic files. Where required by legislation or disaster recovery or business continuity policies, older records may be stored in a secure, offsite location.
Lakehead Social Planning Council will ensure that:
- access to personal/private information is authorized only for the employees and other agents of the organization who require the information to perform their job-related duties, and to those otherwise authorized by law.
- the organization’s computer network systems and databases are secured by complex passwords and firewalls to which only authorized individuals may access.
- active physical files are kept in locked filing cabinets.
- routers and servers connected to the Internet are protected by a firewall and are further protected against viruses or “snooping” by sufficient software solutions.
- personal/private information is not transferred to employees, volunteers, students, or any other person in the organization unless authorized.
The Lakehead Social Planning Council website will include our privacy policy and disclose our personal information practices. Individuals providing data online will be notified about:
- identifying information about the individual that is collected from the website or through affiliate sites.
- information about the organization collecting the data.
- how the data will be used.
- to whom the data may or may not be disclosed.
- what options are available to the individual regarding the collection, use, and disclosure of personal information.
- security procedures in place that protect against the destruction, loss, theft, alteration, or misuse of personal information under the organization’s possession and control.
- how the individual may access and correct any inaccuracies in their personal information.
In addition, Lakehead Social Planning Council will explain that the organization may share compiled demographic information with its community partners or advertisers, but no personal information that can identify any individual person will be disclosed. While IP addresses will be logged to administer the site, track visitor movement, and gather demographic information, these IP addresses will not be linked to any personally identifiable information. Any registration or order form asking site visitors to enter personal or financial information will be protected by SSL encryption. At the point when the information is gathered, site visitors may opt out of having their personal information used.
Lakehead Social Planning Council will grant individuals access to personal information in the care, custody, and control of the organization upon presentation of a written request and satisfactory identification. If an individual finds errors of fact with their personal information, they should notify the organization as soon as possible to make the appropriate corrections.
If the organization denies an individual’s request for access to their personal information, the organization will advise in writing of the reason for such a refusal. The individual may then challenge the decision.
Lakehead Social Planning Council may use personal information without the individual’s consent under particular circumstances. These situations include, but are not limited to:
- the collection is clearly in the interests of the individual and consent cannot be obtained in a timely way.
- the personal information was produced by the individual in the course of their employment, business, or profession, and the collection is consistent with the purposes for which the information was provided.
- the collection is made for the purpose of making a disclosure required by law.
- any other reason as defined in applicable legislation.
Any questions or concerns regarding this policy can be addressed by contacting Lakehead Social Planning Council. The organization will investigate and respond to concerns about any aspect of the handling of personal information. This organization will address concerns to the best of its abilities.