Purpose 

This Privacy Policy is based on the principles set out in the Canadian Standards Association Model Privacy Code. 

Prince Edward County Community Foundation (the “County Foundation”) recognizes the importance of the privacy of its fundholders, donors, prospective donors, employees, Board members, volunteers, community partners and other stakeholders. This Privacy Policy (the “Policy”) provides information about Personal Information, including practices for collection by the County Foundation, and provides information about the use and disclosure of Personal Information received in the course of the County Foundation’s charitable work. This Policy describes the County Foundation’s online and offline information practices and use, how someone can opt out, correct or change Personal Information.  

The County Foundation will protect Personal Information in accordance with this Policy, and in its relations with everyone, including existing and potential donors, volunteers, and employees. The County Foundation acknowledges and recognizes that maintaining trust in managing Personal Information requires transparency and accountability. Board members, committee members and staff will sign an annual commitment to abide by this Policy.  

What is Personal Information?  

For the purposes of this Policy, “Personal Information” means information about an identifiable individual; including any identity information including name, age, income, other demographic information and photographic likeness.  

Scope 

This Policy applies to Personal Information collected by the County Foundation, including on the County Foundation website (“Site”), mobile applications, blogs and other current or future online or offline services, managed by or on behalf of the County Foundation (the “Services”).  

Everyone whose responsibilities include the collection of Personal Information on behalf of the County Foundation will protect Personal Information in accordance with this Policy.  

This Policy does not apply to any third-party websites, services or applications, even if they are accessible through the Services. 

The County Foundation will identify the purpose for collection of Personal Information, which will becollected in a timely way as may be practical. 

In all cases Personal Information collected will be limited to what is necessary and essential for the County Foundation to maintain operations, including charitable work, programs, and other activities. 

For example, the County Foundation may use Personal Information from its fundholders, donors and prospective donors to identify and help them meet their philanthropic needs, manage their preferences, process their donations, provide tax receipts, direct their gifts, and keep prospective donors informed about gift giving opportunities. 

The County Foundation manages Personal Information from its grant applicants to verify eligibility, to notify applicants of funding decisions, for program evaluation and reporting and to issue grant disbursements.  

The County Foundation manages Personal Information from its Board members and other volunteers to inform its activities, assist volunteers in performing their roles, manage its operations, and to administer the Site.  

The County Foundation manages Personal Information from its staff to help administer employee benefit programs, accommodate individuals in the workplace, support staff with illnesses or injuries in returning to work, staff training and development, and other activities including Site and operations management.  

All the County Foundation’s activities in respect of this Policy and the management of Personal Information will comply with applicable federal and provincial legal and regulatory guidelines and reporting requirements.  

Principle #3 Consent  

Consent is required for the individual collection, use or disclosure of Personal Information by the County Foundation. 

The County Foundation acknowledges its obligation to reasonably ensure that individuals understand the nature, purposes and consequences of this Policy and practices in the management of Personal Information.  

Consent can be provided directly by an individual or by their authorized representative, in words, writing or through electronic means like online approvals (e.g. “ checkbox”).  

Implied consent may be reasonably inferred from an individual’s action or inaction.  For example, by using the Site to provide Personal Information to the County Foundation, visitors to the Site consent to the use of Personal Information in accordance with this Policy.  

The County Foundation obtains consent for collecting, using and disclosing fundholder information, such as names and name of the fund, in publications and reports.  The County Foundation will seek subsequent consents from fundholders if the purpose for collection, use or disclosure of the Personal Information changes.   

Principle #4 Limiting Collection  

Personal Information collection is limited to only what is necessary and essential for the County Foundation’s activities, in accordance with all applicable laws and regulations, for it to reasonably fulfill the purposes set out in this Policy. 

Principle #5 Limiting Use, Disclosure and Retention  

Personal Information will not be used or disclosed for purposes other than those for which it was collected and will be retained only as long as needed. 

The County Foundation will obtain subsequent and additional consents when the purpose for which Personal Information was initially obtained changes. 

The County Foundation does not sell, rent or trade mailing lists. 

Personal Information will be retained for as long as the purposes for which the information was originally collected remain valid, or as required by law, reasonably subject to the best practices and applicable laws regarding retention and records destruction.  

Principle #6 Accuracy  

The County Foundation will use best efforts to keep Personal Information as accurate, complete and up-to-date as necessary for it to effectively fulfill its operational mandate. 

Individuals may request corrections and updates to their Personal Information by notifying the Chief Privacy Officer, using the contact information provided above.  

Principle #7 Safeguards  

Personal Information will be protected by a range of security safeguards, appropriate to the circumstances and the sensitivity of information. 

At all times, the County Foundation takes reasonable security precautions to protect Personal Information from risks such as unauthorized access, collection, use, disclosure or disposal. 

Precautions to protect Personal Information include physical, administrative and technological measures.  Measures to safeguard privacy include locked and fire-proof file cabinets, limiting access by physical means like keys and through limiting confidentiality, and also the use and updating of passwords and employing electronic means, like firewalls.  

The long-term confidentiality of all donor and volunteer records will be in accordance with the County Foundation’s records management policy.  

Third party service providers, such as mailing services or data analysis providers, are informed of the County Foundation’s privacy protocols and are required to sign its Confidentiality Agreement. 

Principle #8 Openness  

The County Foundation will make information available to individuals about this Policy and practices relating to the management of Personal Information. 

This Policy is available for review on the Site.  

Principle #9 Individual Access  

When requested, any individual will be informed of the existence, use and disclosure of their Personal Information and given access to that information.  An individual can challenge the accuracy of their own Personal Information, to have it amended. 

To make a request to access their own Personal Information, individuals should contact the County Foundation’s Chief Privacy Officer and may be required to show proof of identity. 

Upon request, the County Foundation will provide specific information about third parties to whom Personal Information has been disclosed, subject to applicable confidentiality or non-disclosure agreements. 

The County Foundation will make a reasonable effort to provide requested personal information without cost to the individual requesting access to their information. However, where such requests require a significant use of time and resources, the County Foundation at its sole discretion may charge a reasonable fee, upon notice, to recover costs.   

Individuals may request updates and corrections to their Personal Information by notifying the Chief Privacy Officer.  Where an individual has successfully demonstrated the inaccuracy or incompleteness of Personal Information in the control or custody of the County Foundation, the County Foundation will amend the information as required. 

Principle #10 Challenging Compliance  

The County Foundation will maintain procedures to receive and respond to complaints or inquiries about its policies and practices for handling Personal Information.   

An individual may challenge compliance with this Policy by contacting the Chief Privacy Officer or the Board Chair.  Where the Chief Privacy Officer or Board Chair is not available to receive a challenge, for any reason, individuals may direct challenges to the next available executive officer of the County Foundation.  

The name of the County Foundation’s Chief Privacy Officer will be known to staff and made available to the public on the Site, and as needed in other relevant documents. 

Where a complaint or challenge to compliance has been found to be justified, the County Foundation will take appropriate measures, including revision to Personal Information and, if necessary, to amend the County Foundation’s policies and practices. 

This Policy may be amended from time to time. 

Approved by the Board of Directors : June 24th