DOMINION IN CHRIST INTERNATIONAL MINISTRIES (“DICIM”)
GENERAL PRIVACY POLICY
OUR COMMITMENT TO PRIVACY AND OUR PRIVACY PRACTICES
DICIM is committed to protecting the privacy, confidentiality and security of the personal information of DICIM’s members, constituents, supporters and other stakeholders. DICIM values the trust of those DICIM deals with and recognizes that maintaining that trust requires that DICIM be transparent and accountable in how DICIM treats the information that you provide to DICIM.
During the course of DICIM’s various activities, DICIM frequently gathers and uses personal information. Anyone from whom DICIM collects such information should expect that it will be carefully protected and that except as otherwise legally required or permitted any use or other dealing with this information is subject to consent. DICIM’s privacy practices are designed to achieve this.
Personal information gathered by DICIM is kept in confidence. DICIM staff is authorized to access personal information based only on their need to deal with the information for the reasons for which it was obtained. Safeguards are in place to ensure that the information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered. DICIM also takes measures to ensure the integrity of this information is maintained and to prevent it being lost or destroyed.
This policy is based on the Ten Privacy Principles contained in the Canadian Standards Association (CSA) Model Code for the protection of personal information and on which the relevant privacy legislation is founded. DICIM has tailored its own ten privacy principles in compliance with the relevant privacy legislation to meet the specific needs and expectations of its stakeholders.
SCOPE OF POLICY
This policy applies to personal information of individual stakeholders in the possession and control of DICIM. This policy does not apply to information collected, used or disclosed with respect to corporate or commercial entities that deal with DICIM. Corporate and commercial information is protected by other policies and practices of DICIM and through contractual arrangements.
This policy does not apply to the collection, use or disclosure of publicly available information by DICIM.
DEFINITIONS
In this policy:
“Dominion In Christ International Ministries ” means Dominion In Christ International Ministries which operates a ministry at Mississauga, ON.
“business contact information” means information to contact a person at a place of business, including the person’s name, position, business address, business telephone number, business email address and business fax number.
“collection” means the act of gathering, acquiring, or obtaining personal information from any source, including third parties, by any means.
“consent” means voluntary agreement to the collection, use and disclosure of personal information for specified purposes. Consent may be express or implied. Express consent may be given orally or in writing, if it is clear and does not require any inference on the part of DICIM. Implied consent exists when DICIM can reasonably infer consent based upon your action or inaction.
“disclosure” means making personal information available to others outside of DICIM.
“personal information” means information about an identifiable person that is recorded in any form but does not include his or her business contact information. Personal information includes a person’s age, gender, race, ethnic origin, identification numbers, financial and credit information, personal health information, religious affiliations, donation history, travel history, consumer preference information, personal habits, personal interests and personal history.
Personal information does not include information that cannot be associated with a specific person.
“privacy officer” means a person designated by DICIM who is accountable for compliance with this policy by DICIM and whose contact information is set out at the end of this policy.
“third party” means a person or organization other than DICIM and you.
“use” means the treatment and handling of personal information by and within DICIM.
“you” means a DICIM member, constituent, supporter, stakeholder and anyone else from whom DICIM collects personal information.
1. DICIM ACCOUNTABILITY
DICIM is accountable and responsible for personal information under its control, including information that has been transferred to a third party. In cases where such transfers take place DICIM will ensure that the third party has comparable privacy safeguards in place. DICIM has designated a privacy officer to ensure compliance with this policy. Ultimate accountability for DICIM compliance rests with the Board of Directors of DICIM who delegates day-to-day accountability to the privacy officer. Other persons within DICIM may be accountable for the day-to-day collection and processing of personal information or may act on behalf of the privacy officer. DICIM will adopt policies, procedures and practices to protect personal information, receive and respond to complaints and inquiries, train staff regarding privacy policies, procedures and practices and communicate policies, procedures and practices to you.
2. IDENTIFYING THE PURPOSES OF PERSONAL INFORMATION
When collecting personal information DICIM will orally or in writing state the purpose of collection and will provide, on request, contact information for the privacy officer who can answer questions about the collection.
DICIM may collect your personal information for the following purposes:
- to provide and administer resource materials and other related products and services through DICIM;
- to provide and administer pastoral support and services and other related support and services through DICIM;
- to provide administrative services through DICIM;
- to assess applications for membership in DICIM by prospective members;
- to contact DICIM members, constituents, supporters and other stakeholders regarding resource materials and other related products and services of DICIM;
- to contact DICIM members, constituents, supporters and other stakeholders for special events, promotions, fund raising and other similar matters, which are directly or indirectly beneficial to DICIM;
- to administer the policies, procedures and practices of DICIM;
- to thank and publicly recognize DICIM members, constituents, supporters and other stakeholders;
- to provide members, constituents, supporters and other stakeholders with information about how donated funds are used by DICIM;
- to keep DICIM members, constituents, supporters and other stakeholders informed about DICIM activities;
- to promote opportunities for members, constituents, supporters, potential constituents and supporters and other stakeholders to support DICIM;
- to establish and maintain lists of members, constituents, supporters and other stakeholders;
- to conduct surveys or research;
- to compile statistical and historical information about members, constituents, supporters and other stakeholders;
- to establish and maintain subscriptions to publications of DICIM or related organizations;
- to build and maintain relationships among stakeholders within DICIM;
- to disclose information requested by third parties (with permission of members, constituents, supporters or other stakeholders);
- to protect DICIM, you and others from fraud and error and to safeguard the interests of DICIM and its staff and representatives;
- to authenticate your identity;
- to ensure staff and contractors comply with their agreements and legal obligations to DICIM;
- to administer relations with municipal, provincial and federal authorities, and other organizations with whom DICIM has relations from time to time;
- to comply with applicable Canada Revenue Agency requirements;
- to comply with any legal or regulatory requirement; and
- to use and disclose for any other purpose directly or indirectly related to the establishment or operation of DICIM.
The above collections, uses and disclosures are a reasonably necessary part of your relationship with DICIM.
When your personal information is to be used for a purpose not previously identified, the new purpose will be disclosed to you prior to such use, and your consent will be sought unless the use is permitted or required by law.
3. CONSENT
DICIM will obtain your consent to collect, use or disclose personal information except where DICIM is permitted or required by law to do so without consent. For example DICIM may collect, use or disclose personal information without your consent where:
- DICIM reasonably expects that obtaining consent would compromise an investigation or proceeding;
- DICIM’s use of the information is for acting in an emergency that threatens a person’s life, health or personal security;
- DICIM is obtaining legal advice; or
- DICIM needs to deal with an anticipated breach of law.
DICIM will make reasonable efforts to ensure that you understand how your personal information will be used and disclosed.
Your consent may be express or implied and may be given through an authorized representative such as a lawyer or agent. If you are under the legal age, your consent may be obtained from a parent or guardian.
Express consent may be given orally, in writing or electronically. For example, oral consent could be given over the telephone when information is being collected; electronically when submitting an agreement, application or other information; or in writing when signing an agreement or application. Consent may be implied by DICIM if the purpose for the collection of the information would be reasonably obvious to you and is given voluntarily by you for that purpose. Consent may also be implied where DICIM notifies you that DICIM intends to collect, use or disclose information and you do not decline DICIM’s intended action within a reasonable period of time. The manner in which DICIM obtains consent for the collection of personal information will vary with the sensitivity of the information being collected.
You may withdraw your consent at any time, subject to legal or contractual restrictions, provided that DICIM is given reasonable written notice. DICIM will inform you of the likely consequences of the withdrawal of consent, which may include the inability of DICIM to provide products or services to you.
4. LIMITS FOR COLLECTING PERSONAL INFORMATION
DICIM will only collect personal information that is reasonably necessary to provide a product or service either directly or indirectly and which is reasonably necessary for the purposes which you consented to. DICIM will collect personal information by lawful means. DICIM may also collect information as permitted or required by law.
5. LIMITS FOR USING, DISCLOSING AND KEEPING PERSONAL INFORMATION
Your personal information will only be used or disclosed for the purpose for which it was collected. DICIM will not use personal information for any additional purpose unless DICIM seeks your consent to do so.
DICIM may periodically use your personal information to conduct surveys in order to enhance DICIM’s provision of products or services.
DICIM will not sell DICIM member, constituent, supporter and other stakeholder lists or personal information to third parties.
DICIM will retain your personal information only so long as necessary for the identified purposes or for necessary legal or business purposes. DICIM will keep your personal information used to make a decision affecting you for at least one year after using it to make the decision. DICIM will also keep personal information that is the subject of a request by you for as long as is necessary to allow you to exhaust recourse with respect to this personal information. Once DICIM no longer has a reason to retain your personal information, DICIM will destroy, erase or make anonymous documents or the records containing personal information.
6. ACCURACY
DICIM will make reasonable efforts to ensure your personal information is as accurate, complete and current as required for the purposes for which it was collected. In some cases, DICIM will rely on you to ensure that certain information, such as your street address, e-mail address or telephone number, is current, complete and accurate.
DICIM will not routinely update your personal information unless it is necessary to fulfill the purposes for which it was collected. You may request amendments to the records at DICIM to ensure the accuracy and completeness of your personal information. If the amendment request relates to information that remains in dispute, DICIM will note your opinion on the file.
7. SAFEGUARDING PERSONAL INFORMATION
DICIM is committed to the safekeeping of your personal information in order to prevent its loss, theft, unauthorized access, disclosure, duplication, use or modification.
Depending on the sensitivity of your personal information, DICIM will employ appropriate security measures to protect the information. The measures may include, for example, the physical security of offices and data centres, the limiting of access on a “need-to-know” basis and the use of passwords and encryption.
DICIM will also use appropriate security measures when disposing of your personal information.
DICIM will require third parties through contractual or other reasonable means to safeguard your personal information entrusted to them in a manner consistent with the policies, procedures and practices of DICIM.
8. AVAILABILITY OF POLICIES AND PROCEDURES
DICIM is open about the policies, procedures and practices it uses to protect your personal information. Information about these policies, procedures and practices will be made available to you either electronically or in writing. To ensure the integrity of our security procedures and business methods, DICIM may refuse to publicly disclose certain information.
DICIM will make the following information available:
- The name, title and address of the person accountable for the polices, procedures and practices and to whom complaints or inquiries can be provided;
- A description of the type of personal information held by DICIM, including a general account of its use;
- A copy of any documents that explain the policies, procedures and practices; and
- An explanation of what personal information is made available to related organizations.
9. PROVIDING ACCESS TO YOUR PERSONAL INFORMATION
You have a right to access your personal information held by DICIM. Upon request and confirmation of your identity, DICIM will, within a reasonable period of time, tell you what personal information it has, what it is being used for and to whom it has been disclosed. You may be asked to be specific about the information that you would like to access and to submit your request in writing. Depending on the type and amount of information requested, DICIM may charge you a reasonable fee for providing you with access to your information. Where a cost will be incurred by you, DICIM will inform you of the cost and request your direction on whether or not DICIM should proceed with the request.
DICIM will make the information available within 30 days or provide written notice where additional time is required to fulfill the request.
In some situations, DICIM may not be able to provide access to certain personal information. The reasons for not providing this information may include that it is information that would threaten the life or security of another person, information generated in a formal dispute resolution process, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons and information that is subject to solicitor-client privilege.
If a request is refused, DICIM will notify you in writing, setting out the reasons for the refusal and resources for redress available to you.
If your personal information is demonstrated to be inaccurate or incomplete, DICIM will amend the information as required. Where appropriate DICIM will send the amended information to third parties to whom the information has been disclosed.
10. COMPLIANCE AND COMPLAINTS
DICIM will, on request, provide you with information regarding its complaint response procedure.
You are to direct any complaints, concerns or questions regarding this policy in writing to the privacy officer. If the privacy officer is unable to address your concern, the issue can be referred to the Board of Directors of DICIM. At any point in this process you may also write to the Privacy Commissioner.
Contact Information:
Privacy Officer
18 – 3075 Ridgeway Drive
Mississauga, ON L5L 5M6
Phone: 905-569-1226