Privacy Policy Updated
February 2006
Habitat for Humanity Victoria ( HFHV) is dedicated to protecting
your privacy and maintaining the trust that you have placed in it.
As such our privacy policy (the “Privacy Policy”) incorporates
the highest standards as set out in federal and provincial legislation.
A. Collection of Personal Information
HFHV is committed to identifying the purposes for which information
is collected at or before the time the information is collected
and to documenting the purpose for which personal information is
collected.
1. We may collect banking and credit card information to allow
us to receive and process donations. In addition, we may collect
contact information to seek donations, acknowledge donations, send
out our newsletter, send membership information , and issue tax
receipts. We deeply appreciate your financial, and in-kind support.
We may contact you to acknowledge receipt of donations, and to request
your support for our future endeavors, because you have demonstrated
interest in supporting HFHV and our mission.
2. We may collect family selection information (such as names,
ages of family members, current address, work history, income, assets,
debt, credit history, general health, condition and size of current
dwelling ) to determine if a family qualifies as a house purchaser.
The family selection committee uses this information to assess credit-worthiness,
need, stability of relationships, steady income, willingness and
ability to partner with HFHV.
3. We may collect mortgage application information, to grant mortgage
funding, collect mortgage payments, collect and pay property taxes,
transfer ownership to the new families, deal with insurance on homes,
or to engage professional mortgage administration from a third party.
4. We may collect family and neighbourhood information and statistics,
to raise awareness of and increase potential for fundraising and
new family recruitment.
5. We may collect personal information from past, present, and
prospective volunteers, employees and members for administrative,
or management purposes, such as to establish, manage or terminate
a volunteer, for employment purposes, or member relations work.
6. We do not collect personal information indiscriminately. Both
the amount and the type of information we collect is limited to
that which is necessary to fulfill the general purposes detailed
above.
7. We will not use previously collected information for a new
purpose without firstly identifying the new purpose, and obtaining
your consent for the new use, unless otherwise permitted by law.
8. You may direct any questions concerning the collection, the
use which will be made of the information, the categories of people
which may have access to it within our organization, the place where
the file would be kept, and your rights of access and rectification
to our Chief Privacy and Compliance Officer.
B. Obtaining Consent
HFHV is committed to obtaining your consent for the collection
of your personal information and the subsequent use or disclosure
of this information, unless otherwise permitted by law.
1. In obtaining consent, we make a reasonable effort to ensure
that you are advised, in a manner that can be reasonably understood,
of the purposes for which the information will be used.
2. We will not as a condition of supplying a product or service,
require you to consent to the collection, use or disclosure of personal
information beyond that required to provide that good or service.
3. We collect your personal information through fair and lawful
means, and not through false or misleading practices.
4. In determining the appropriate form of consent, we will take
into account the sensitivity of the personal information and your
reasonable expectations.
5. Consent may be given in writing, orally, electronically, through
an authorized representative, or it can be implied where the purpose
of collecting, using, or disclosing the personal information would
be considered obvious and the person voluntarily provides personal
information for that purpose. Consent my also be implied where a
person is given notice and a reasonable opportunity to opt-out of
his or her personal information being used for purposes such as
mail-outs, or fundraising, and the person does not opt-out.
6. You may withdraw your consent at any time, subject to legal
or contractual restrictions and reasonable notice, by contacting
our Chief Privacy Compliance Officer. Please note that the withdrawal
of your consent may impact on our ability to serve you and to maintain
our relationship.
Note: In certain circumstances personal information can be used
or disclosed without your knowledge and consent. For example, legal,
medical, or security reasons may make it impossible or impractical
to seek consent. When information is being collected for the detection
and prevention of fraud or for law enforcement, seeking consent
might defeat the purpose of collecting the information. In addition,
we may not be able to seek consent if we do not have a direct relationship
with you. For example, seeking consent may be impractical for a
charity or a direct marketing firm that wishes to acquire a mailing
list from another organization. In such cases, the organization
providing the list would be expected to obtain your consent before
disclosing personal information. Finally we may collect information
without consent if the collection is reasonable for the purposes
of establishing, managing, or terminating an employment or volunteer
relationship.
C. Use And Disclosure of Personal Information
HFHV does not use or disclose personal information for
purposes other than those for which it was originally collected,
except with your consent or as otherwise permitted by law.
1. We are responsible for personal information in our possession
or custody, including information that we transfer to a third party
for processing. As such, we enter into confidentiality agreements
or contractual arrangements with these third parties in which we
require them to provide a level of security comparable to that provided
in our privacy policy.
D. Protection of Personal Information
HFHV is committed to protecting your personal information
by security safeguards appropriate to the sensitivity of the information.
1. We protect personal information against loss or theft, as well
as unauthorized access, disclosure, copying, use or modification,
regardless of the format in which it is held.
2. We protect personal information with physical security measures,
such as locked fireproof file cabinets, and restricted access to
areas where this information is stored.
3. We protect personal information with organizational security
measures, such as security clearances and limiting access to a “need
to know” basis. In addition to ensuring our employees and
selected volunteers are aware of the importance of maintaining the
confidentiality of personal information, we also enter into confidentiality
or contractual agreements with third parties to whom we might provide
any personal information.
4. We use technological security measures, including passwords
and encryption to prevent unauthorized access to personal information
stored in our computer systems.
5. When disposing of or destroying personal information which
is no longer needed, we ensure that appropriate measures are taken
regarding the disposal or destruction, including shredding, so as
to prevent unauthorized parties from gaining access to the personal
information.
E. Retention Of Personal Information
HFHV is committed to retaining your personal information
only as long as necessary for the fulfillment of the general purposes
outlined above, or for the fulfillment of legal business purposes.
1. We will retain personal information that has been used to make
a decision about you for at least one year, even if retention is
no longer necessary because the identified purpose for which the
personal information was collected is no longer being served, to
allow you access to the information after the decision was made.
2. We will retain personal information that is the subject of
a request for as long as is necessary to allow you to exhaust any
recourse that you may have under federal and provincial legislation
across Canada, even if retention is no longer necessary because
the identified purpose for which the personal information was collected
is no longer served.
F. Access To Personal Information
Upon written receipt of a request, HFHV will inform you
of the existence, use and disclosure of your personal information
and will give you access to that information after reasonable time
for retrieval. You will be able to challenge the accuracy and completeness
of the information and have it amended accordingly.
1. Upon receipt of your written request, we will provide an account
of the use that has been made or is being made of your personal
information and an account of third parties to which it has been
disclosed. When it is not possible to provide a list of the third
parties to which we have actually disclosed your personal information,
we will provide a list of organizations to which we may have disclosed
your information to.
2. In responding to your written request, we may require you to
provide sufficient information to permit us to verify your identification
before we provide an account of the existence, use and disclosure
of your personal information. Please forward your request in writing
to our Chief Privacy Officer at the address set out herein.
3. If you need assistance in preparing your written request we
will assist you.
4. Within 30 days after receipt of your written request, we will
either respond to your query or send you a notice of extension,
advising you of the new time limit, the reasons for the extension,
and your right to make a complaint to the Commissioner. We may extend
the time limit for a maximum of 30 days if meeting the time limit
would unreasonably interfere with out activities or is impractical
because we need to undertake consultations necessary to respond
to your query. Or, we may extend the time limit for whatever period
is necessary to convert the personal information into an alternative
format.
5. We will respond to your written request at no or very minimal
cost you. If there is a cost involved for the transcription, reproduction
or transmission of your personal information, we will inform you
of the approximate cost beforehand and will only proceed if you
have advised us that the request is not being withdrawn.
6. The requested information will be provided or made available
in a form that is generally understandable. For example if we use
abbreviations or codes to record information, we will provide an
explanation of such abbreviations or codes.
7. In certain circumstances we may not be able to provide access
to all the personal information we hold about you. Exceptions may
include information that is prohibitively costly to provide, that
contains references of others information, that cannot be disclosed
for legal, security, or commercial proprietary reasons, and that
is subject to solicitor-client or litigation privilege. However,
if the information containing the exceptions is severable, we will
sever the information and provide you with access to the remaining
information.
8. The reasons for denying access and the statutory provisions
on which the refusal is based will be provided to you in writing,
along with any recourse that you may have under federal and provincial
legislation across Canada.
G. Correction of Personal Information
HFHV is committed to maintaining as accurate, complete,
and up-to-date personal information as is necessary for the purposes
for which it is to be used and to maintain the possibility that
inappropriate information may be used to make a decision about you.
1. We do not routinely update personal information unless such
a process is necessary to fulfill the purposes for which the information
was collected or we receive notification from you to do so. If you
are aware of changes to the personal information you have given
us, simply write our Chief Privacy and Compliance Officer and we
will update our records accordingly.
2. When the accuracy or completeness of your personal information
is successfully challenged, we will amend your personal information
as requested and issue a copy of any personal information modified
or added or an attestation that personal information has been deleted
as requested. Where appropriate, the amended information will be
transmitted to third parties having access to the information in
question.
3. Any unresolved challenges will be recorded in your files. Where
appropriate, the existence of the unresolved challenge will be transmitted
to third parties having access to the information in question.
H. Compliance
In meeting our Privacy responsibilities, HFHV will act
in a reasonable manner, as required in the circumstances.
1. We have designated our Society Secretary as Chief Privacy Compliance
Officer. The Chief Privacy Compliance Officer can be reached by
regular Mail at:
Attention Chief Privacy Compliance Officer
Habitat for Humanity Victoria
2100 Douglas Street
Victoria, B.C. V8T 4L3
Or by Email at: vhfhadmin@shaw.ca
2. A Challenge concerning compliance with privacy laws can be
addressed to our Chief Privacy Compliance Officer
3. We reserve the right to seek legal advice where appropriate
before providing a final response to inquiries or complaints.
I. Internet Useage
When you visit HFHV’s website at www.habitatvictoria.com
to obtain information about us, to research what we do, to use our
on line registries, or use our on line tools, please rest assured
that we do not collect identifying information about you unless
you specifically provide it. The only information we collect is
non-identifying information (such as the ISP, the type of internet
browser used, the referring website, the pages requested and the
date and time of the requests) to create aggregate data in order
to determine the level of interest in the information provided on
our website and to improve the content of the site.
We collect the non-identifying information through the use of cookies
and server log files, including IP addresses. Our website does not
link IP addresses to any personally identifiable information. Cookies
identify which area of our website you have visited or customized,
and make these pages readily accessible the next time you visit.
If you do not want non-identifying information collected through
the use of cookies, you can disable this function by changing the
settings of your internet provider.
In addition, we may provide links to other websites managed by
third parties or permit third parties to offer users subscriptions
and registration-based services through its website. As we cannot
control or be responsible for the actions or policies of such third
parties, you should check the applicable privacy policy of such
third parties when visiting their websites or when providing any
personal information to them. Please also note that we cannot control
or prevent the use of cookies or any information obtained through
cookies by such third parties.
Finally, please be advised that information voluntarily disclosed
online in discussion areas and other public areas of our website
can be collected, used and disclosed by third parties. Any submissions
made to discussion areas or other public areas on our website are
done at the user’s risk and with the understanding that such
information may be accessible to third parties. We cannot control
and will not be liable for any damages that may arise from such
user activity.
J. Changes To Privacy Policy
HFHV reserves the right to modify our Privacy Policy at
our discretion, in particular, the Chief Privacy Compliance Officer
will periodically review and modify our Privacy Policy in response
to developments and changes in privacy law. Any modifications shall
be effective upon its publication by any means, including posting
on our website. You agree to regularly review our Privacy Policy
posted on our website, be aware of any modifications and be bound
by the same.
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