Personal Information Protection Policy
At Arts Access Fund, we are committed to providing our client, member, partner and donor with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our clients, members, partners and donors, protecting their personal information is one of our highest priorities.
We will inform our client, member, partner and donor of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information
Protection Policy, in compliance with PIPEDA, outlines the principles and
practices we will follow in protecting client, member, partner and donor
personal information. Our privacy commitment includes ensuring the
accuracy, confidentiality, and security of our client, member, partner and
donor personal information and allowing our client, member, partner and donor
to request access to, and correction of, their personal information.
Policy 1 – Collecting Personal Information
1.1 Unless the purposes for collecting personal information are obvious and client, member, partner and donor voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 We will only collect client, member, partner and donor information that is necessary to fulfill the following purposes:
· To verify identity;
· To identify [client, member, partner and donor] preferences;
· To understand the [financial] needs of our [clients, members];
· To open and manage an application;
· To deliver requested services
Policy 2 – Consent
2.1 We will obtain client, member, partner and donor consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
2.2 Consent can be provided [ orally, in writing, electronically, through an authorized agent or partner representative] or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client, member, partner and donor voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where a client, member, partner and donor is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing of new services or programs, fundraising and the client, member, partner and donor does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or program, or the withdrawal of consent would frustrate the performance of a legal obligation), client, member, partner and donor can withhold or withdraw their consent for Arts Access Fund to use their personal information in certain ways. A client’s, member’s, partner’s and donor’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or program. If so, we will explain the situation to assist the client, member, partner and donor in making the decision.
2.5 We may collect, use or disclose personal information without the client’s, partner’s, donor’s, member’s knowledge or consent in the following limited circumstances:
· To process a donation;
· To enrol the client in a program
· To send out partner information;
· To contact our [Donors, Partners] for fundraising;
· To contact clients, members for renewals
· To ensure a high standard of service to our [client, member, partner and donor];
· To meet regulatory requirements;
· To assess criteria for funding;
· To collect and process administration fees;
· To verify and process donation fees
· To issue tax receipts
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose client, member, partner and donor personal information where necessary to fulfill the purposes identified at the time of collection [or for a purpose reasonably related to those purposes such as:
· To conduct client, member, partner and donor surveys in order to enhance the provision of our programs;
· To contact our [client, member, partner and donor] directly regarding programs services that may be of interest
3.2 We will not use or disclose client, member, partner and donor personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not distribute client, member, partner and donor lists or personal information to other parties [unless we have consent to do so].
Policy 4 – Retaining Personal Information
4.1 If we use client, member, partner and donor personal information to make a decision that directly affects the client, member, partner and donor, we will retain that personal information for at least one year so that the client, member, partner and donor has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain client, member, partner and donor personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that client, member, partner and donor personal information is accurate and complete where it may be used to make a decision about the client, member, partner and donor or disclosed to another organization.
5.2 Clients, members, partners and donors may request correction to their personal information in order to ensure its accuracy and completeness. 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.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the clients’, members’, partners’ and donors’ correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of client, customer, member personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
6.2 The following security measures will be followed to ensure that client, member, partner and donor personal information is appropriately protected: the use of locked filing cabinets; physically securing offices where personal information is held; the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information;
6.3 We will use appropriate security measures when destroying client’s, customer’s, member’s personal information such as: shredding documents, deleting electronically stored information, encrypting electronically stored information
6.4 We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.