1.0 Purpose
The Canadian Cancer Society (the “Society”) is committed to protecting the privacy of its donors, funders, partners, fundraisers, and individuals who uses the services of the Society including, but not limited to, individuals with cancer and their families and caregivers (collectively, the “Individual” or “Individuals”). This Privacy Policy (“Policy”) applies to the Society’s collection, use, and disclosure of personal information.
2.0 Scope
This Policy is intended to comply with the applicable federal and provincial privacy legislation in all the jurisdictions that it operates.
3.0 Collection, Use and Disclosure of Personal Information
3.1 Personal Information
3.1.1 Personal information” is information about an identifiable individual but does not include contact information. Examples of personal information includes information such as your address, gender, age, ID numbers, income, ethnic origin, credit records, or medical records.
3.1.2 Contact information” is information to enable an individual at a place of business to be contacted and includes the name, position name or title, business telephone number, business address, business email or business fax number of the individual.
3.2 Collection and Use of Personal Information
3.2.1 Except where otherwise required or permitted by law, the Society will inform Individuals of the purposes for the collection, use or disclosure of the Individual's personal information, prior to collecting, using or disclosing that personal information.
3.2.2 The Society collects information from Individuals in the course of its business through various means including, but not limited to:
(a) registration and application forms;
(b) the Society programs and services;
(c) donor and fundraising forms; and
(d) online applications, services, and systems.
The type of information collected will vary depending on the means through which an Individual submits his/her personal information. The type of information collected may include an Individual’s name, residential address, email address, home phone number, occupation, employment status, credit card information, bank account information, health information, and notes from meetings and discussions with the Individuals.
3.2.3 The Society uses information collected from Individuals to:
(a) provide services which include Cancer Information Service, Peer Support Service, CancerConnection.ca, volunteer driver program, and other cancer-related services,
(b) respond to requests for information regarding the Society’s services,
(c) fundraise, market special events, and promote its services;
(d) communicate with the community, including communications with donors, funders, partners, and individuals that uses its services;
(e) determine the Individual’s suitability to be in a position of trust including the handling of cash and working with a vulnerable population;
(f) complete accounting and transactions purposes; and
for additional purposes that may be identified at or before the time that the information is collected.
3.3 Disclosure of Personal Information
3.3.1 The Society will not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law.
3.3.2 The Society may disclose or transfer certain personal information to third party service providers and to affiliated entities in connection with the performance of certain technological or administrative functions, such as data processing, data management, and data storage. From time to time, these third party service providers may be located outside of Canada in which case the laws of the other jurisdictions may apply to the collection, use, disclosure or storage of the personal information. Prior to making this disclosure or transfer, the Society will take appropriate steps to ensure that the third party service providers safeguard the personal information and use the personal information only for authorized purposes set out in the Privacy Policy.
4.0 Consent
4.1.1 Requirements for consent to collection, use, or disclosure of personal information vary depending on circumstances and on the type of personal information that is intended to be collected, used or disclosed. In determining whether consent is required and, if so, which form of consent is appropriate, the Society will take into account both the sensitivity of the personal information at issue and the purposes for which the Society will use the information. Consent may be express, implied (including through use of “opt-out” consent where appropriate), or deemed. For example, if an Individual provides his/her mailing address and requests information regarding a particular product, consent to use the address to mail product information to the Individual is implied.
4.1.2 By submitting personal information to the Society or its service providers and agents, the Individual agrees that the Society may collect, use and disclose such personal information in accordance with this Policy and as permited or required by law.
4.1.3 Subject to legal and contractual requirements, the Individual may refuse or withdraw their consent to certain of the identified purposes at any time by contacting the Privacy Officer. If the Individual refuse to consent or withdraw his/her consent, the Society may not be able to provide or continue to provide the Individual with the services of the Society.
5.0 Accuracy
5.1.1 Personal information is kept as accurate, complete and up to date as appropriate. It is the responsibility of each Employee to provide the Society with any changes in personal information so that the appropriate records may be accurately maintained.
5.1.2 An Individual may request in writing that the Society correct an error or omission in personal information. If the Society is satisfied that a correction should be made, it will amend the information as requested and, where appropriate, will send the corrected information to the third parties to which it has disclosed that information.
5.1.3 Access requests should be made, in writing, to the Privacy Officer. The written request must also provide sufficient detail so that the Privacy Officer can properly and efficiently respond to the request.
5.1.4 The Society will respond to the written requests within 30 days, or alternatively, the timeframe prescribed by the relevant legislation.
6.0 Access
6.1.1 An Individual may request in writing access to his or her personal information and information regarding the collection, use and disclosure of that personal information. The Society will provide appropriate access to personal information requested. A written explanation will be provided if the requested access is not granted. Access requests should be made, in writing, to the Privacy Officer.
6.1.2 The Society will respond to the written requests within 30 days, or alternatively, the timeframe prescribed by the relevant legislation.
7.0 Personal Information Retention
The Society retains personal information in accordance with its legal or business practices. Once the personal information is no longer required to fulfill the purpose for which it was collected and no longer required or permitted to be retained for legal or business purposes, it will be destroyed or made anonymous.
8.0 Protection of Personal Information
The Society takes appropriate steps to protect personal information whether in paper or electronic form from unauthorized access disclosure, use or modification. These steps include but are not limited to:
(a) protecting the confidentiality of your personal information when doing business internally or externally with other organizations;
(b) protecting your personal information with appropriate and effective security safeguards, including physical, administrative, and technology safeguards, against such risks as loss or theft, unauthorized access, disclosure, copying, use or destruction, regardless of the format in which it is held; and
(c) retaining personal information only as long as necessary for the fulfilment of the identified purposes, or as required by law, and will maintain reasonable and systematic controls, schedules and practices for the retention and destruction of such information.
9.0 Concerns of a Non-Compliance
9.1.1 Individuals may direct a complaint concerning compliance with the Policy to the Society’s Privacy Officer.
9.1.2 The complaint must be in writing. Within a reasonable time of receipt of the complaint, the Privacy Officer will conduct an investigation into the compliant. The format of this investigation will vary depending on the circumstances and may or may not involve an interview of the complainant and/or the Society’s employees conduct by the Privacy Officer.
9.1.3 After the investigation into the complaint, the Society will take appropriate measure necessary to rectify the source of the complaint if it is necessarily required.
9.1.4 Within a reasonable time of conclusion of the investigation, the Privacy Officer will inform the complainant, either verbally or in writing, of:
(a) the result of its investigation; and
(b) any appropriate measures the Society will take to rectify the source of the complaint if necessarily required.
10.0 Privacy Officer
Any concern, inquiry or request regarding personal information should be directed in writing to the Privacy Officer:
NAME
TITLE
200, 325 Manning Road NE
Calgary, AB T2E 2P5
Phone 403-XXX-XXXX
Fax 403-XXX-XXXX (confidential)
privacy.officer@cancer.ab.ca
11.0 Changes to the Policy
The Society may from time to time make changes to this Policy to reflect changes in its legal or regulatory obligations or in the manner in which the Society deal with the personal information of the Individuals.
The Society will communicate any revised version of this Policy by providing reasonable notice of the revised Policy.
