Private Sector Privacy Legislation

Personal Information Protection Policy

 RightNow HQ Canada

 Personal Information Protection Policy

At RightNow HQ Canada, we are committed to providing our donor or supporters with exceptional service.  As providing this service involves the collection, use and disclosure of some personal information about our donor or supporters, protecting their personal information is one of our highest priorities.

While we have always respected our donor or supporters privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA).  PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

We will inform our donor or supporters 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 PIPA, outlines the principles and practices we will follow in protecting donor or supporters’ personal information.  Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our donor or supporters’ personal information and allowing our donor or supporters to request access to, and correction of, their personal information.

Scope of this Policy

This policy also applies to any service providers collecting, using or disclosing personal information on behalf of RightNow HQ Canada.

Definitions

Personal Information –means information about an identifiable individual such as name, age, home address, phone numbers, marital status, religion, employment, and/or emails. 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 PIPA.

Privacy Officer – means the individual designated responsibility for ensuring that RightNow HQ Canada complies with this policy and PIPA.

Policy 1 – Collecting Personal Information

1.1  Unless the purposes for collecting personal information are obvious and the donor or supporter 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 donor or supporter information that is necessary to fulfill the following purposes: 

• To verify identity;
• To identify donor or supporter preferences;
• To understand the banking needs of our donor or supporters; 

• To contact our donor or supporters for fundraising;
• To ensure a high standard of service to our donor or supporters;
• To meet regulatory requirements;

Policy 2 – Consent

2.1  We will obtain donor or supporter 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 through providing donor or supporter information on our website, social media, or directly to an officer of the organization, or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the donor or supporter voluntarily provides personal information for that purpose.

2.3  Consent may also be implied where a donor or supporter is given notice and a reasonable opportunity to opt-out of his or her personal information being used for communications and fundraising and the donor or supporter 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), donor or supporters can withhold or withdraw their consent for RightNow HQ Canada to use their personal information in certain ways.  A donor or supporter’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 donor or supporter in making the decision.

2.5  We may collect, use or disclose personal information without the donor or supporter’s knowledge or consent in the following limited circumstances: 

• When the collection, use or disclosure of personal information is permitted or required by law;
• When we require legal advice from a lawyer;
• To protect ourselves from fraud;
• To investigate an anticipated breach of an agreement or a contravention of law

Policy 3 – Using and Disclosing Personal Information

3.1  We will only use or disclose donor or supporter personal information where necessary to fulfill the purposes identified at the time of collection for a purpose reasonably related to those purposes such as: 

• To conduct donor or supporter surveys in order to enhance the provision of our services;
  • To contact our donor or supporters directly about fundraising opportunities;
  • To contact our donor or supporters directly about our ongoing activities.

3.2  We will not use or disclose donor or supporter personal information for any additional purpose unless we obtain consent to do so.

3.3  We will not sell donor or supporter lists or personal information to other parties unless we have consent to do so. 

Policy 4 – Retaining Personal Information

4.1  If we use donor or supporter personal information to make a decision that directly affects the donor or supporter, we will retain that personal information for at least one year so that the donor or supporter has a reasonable opportunity to request access to it.

4.2  Subject to policy 4.1, we will retain donor or supporter 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 donor or supporter personal information is accurate and complete where it may be used to make a decision about the donor or supporter or disclosed to another organization.

5.2  Donor or supporters 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 donor or supporters’ correction request in the file. 

Policy 6 – Securing Personal Information

6.1  We are committed to ensuring the security of donor or supporter 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 donor or supporter personal information is appropriately protected:

• Donor and supporter physical information will be stored on a secured site in a locked filing cabinet;
• Donor and supporter electronic information will be stored on a secured website with the proper use of IDs, passwords, encryptions and firewalls;
• Donor and supporter information (both electronic and physical) will only be accessible to employees and officers of the organization with the proper clearance from management.

6.3  We will use appropriate security measures when destroying donor or supporter’s personal information such as:

• The shredding of donor or supporter physical information;
• The deleting of donor or supporter electronic 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 Donor or supporters Access to Personal Information

 7.1  Donor or supporters have a right to access their personal information, subject to limited exceptions:

• Solicitor-client privilege;
• Disclosure would reveal personal information about another individual.

7.2  A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. 

7.3  Upon request, we will also tell donor or supporters 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 donor or supporter of the cost and request further direction from the donor or supporter 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 donor or supporter in writing, providing the reasons for refusal and the recourse available to the donor or supporter. 

Policy 8 – Questions and Complaints:  The Role of the Privacy Officer or designated individual

8.1  The Privacy Officer or designated individual is responsible for ensuring RightNow HQ Canada’s compliance with this policy and the Personal Information Protection Act.

8.2  Donor or supporters should direct any complaints, concerns or questions regarding RightNow HQ Canada’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the donor or supporter may also write to the Information and Privacy Commissioner of British Columbia.

Contact information for RightNow HQ Canada’s Privacy Officer or designated individual:

Scott Hayward

[email protected]