Canada Without Poverty acknowledges the importance of philanthropy and the role it plays in CWP’s mission to eliminate poverty in Canada. CWP recognizes the goodwill of its supporters and pledges to maintain a high level of integrity and accountability. To achieve this, CWP adheres to the Ethical Fundraising and Financial Accountability Code developed by the Canadian Center for Philanthropy and the Canadian Marketing Association’s Code of Ethics & Standards of Practice. CWP strongly believes in the donor’s right to truthful information and privacy. The following outlines CWP’s principles regarding personal privacy:
Accountability
CWP is responsible for protecting personal information under its control.
a) It has designated a staff manager to be responsible for CWP’s adherence to the Federal Personal Informational Protection and Electronic Documents Act.
Identifying Purposes
CWP will clearly identify the primary use of the personal information and ask permission before any secondary use of the personal information.
a) CWP collects personal information primarily to communicate with its members and build relationships with its supporters.
b) Should personal information be collected during volunteer participatory activities, permission must be granted before any fundraising appeal use.
Consent
CWP recognizes that donors have control over the use of their information.
a) All new donors are given the opportunity to decline to have their name or other information used for any further marketing purposes by a third party.
b) Current donors have the opportunity to decline to have their names or other information used for marketing purposes by a third party at least every two years.
c) CWP removes a donor’s name from its existing house files or trade list promptly upon request.
d) CWP uses the Do Not Mail/Do Not Call service of the Canadian Marketing Association when conducting a campaign in order to delete the name of any person, other than a current donor, who has requested that he or she be removed from mail or telemarketing lists.
Limiting Use
CWP will control the use of information by third parties.
a) CWP does not rent its trade list.
b) CWP does exchange its trade list with other like-minded organization from time to time.
c) CWP will only exchange lists with other privacy compliant organizations.
d) CWP maintains a summary of trade list exchanges over the last 12 months and will provide the information when queried about the potential use of personal information to a third party.
Limiting Collection, Disclosure and Duration of Retention
CWP shall limit collection of information to that which is necessary for the activities noted below.
a) CWP collects the contact information, donation history and special interests of its donors in order to build on its existing relationship with its supporters.
b) CWP is obligated to retain donor information for 7 years as per Revenue Canada tax receipting guidelines.
c) CWP may collect survey information as part of its volunteer participatory activities.
d) Any personal banking information is deleted from donor records upon their cancellation from the pre-authorized payment program.
Accuracy
CWP will ensure that information is accurate, complete and up-to date as is necessary for the purpose of continuing its contact with its support base.
a) CWP will endeavor to keep donor contact records up-to-date.
b) CWP will ensure that any requests regarding donor giving preferences, i.e. limiting the number of solicitations, no further requests, do not solicit by telephone or other technology, will be added to the personal record promptly.
c) CWP will not update records with contact information that is deemed not in the public domain i.e. unlisted telephone numbers etc.
Safeguards
CWP assures the security and confidentiality of private information.
a) The CWP donor database has electronic security passwords. Access to the database is limited to select CWP personnel.
b) Any paper files with confidential financial information are stored in locked filing cabinets.
c) CWP staff are bound by CWP’s Values Statement and Confidentiality Agreement.
d) If CWP outsources data processing or enters into contracts that require handling of personal information, CWP will have written assurances that the firm abides by the law.
e) Confidential personal information is disposed of properly to prevent unauthorized use.
Access
CWP recognizes that donors have the right to access their information.
a) All CWP donors have the right to see their own donor record and to challenge its accuracy.
b) CWP will provide information about the potential use of personal information upon request.
c) All potential donors have the right to know the source of obtaining their name.
Openness & Proper Handling of Donor Complaints
CWP pledges to respond immediately to any queries about personal information or complaints regarding the use of personal information. CWP will also make readily available our privacy policies and practices relating to the management of personal information upon request. Information requests must be fulfilled within 30 days.
Anonymous Information
We routinely collect anonymous information, which is information that cannot be directly traced back to specific individuals. For example our web servers may electronically collect information from Web site visitors. This type of anonymous information might typically include specific web sites pages visited and the number of visitors.
At no time is personal information collected from our web site unless an individual chooses to provide it, e.g., via on-line donation.
We also periodically gather anonymous information from donor surveys for analytical purposes.
Disclosure of Information to Outside Parties
We strive to keep personal information private at all times. Occasionally, we may need to undergo analysis on our database systems by a third party in which case we are required to and obtain written assurances that the firm abides by privacy safeguard provisions set out in the privacy law.
There are occasions when we are required by law to allow access to donor records. For example, our external auditing firm or Revenue Canada’s auditors may request to look at a sample of representative donor records or receipts during the course of their review of our accounting procedures.
