All directors, officers, employees and volunteers of The Christian and Missionary Alliance in Canada are required to comply with the Policy and may be given restricted access to personal information solely to fulfill the purposes as set out in this Policy.
All other persons or organizations who act for, or on behalf of, The Christian and Missionary Alliance in Canada are also required to comply with the principles and the Policy and may be given restricted access to personal information solely to fulfill the purposes as set out in this Policy.
PRINCIPLE 1 - ACCOUNTABILITY
1.1 THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA is responsible for personal information which we collect, use or distribute and any personal information in our custody or under our control.
1.2 THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA has appointed a Privacy Officer who will be responsible for overseeing the Policy as well as any inquiries, requests or concerns relating to privacy matters. The Privacy Officer may, from time to time, designate one or more individuals within The Christian and Missionary Alliance to act on his behalf.
PRINCIPLE 2 - PURPOSES
2.1 THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA is committed to ensuring that the purposes for which personal information is collected, used, or disclosed are identified and are reasonable and appropriate in the circumstance.
2.2 THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA will only collect personal information from employees, licensed workers, candidates, donors and contacts that is necessary to fulfill the following purposes:
To verify identity
To assess ongoing suitability for employment and/or licensing
To identify individual preferences
To understand individual needs
To provide requested products and services
To inform regarding denominational priorities, policies and practices
To make contact for fundraising
To meet government requirements
PRINCIPLE 3 - CONSENT
3.1 THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA will obtain reasonably informed consent of employees, licensed workers, candidates, donors and contacts to collect, use or disclose personal information except where we are authorized to do so without consent.
3.2 Consent can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the employees, licensed workers, candidates, donors and contacts voluntarily provides personal information for that purpose.
3.3 In general, the use of products and services by an employee, licensed worker, candidate, donor or contact, or the acceptance of employment or benefits by an employee, constitutes implied consent for THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA to collect, use and disclose personal information for all identified purposes. Consent may also be implied where employees, licensed workers, candidates, donors and contacts are given notice and a reasonable opportunity to opt-out of his or her personal information being used for certain purposes and the employee, licensed worker, candidate, donor or contact does not opt-out. Individuals may withdraw their consent at any time subject to legal or contractual notice, by providing reasonable notice to C&MA of their intent to withdraw their consent.
3.4 The following are examples of when we may collect, use or disclose the personal information of an employee, licensed worker, candidate, donor or contact without their consent:
When the collection, use or disclosure of personal information is permitted or required by law;
When collection is clearly in your best interests and we are unable to obtain your consent in a timely way;
In an emergency that threatens an individual’s life, health or personal security;
When disclosure is required for archival purposes;
When the personal information is available from a public source (eg. a telephone directory);
When the personal information is available through observation at a public event to which you attended voluntarily;
When the collection, use or distribution is necessary to determine your suitability to receive an honour, award or similar benefit or to be selected for a religious, athletic or artistic purpose;
When we require legal advice from a lawyer;
For the purposes of collecting a debt or other obligation;
To protect ourselves from fraud;
To investigate an anticipated breach of an agreement or a contravention of law;
When the personal information is voluntarily disclosed by the person to whom it applies by using equipment or data owned by the C&MA (eg. through the use of company computers, email addresses etc.).
PRINCIPLE 4 - LIMITING COLLECTION
4.1 THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA will limit the collection of personal information to that which is necessary for identified purposes. The C&MA will only collect personal information by fair and lawful means and for purposes that a reasonable person would consider appropriate in the circumstances.
PRINCIPLE 5 - LIMITING USE, DISCLOSURE AND RETENTION
5.1 THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA will not use or disclose personal information for purposes other than for those for which it was collected except with the consent of the individual or as required or permitted by law.
5.2 THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA will only retain personal information as long as it is needed for the purposes for which it was collected or consented to. THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA will maintain reasonable schedules to ensure that personal information is reviewed on an ongoing basis to determine relevance and if retention is required.
5.3 When personal information collected is no longer relevant to its purpose or when it is permitted by law, THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA will ensure that it is deleted, destroyed or made anonymous in a secure manner.
PRINCIPLE 6 - ACCURACY
6.1 THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA will take reasonable efforts to ensure that personal information is accurate and complete.
6.2 THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA will update information when it is necessary to fulfill the purpose for which the information was collected or when an individual notifies us. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. This request should be directed to the Privacy Officer.
PRINCIPLE 7 - SAFEGUARDS
7.1 THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA shall stress to both employees and volunteers the importance of safeguarding the confidential nature of personal information and will provide training in this regard.
7.2 THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA will routinely review and update our security measures which will include: Physical measures such as locking filing cabinets and restricted access to offices as appropriate; Organizational measures, such as security clearances and policies governing access to information; Technological measures, such as the use of passwords and encryption.
7.3 THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA shall protect personal information disclosed to third parties by contractual agreement that stipulates the confidentiality and safeguard requirements that are comparable to our own.
PRINCIPLE 8 - OPENNESS
8.1 THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA is committed to making its privacy policies and procedures available and clear to all interested parties.
8.2 Any questions or concerns regarding our policy or procedure may be directed in writing to our Privacy Officer.
PRINCIPLE 9 - INDIVIDUAL ACCESS
9.1 Employees, licensed workers, candidates, donors and contacts have a right to access their personal information, subject to limited exceptions including, but not limited to:
Situations of solicitor-client privilege
Situations where disclosure may reveal the personal information of another individual
Situations where the health or safety of an individual may be jeopardized
Situations where the information was provided confidentially, such as the references for candidates
9.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought and should be forwarded to the attention of the Privacy Officer. A reasonable fee may be charged for providing access to personal information, in which case we will inform the employee, licensed worker, candidate, donor or contact prior to proceeding.
9.3 In certain situations, it may not be possible to provide access to all the personal information that is held and a request may be refused in whole or in part, providing the reasons for refusal and the recourse available. For example, information may not be provided if to do so would reveal personal information about a third party or jeopardize the security of another.
PRINCIPLE 10 - CHALLENGING COMPLIANCE
10.2 The procedure of THE CHRISTIAN AND MISSIONARY ALLIANCE IN CANADA for dealing with complaints is as follows:
Record the date and nature of a complaint when it is received
Acknowledge receipt of the complaint promptly
Review the matter fairly and impartially, providing to the individual, where possible, access to all relevant records
Notify the individual of the outcome of the investigation promptly and clearly
If the complaint is found to be justified, we will take appropriate measures, including, if necessary, amending our policies and practices. We will also, if and as required, correct any inaccurate or incomplete information when possible.
10.3 If the Privacy Officer is unable to resolve the concern, the employee, licensed worker, candidate, donor or contact may also write to the Federal Privacy Commissioner.
10.4 The contact information for the Privacy Officer is as follows:
The Christian and Missionary Alliance in Canada
30 Carrier Drive Suite 100
Toronto ON M9W 5T7
Contact - firstname.lastname@example.org