2. Identifying Purposes: Christian Aid Ministries Canada will let you know why we need your personal information.
3. Consent: Christian Aid Ministries Canada will clearly ask for, and obtain, your consent before using your personal information.
4. Limiting collection: Christian Aid Ministries Canada will only collect the minimum personal information needed to provide our goods or services to you.
5. Limiting use, disclosure, and retention: Christian Aid Ministries Canada will use your personal information as we have told you; will only disclose that information to third parties to carry out our work; and will ensure the information used by Christian Aid Ministries Canada and those third parties is destroyed, erased or made anonymous after the work is completed.
6. Accuracy: Christian Aid Ministries Canada strives for complete accuracy of your personal information and will correct your information if you notify us. Please contact the Christian Aid Ministries Canada’s Privacy Information Compliance Officer if any information needs correction.
7. Safeguards: Christian Aid Ministries Canada will take all steps needed to protect your personal information through proper physical storage, organizational controls, and electronic safeguard technologies.
9. Individual access: Upon a written request from you, we will inform you of all personal information we, or third parties Christian Aid Ministries Canada deals with, have about you.
10. Challenging compliance: You have the right to challenge Christian Aid Ministries Canada’s compliance with any of the above privacy principles, via a complaint filed with the Personal Information Privacy Officer, who has authority to make corrections.
Christian Aid Ministries Canada has designated Delphine Horst to be Christian Aid Ministries Canada’s Personal Information Compliance Officer. Any inquiry, request, or concern related to privacy matters should be made inwriting to Christian Aid Ministries Canada. Delphine Horst may be contacted at:
Personal Information Compliance Officer
Christian Aid Ministries Canada
1 Parkview Drive
Moorefield, ON N0G 2K0
A printed copy of the Policy may be requested by mail or e-mail at the above address.
Christian Aid Ministries Canada’s Policy To Protect Personal Information
1.1 Delphine Horst is hereby appointed as the personal information compliance officer (the “officer”).
1.2 All persons, whether employees, volunteers, or board or committee members who collect, process, or use personal information shall be accountable for such information to the officer.
1.3 Christian Aid Ministries Canada’s Policy To Protect Personal Information (the “Policy”) shall be made available via Christian Aid Ministries Canada’s website (https://christianaidministries.ca/privacy-policy/) or a paper copy provided upon written request.
1.4 Any personal information transferred to a third party for processing is subject to this policy. The officer shall use contractual or other appropriate means to protect personal information at a level comparable to this policy while a third party is processing this information.
1.5 Personal information to be collected, retained, or used by Christian Aid Ministries Canada shall be done so only after the officer gives written approval. This information shall be secured according to the officer’s instructions.
1.6 Any person who believes Christian Aid Ministries Canada uses personal information collected, retained, or used for purposes other than those that person explicitly approved may contact the officer to register a complaint or to make any related inquiry.
1.7 Upon receiving a complaint from any person regarding the collection, retention, or use of personal information, the officer shall promptly investigate the complaint and notify the person who complained about his/her findings and corrective action taken, if any.
1.8 Upon receiving the response from the officer, the person who filed the complaint may, if he/she is not satisfied, appeal to Christian Aid Ministries Canada’s [board of directors or the trustees] to review and determine the disposition of the complaint at issue.
1.9 The determination of the [board of directors or the trustees] shall be final and the officer shall abide by and implement any of its recommendations.
1.10 The officer shall communicate and explain this policy and give training regarding it to all employees and volunteers who might be in a position to collect, retain, or use personal information.
1.11 The officer shall prepare and disseminate information to the public which explains Christian Aid Ministries Canada’s protection of personal information policies and procedures.
2. Identifying Purposes
2.1 The officer shall document the purpose for which personal information is collected to comply with the openness an individual access principles outlined below.
2.2 The officer shall determine the information that will be needed to fulfill the purposes for which the information is to be collected. To comply with the limited collection principle below.
2.3 The officer shall ensure that the purpose is specified at or before the time of collecting the personal information from an individual.
2.4 The officer shall ensure that the information collected will not be used for any other purpose before obtaining the individual’s approval, unless the new purpose is required by law.
2.5 The officer shall ensure that a person collecting personal information will be able to explain to the individual why this is being done.
2.6 The officer shall ensure that limited collection, limited use, disclosure, and retention principles are respected in identifying why personal information is to be collected.
3.1 The officer shall ensure that the individual from whom personal information is collected consents to this and to it being used and disclosed.
3.2 The officer shall ensure that the individual can reasonably understand why and how the information will be used when the consent is given.
3.3 The officer shall ensure that no condition is attached to supplying benefits, because of Christian Aid Ministries Canada’s activities, requiring the individual to give consent for the collection, use, or disclosure of information beyond that required to fulfil the explicitly specified and legitimate purposes.
3.4 The officer shall ensure that express consent is obtained wherever possible and appropriate. In rare circumstances where, in the officer’s opinion, (having regard to the information’s sensitivity and the policy’s purpose and intent), implied consent might be acceptable.
3.5 In obtaining consent, the officer shall ensure that the individual’s reasonable expectations are respected.
3.6 The officer shall ensure that the express consent obtained from an individual is clear and in an appropriately verifiable form.
3.7 The officer shall ensure that the individual may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. The individual shall promptly be informed of the withdrawal’s implications.
4. Limiting Collection
4.1 The Officer shall ensure that personal information will not be collected indiscriminately. Both the amount and type of information collected shall be limited to that which is necessary to fulfil the purposes identified. He/she shall specify the type of information to be collected, according to the Openness principle.
4.2 The officer shall ensure that information is collected only by fair and lawful means without misleading or deceiving individuals as to the reason.
4.3 The officer shall ensure that the identifying purposes and consent principles are followed in identifying why personal information is to be collected.
5. Limiting Use, Disclosure, and Retention
5.1 The officer shall ensure that personal information shall not be used or disclose for purposes other than those for which it was collected, except with the consent of the individual or as required by law, and any use of personal information shall be properly documented.
5.2 The officer 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.
5.3 The Officer shall ensure that all use, disclosure, and retention decisions are made in light of the consent principle, the identifying purposes principle and the individual access principle.
6.1 The officer shall reasonably ensure that the personal information is accurate, complete, and up to date, taking into account the individual’s interests. He/she shall ensure that the information is sufficiently accurate, complete, and up to date to minimize the possibility that inappropriate information might be used to make a decision about an individual.
6.2 The officer shall ensure that Christian Aid Ministries Canada does not routinely update personal information, unless it is necessary to fulfil the purposes for which the information was collected.
6.3 The officer shall ensure that personal information used on an ongoing basis, including information that is disclosed to third parties, should generally be accurate and up to date, unless limits to the requirement for accuracy are clearly set out.
7.1 The officer shall ensure that Christian Aid Ministries Canada has security safeguards to protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. He/she shall do this regardless of the format in which Christian Aid Ministries Canada holds the information.
7.2 Depending on the information’s sensitivity, the officer may permit reasonable discretion regarding the information that has been collected: the amount, distribution, format, and the method of storage. A higher level of protection shall safeguard more sensitive information according to the consent principle’s considerations.
7.3 The Officer shall ensure that the protection methods include, 1. physical measures, for example, locked filing cabinets and restricted access to offices; 2. organizational measures, for example, security clearance and limiting access on a “need-to-know” basis; and 3. technological measures, for example, the use of passwords and encryption.
7.4 The officer shall ensure that all employees and volunteers know the importance of keeping personal information confidential.
7.5 The officer shall ensure that care is taken when personal information is disposed of or destroyed to prevent unauthorized parties from gaining access to it.
8.1 The officer shall ensure that Christian Aid Ministries Canada is open about its policies and practices regarding the management of personal information. The policies and information about the related practices shall be available without unreasonable effort in a form generally understandable.
8.2 The officer shall ensure that the information available shall include,
(a) the name or title and address of the officer who is accountable for Christian Aid Ministries Canada’s policies and practices and to whom complaints or inquiries can be forwarded;
(b) the means of gaining access to personal information held by Christian Aid Ministries Canada;
(c) a description of the type of personal information held by Christian Aid Ministries Canada, including a general account of its use;
(d) a copy of any brochures or other information that explain Christian Aid Ministries Canada’s policies, standards, or codes; and
(e) what personal information is made available to related organizations (e.g., organizations that are affiliated).
8.3 The officer shall ensure the information that must be provided according to 8.2 is available either in a brochure at the locations Christian Aid Ministries Canada operates, online, or through the mail.
9. Individual Access
9.1 The officer shall ensure that upon request Christian Aid Ministries Canada shall inform an individual whether Christian Aid Ministries Canada holds personal information about him/her. If possible, the information’s source shall also be given. Christian Aid Ministries Canada shall allow the individual access to this information. Christian Aid Ministries Canada may, however, choose to make sensitive medical information about its employees or volunteers available through a medical practitioner. Christian Aid Ministries Canada shall 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. (Note, If the officer believes for valid reasons that access to personal information should be denied, he/she shall consult legal counsel before making such a decision.)
9.2 A person requesting his/her personal information may be required by the officer to give sufficient information to permit Christian Aid Ministries Canada to provide an account of the existence, use, and disclosure of personal information. Information shall be used only for the purpose for which it was obtained.
9.3 If Christian Aid Ministries Canada has supplied personal information about an individual to third parties, the officer shall ensure that an attempt is made to be as specific as possible. When to give a list of Christian Aid Ministries Canadas to which it has actually disclosed information about an individual is impossible, Christian Aid Ministries Canada shall provide a list of organizations to which it might have disclosed information about the individual.
9.4 The officer shall ensure that Christian Aid Ministries Canada responds to an individual’s request within a reasonable time and at minimal or no cost to the individual. The requested information shall be made available in a generally understandable form. For example, Christian Aid Ministries Canada shall explain abbreviations or codes it uses to record information.
9.5 The officer shall ensure that when an individual successfully demonstrates the inaccuracy or incompleteness of personal information, Christian Aid Ministries Canada shall amend the information as required. Depending on the information challenged, amendment involves the correction, deletion, or addition of information. When appropriate, the amended information shall be transmitted to third parties having access to the information in question.
9.6 The officer shall ensure that when a challenge is not resolved to the individual’s satisfaction, Christian Aid Ministries Canada shall record the unresolved challenge’s substance. When appropriate, the unresolved challenge’s existence shall be transmitted to third parties having access to the information in question.
10. Challenging Compliance
10.1 The officer is authorized to address a challenge concerning compliance with the above principles.
10.2 The officer 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.
10.3 The officer shall inform individuals inquiring about lodging complaints that relevant complaint procedures exist.
10.4 The officer shall investigate all complaints. If a complaint is found to be justified, the officer shall take appropriate measures, including, if necessary, amending the policies and practices pertaining to personal information entrusted to Christian Aid Ministries Canada.