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PERSONAL INFORMATION PROTECTION POLICY
At NG Pride we are committed to providing our followers and clients with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our followers, clients, Board members and volunteers protecting their personal information is one of our highest priorities.
In compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), which came into effect on April 13, 2000, we will inform individuals 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 personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of personal information and allowing individuals to request access to, and correction of, their personal information.
Scope of this Policy
This Personal Information Protection Policy applies to NG Pride and any service provided by; event planned and/or hosted by; or purchase made through NG Pride.
Personal Information –means information about an identifiable individual (E.g., including name, home address and phone number, credit card information). Personal information does not include contact information (described below).
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPEDA.
Privacy Officer – means the individual designated responsibility for ensuring that NG Pride complies with this policy and PIPEDA.
1.1 Unless the purposes for collecting personal information are obvious and the individual 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 information that is necessary to fulfill the following purposes:
Policy 2 – Consent
2.1 We will obtain 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 representative or it can be implied where the purpose for collecting , using or disclosing the personal information would be considered obvious and the client voluntarily provides personal information for that purpose.
2.3 Consent may also be implied where an individual 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 products, fundraising and the individuals does not opt-out.
2.4 Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), individuals can withhold or withdraw their consent for NG Pride to use their personal information in certain ways. An individuals’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the individual in making the decision.
2.5 We may collect, use or disclose personal information without the individual’s knowledge or consent in the following limited circumstances:
Policy 3 – Using and Disclosing Personal Information
3.1 We will only use or disclose 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:
3.2 We will not use or disclose personal information for any additional purpose unless we obtain consent to do so.
3.3 We will not sell contact lists or personal information to other parties.
Policy 4 – Retaining Personal Information
4.1 If we use personal information to make a decision that directly affects the individual, we will retain that personal information for at least one year so that the individual has a reasonable opportunity to request access to it.
4.2 Subject to policy 4.1, we will retain 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 personal information is accurate and complete where it may be used to make a decision about the individual or disclosed to another organization.
5.2 Individuals 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. A request to correct personal information should be forwarded to the Privacy Officer or designated individual.
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 individual’s correction request in the file.
Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of 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 personal information is appropriately protected:
6.3 We will use appropriate security measures when destroying personal information such as shredding documents and deleting 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.
Policy 7 – Providing Access to Personal Information
7.1 Individuals have a right to access their personal information, subject to limited exceptions, such as;
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer.
7.3 Upon request, we will also tell individuals how we use their personal information and to whom it has been disclosed if applicable.
7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the individual of the cost and request further direction from the individual on whether or not we should proceed with the request.
7.6 If a request is refused in full or in part, we will notify the individual in writing, providing the reasons for refusal and the recourse available to the individual.
Policy 8 – Questions and Complaints: The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer is responsible for ensuring NG Pride’s compliance with this policy and the Personal Information Protection and Electronic Documents Act.
8.2 Individuals should direct any complaints, concerns or questions regarding NG Pride’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client may also write to the Privacy Commissioner of Canada.
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