1. POLICY STATEMENT
North York Women’s Centre (“NYWC”) recognizes the importance of keeping personal information safe and confidential. We are committed to protecting the privacy of our clients, donors, members and other stakeholders. We value the trust of those who choose to share personal information with us and recognize that maintaining that trust requires us to be transparent and accountable in how we treat this information.
NYWC is committed to collecting, using, storing and disclosing personal information responsibly and only to the extent necessary to fulfill our charitable purpose. This policy is intended to help you understand what kind of information we collect and how we treat it, so that you can make informed decisions about providing us with personal information.
This policy confirms the importance of privacy rights as well as professional obligations. All employees, volunteers, contractors and independent service providers working on behalf of NYWC are required to uphold the principles and practices described in this policy.
2. PERSONAL INFORMATION, CONSENT AND DISCLOSURE
Personal information is any information that can be used to identify or contact an individual, such as your email address, telephone number or residential address. Information that is publicly available, such as business contact information, is not considered personal information and is, therefore, not included in this policy.
NYWC collects personal information about you only when voluntarily submitted by you. The collection of personal information is limited to the purpose for which it was collected. For example, if you contact us for information, your personal information will be collected from you so that we can reply to your request. NYWC does not sell, rent or trade personal information.
Personal information can be shared only with your consent and only for the purpose for which consent was given. Consent may be express or implied and must be provided directly by you or an authorized representative. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from your actions and/or relationship with us.
You may withdraw consent at any time by providing reasonable notice in writing. Withdrawal of consent applies to future situations only. Consent may not be withdrawn retroactively.
NYWC may, in certain circumstances, be required to disclose personal information without your consent, if required by legal or regulatory authorities, such as to satisfy a government request, subpoena or court order.
3. COLLECTION AND USE OF PERSONAL INFORMATION
NYWC gathers and uses personal information when delivering services and undertaking other activities to advance our charitable purpose. Client, donor, member and volunteer information are always considered personal information and will not be disclosed without your consent.
With consent, NYWC collects, maintains, and uses personal information about our clients, donors and/or members in order to:
- Provide and maintain quality programs and services;
- Provide information to other people or organizations with client consent (for example, making a referral to another service provider);
- Contact clients, donors and/or members for the purpose of evaluating NYWC’s programs and services;
- Contact clients, donors and/or members for the purpose of conducting research that helps us understand better the issues our clients and community may be facing;
- Collect stories and feedback that demonstrate the impact of NYWC’s programs and services;
- Generate statistics and aggregate data for reporting and planning purposes;
- Contact individuals about events, fundraising initiatives and/or membership activities;
- Recognize donor, volunteer and other contributions;
- Review records to ensure high quality of service, documentation and compliance.
CLIENT PERSONAL INFORMATION
NYWC keeps electronic and paper records for individuals who use our programs, to the level required to provide quality services. Once they are no longer required, all paper records with client information are shredded. Client files are not stored in physical copy.
In order to protect personal client information, access to records is granted on a “need to know” basis (for example, only people directly involved in client service and supervision are allowed to look at that client’s record).
Clients have the right to access information of themselves and be provided verbally, by summary report or by giving the client access to review relevant documents, their information.
Following strict rules and practices, personal information in client records may include:
- Client contact information, including name, email address and telephone number;
- Demographic information, i.e. age and gender;
- Information about the client’s needs and the issues they are facing;
- Information about the services NYWC provides directly or indirectly;
- Surveys and data intended to measure client outcomes and program impact; and
- Aggregate socio-demographic information for research and reporting purposes.
There are times when NYWC is required or permitted by law to disclose information about a client without asking for consent. We will release information if:
- We believe someone is in danger of imminent harm to themselves or others;
- A child is, or is at risk of, being abused or neglected;
- A client’s records have been subpoenaed by a court of law;
- We have to obey a summons, warrant or similar order; and
- We are required to disclose information by a legal or regulatory authority.
DONOR PERSONAL INFORMATION
NYWC keeps electronic and paper records for individuals who donate to the organization. Personal information will be collected from you in order to process your donation, thank you for your gift, and provide you with a charitable tax receipt, if applicable. Donors’ requests to remain anonymous will be respected.
With your consent, we also use your personal information to:
- Invite you to participate in fundraising initiatives;
- Send you updates on programs and activities supported with donations; and
- Acknowledge your support publicly, such as in our Annual Report, which is posted on our website and social media.
NYWC keeps electronic and paper donation records for the purpose of financial accountability and transparency. Aggregated records are used for compliance and reporting.
We use personal information, such as donation history to better understand our donors. This is limited to what is relevant and necessary for our fundraising efforts. We will not make unwarranted or intrusive inquiries into your gift history.
NYWC endorses, and has received permission to use, the Donor Bill of Rights created by the Association of Fundraising Professionals et al. and has adopted it as our Donor Bill of Rights.
MEMBER PERSONAL INFORMATION
As a registered charity incorporated in Ontario, NYWC is required to maintain a member registry that includes each member’s name, full residential address, email address, whether consent is given to receive electronic communications, and the date the individual became and ceased to be a member.
In order to be properly constituted, the member registry must be authorized by a resolution of the Board of Directors. A copy of the registry will be shared with the Board for this purpose.
The personal information contained in the registry will be used to:
- Provide notice of the Annual General Meeting and other general members’ meetings;
- Share information regarding proposals brought forward, or topics to be discussed, at members’ meetings; and
- Communicate membership renewal and other business-related information.
The minutes of all members’ meetings, including the Annual General Meeting, will include a list of individuals attending the meeting, their membership status, and details related to the transaction of business. NYWC will disclose a member’s personal information only with consent or when required or permitted by law.
VOLUNTEER PERSONAL INFORMATION
We collect personal information for volunteers, or prospective volunteers, to determine your eligibility, match your skills with our volunteer needs, and manage volunteer activities in accordance with our volunteer policies. Personal information related to volunteer recognition will be shared only with your consent.
4. ELECTRONIC COMMUNICATIONS
In addition to respecting and protecting privacy, NYWC is committed to responsible electronic communications. We share general information about programs, services and organizational activities through newsletters and bulletins hosted on a reputable, permission-based, email platform. We use data collected through the platform to help us communicate with you responsibly, understand your engagement with us, and provide you with the content you want.
If you sign up for one or more of our email lists, we will collect your email address, information on consent, and any other information you choose to share. The platform includes a web beacon that tracks your subscription activity and provides us with information about your email delivery, opens, clicks and subscription preferences.
All emails you receive through the platform include an easy, automated way to stop receiving emails from us by simply clicking on the “unsubscribe” link at the bottom of every email.
Direct electronic communication between you and NYWC will be sent only through a valid “@nywc.org” email address. It is important to note that email is not a secure means of transmission and can be vulnerable to interception. We strongly discourage sharing personal information via email. You assume the risk if you choose to do so.
“Cookies” are small text files of information that a website sends to your computer. Your computer stores these cookies in your web browser. Cookies cannot be used to run programs or deliver viruses to a user’s computer.
The NYWC website collects cookies from your browser to help us gather information to make your experience on our website easier and more convenient. We do not trade, rent or sell information gathered from our website. Information collected from cookies helps NYWC to better understand when and how people use our website so that we can make improvements to it. Cookies are anonymous and do not store personal information.
You can disable cookies in your internet browser’s settings. You will still be able to access our website, although some features may not work as smoothly.
6. WEB ANALYTICS
The NYWC website uses Google Analytics to track performance on our website and understand how to serve you website visitors.
The type of information collected may include:
- IP address of the device that has been used to connect to the NYWC website;
- Type of browser used;
- Type of operating system used;
- The dates and times of visits to NYWC’s website;
- Pages visited and documents downloaded; and
- Referral sources to our sites.
In compliance with the Google Analytics Terms of Service, personally identifiable information is never passed to Google Analytics. Google Analytics makes your data anonymous by removing part of your IP address. Cookies used by Google Analytics will expire two years after your last visit to our website. Google Analytics stores its data within the United States of America and is subject to US laws. For more information, consult the Google Analytics website.
You can opt out of Google Analytics data collection with the Google Analytics Opt-out Browser Add-on.
7. SOCIAL MEDIA
Your use of social media sites is governed by the privacy policies of individual platforms. We do not capture or store login or other personal data for these services, but session information or cookies may be stored. Users who choose to interact with NYWC via Facebook, Twitter, Instagram, or LinkedIn should read the terms of service and privacy policies of these third-party service providers and the terms of service of any applications you use to access them.
Information from conversations between you and NYWC on social media platforms, such as questions and answers, comments, "likes," and retweets, may be used to respond to inquiries, or for statistical, evaluation and reporting purposes.
NYWC uses social media to engage with and foster a community that is safe and respectful. Comments that contradict NYWC mission and values may be deleted.
8. LINKS TO OTHER SITES
9. ACCURACY, ACCESS AND RETENTION
NYWC makes reasonable efforts to keep personal information accurate, complete and as up-to-date as is necessary for the purposes that it is being collected and used for. Please contact a NYWC staff member if you would like to see what personal information NYWC has about you, or need to update or correct your personal information. We reserve the right to ask for identification before providing you with access to your personal information held by NYWC.
You have a right to
- Know what personal information NYWC collects and why;
- See the personal information NYWC has about you;
- Ask for help in understanding this information;
- Have errors or omissions in your record corrected;
- Withdraw or refuse to give your consent to share or use your information;
- Change your mind about sharing or using your information; and
- Register a complaint if you think your privacy is not being protected.
NYWC will retain your personal information only as long as is necessary for the purposes for which it is collected, or as required by law.
10. PROTECTION OF PERSONAL INFORMATION
NYWC does not trade, rent or sell personal information or any information collected.
NYWC is committed to protecting your personal information from loss or theft, as well as unauthorized access, use or disclosure, regardless of the format in which the information is stored. NYWC has technical measures in place such as passwords and encryption; physical measures such as locked filing cabinets; and organizational measures such as limiting access to only those who “need to know” to fulfil their job responsibilities. All measures are appropriate to the sensitivity level of the information. Your personal information will continue to be protected even after your relationship with NYWC has ended.
We will not disclose your personal information, except with your consent or if required by law. If we are obliged or permitted to disclose information without consent, we will not disclose more information than is minimally required in the circumstances. We may seek additional consent in situations where we consider it necessary or appropriate.
12. HOW TO REACH US
If you have any questions or concerns about NYWC’s privacy practices, including how your personal information has been collected or used, or to register a complaint, please contact our executive director using the contact information below.
Mail: 116 Industry Street, Toronto, ON M6M 4L8
Further information on privacy and your rights with respect to your personal information can be found on the website of the Privacy Commissioner of Canada at www.priv.gc.ca or the Office of the Information and Privacy Commissioner of Ontario at www.ipc.on.ca.