The Christian and Missionary Alliance in Canada (C&MA) is committed to
respecting the privacy of its employees, official workers, candidates,
donors, and contacts. In demonstration of our commitment to this privacy
and in voluntary compliance with the Personal Information Protection and
Electronic Documents Act (PIPEDA), we have created the following Privacy
Policy (the Policy). The Policy has been designed to reflect our
commitment to the principles outlined in PIPEDA.
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 the 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 of the Policy and may be given restricted access to
personal information solely to fulfill the purposes as set out in the
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 or
her behalf.
1.3 - We will continually create and update procedures in
accordance with the Policy to govern the handling of personal information
and respond to complaints.
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, reasonable, and appropriate
in the circumstance.
2.2 - The Christian and Missionary Alliance in Canada
will only collect personal information from employees, official 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
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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, official 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, official 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, official 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, official workers, candidates, donors, and
contacts are given notice and a reasonable opportunity to opt-out of their
personal information being used for certain purposes and the employee,
official 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, official 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 (e.g., 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 honor, 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 (e.g.,
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.
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
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.
7.2 - 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.
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, official 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, official
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
10.1 - It is The Christian and Missionary Alliance in
Canada’s policy that all privacy related complaints shall be investigated.
Complaints made regarding the Privacy Policy or the use of personal
information should be made to the Privacy Officer in writing.
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
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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, official worker, candidate, donor or contact may
also write to the Federal Privacy Commissioner.
Contact Information
Privacy Officer
The Alliance Canada
2580 Matheson Blvd E, Suite 101, Mississauga, ON L4W 4J1
Phone: 416-674-7878
Email:
privacyofficer@cmacan.org