General Policy Statement

The County Foundation (TCF) recognizes the value of its relationships with donors (existing and potential), volunteers and employees, and is committed to respecting and protecting their personal information.  We value the trust of those we deal with, and of the public, and recognize that maintaining this trust requires transparency and accountability in our treatment of the personal information entrusted to us.

Our privacy policy is based on and adheres to the principles that comprise the Canadian Standards Association Model Privacy Code.

Principle #1 – Accountability (the organization shall designate an individual or individuals who are accountable for the organization’s compliance with the privacy policy)

At The County Foundation, the Executive Director has been designated as the Chief Privacy Officer and is responsible for ensuring that the policy is operational and followed.  From time to time, as appropriate, the President may designate the responsibilities of Chief Privacy Officer to another individual.

Principle #2 – Identifying Purposes (TCF shall identify the purposes for which personal information is collected when or before such information is collected)

Information collected will be limited to that which is necessary for TCF’s projects, programs and activities.

Personal information collected from our donors will be used:

• To comply with CRA requirements for gift processing
• To provide donors with information about how donated funds are used by TCF
• To keep donors informed of relevant activities and to promote opportunities to support the foundation.

TCF, during the course of its various projects and activities, may also collect personal information from Board members, other volunteers and employees.  TCF will identify to those individuals the purposes for which such information is collected before or during time of collection.

Principle #3 – Consent (knowledge and consent of individuals is required for the collection, use or disclosure of personal information)

TCF will ensure that individuals understand the nature, purposes and consequences of what they are consenting to at or before the time of collection.  This includes providing key elements so that individuals can quickly understand the impact of their privacy decisions with clear options to say yes or no.

Consent may be given in writing, through an opt-in process or orally (in person or by telephone).  Implied consent will be relied upon only in strictly defined circumstances.

Individuals may withdraw their consent at any time, in writing and by providing TCF with reasonable notice.  Consent may not be withdrawn retroactively.

TCF may collect, use and disclose personal information without consent where such information is deemed to be in the public domain.

Principle #4 – Limiting Collection (the collection of personal information will be limited to that which is necessary for the identified purposes.  Information will be collected by fair and lawful means)

TCF will determine the minimum amount of personal information that is necessary and reasonable to fulfill the purposes outlined under principle #2.

Principle #5- Limiting Use, Disclosure and Retention (Personal information shall not be used or disclosed for purposes other than those for which it was collected.  Personal information shall be retained only as long as necessary for the fulfillment of those purposes.)

Should The County Foundation want to use personal information for purposes other than those given at the time of collection, consent will be obtained for new purposes.

TCF does not sell, rent or trade mailing lists.

Personal information will be retained for as long as the business purposes for which the information was originally collected remain valid, or as required by law.

Principle #6 – Accuracy (personal information shall be as accurate, complete and up-to-date as is necessary for the purposes for which it is to be used.)

TCF will use its best efforts to ensure information in its possession is complete, accurate and up-to-date.

Individuals may request corrections to their personal information by notifying The County Foundation in writing.

Principle #7 – Safeguards (personal information shall be protected by security safeguards appropriate to the sensitivity of the information)

TCF makes reasonable security arrangements to protect personal information from risks such as unauthorized access, collection, use, disclosure or disposal.

We ensure our employees are trained in the importance of maintaining confidentiality of personal information.  We exercise care in the disposal and destruction of personal information to prevent unauthorized parties from gaining access to it.  All employees and volunteers are required to sign our Confidentiality Agreement.

Our methods of protection include physical safeguards (such as locked file cabinets), administrative safeguards (such as limiting access on a “need to know basis”) and technology safeguards (such as use and updating of passwords).

Third party service providers, such as mailing services or data analysis providers, are informed of our privacy protocols and are required to sign our Confidentiality Agreement.

Principle #8 – Openness (the organization shall readily make available to individuals information about its policies and practices relating to the management of personal information)

Information that will be available to individuals regarding TCF’s use and management of personal information include:

• Name and contact information of the Chief Privacy Officer
• Purposes for information collection
• A general description of the types of personal information held by TCF
• A copy of our policy and any other documents that explain privacy procedures, standards and codes
• A general description of any personal information shared with third parties and who those third parties are.

Principle #9 – Individual Access (upon request, an individual shall be informed of the existence, use and disclosure of his/her personal information and shall be given access to that information.  An individual will be able to challenge the accuracy and completeness of personal information, and have it amended, as appropriate)

To access personal information, a written request will be made to the Chief Privacy Officer.  The requesting individual will be asked to provide proof of identity.

Upon request, TCF will provide specific information about third parties to whom personal information has been disclosed, unless prevented from doing so by applicable confidentiality or non-disclosure agreements.

Mostly, responses will be provided without cost to the individual requesting access to their information.  However, where such requests require a significant of time and resources, we may charge a reasonable fee to recover our costs.  Such fees will be estimated with the estimate provided to the requesting party prior to any work being undertaken.

Where an individual has successfully demonstrated the inaccuracy or incompleteness of personal information in the control or custody of TCF, the Foundation will amend the information as required.

Principle #10 – Challenging Compliance (an individual shall be able to address a challenge concerning compliance with the above principles to the person or persons responsible for the organization’s compliance)

The name of TCF’s Chief Privacy Officer will be known to staff and made available to the public on the website and other relevant documents.

TCF will maintain procedures to receive and respond to complaints or inquiries about its policies and practices for handling personal information.  Complaint procedures will be easily accessible and simple to use.

Individuals making complaints shall be given relevant information about TCF’s complaints procedures.

Where a complaint has been found to be justified, TCF will take appropriate measures, including revision to personal information and, if necessary, amend the Foundation’s policies and practices.

How to Contact the Privacy Officer:

Executive Director
The County Foundation
Suite 107 – 35 Bridge Street
Picton, ON                                                                                                                                                   Email: ed@thecountyfoundation.ca