Preface
Rossbrook House is a corporation without share capital and is registered as a charity with the Canada Revenue Agency. Rossbrook House operates a community youth centre located at 658 Ross Avenue in Winnipeg, Manitoba, providing a constant alternative to the destructive environment of the streets. Its mission is to give children and youth living in the inner city a safe place to belong, to play, to learn and to become…
Rossbrook House values the privacy of personal information of parties participating in its programs, their families / caregivers, vendors and supporters. All personal information collected is directly related to program activities, operations, or fund development activities conducted by Rossbrook House.
1.0 Purpose
This Privacy Policy outlines Rossbrook House’s commitment to protect the privacy and confidentiality of your personal information. This Privacy Policy complies with the Privacy Act and the Personal Information Protection and Electronic Documents Act of Canada. This Policy applies to all information collected and all transactions made on behalf of Rossbrook House.
2.0 Accountability
Rossbrook House is responsible for keeping personal information confidential and applying it for the intended purpose(s). A Chief Privacy Officer, designated by the Board of Directors of Rossbrook House, is responsible for Rossbrook House’s compliance to this Policy. The Chief Privacy Officer may be reached at the address noted in Section 7.2.
3.0 Personal Information
Personal information is any information that can be used to identify, distinguish or contact a specific individual. Personal information can include facts about, or related to, an individual, as well as an individual’s opinions or beliefs. Personal information does not include publicly available information such as names, addresses and telephone numbers or business contact information.
4.0 Personal Information Collection and Use
4.1 In carrying on the activities of Rossbrook House, personal information is collected about:
- the individuals who participate in programs and/or to whom services are provided,
- other constituents including the Board Directors, volunteers and staff, independent contractors, donors and other persons in the community with whom Rossbrook House interacts.
The privacy of all of these individuals is respected.
4.2 Personal information is collected only for the following purposes, that is, to:
4.2.1 identify participants and other constituents;
4.2.2 establish and maintain responsible relationships with participants and other constituents;
4.2.3 understand the needs, desires, concerns and opinions of participants and other constituents;
4.2.4 provide the services expected of Rossbrook House with a view to advancing the mission;
4.2.5 process and collect donations for Rossbrook House, including issuing tax receipts;
4.2.6 in response to constituent requests, provide a copy of their own information;
4.2.7 manage and develop Rossbrook House business and operations; and
4.2.8 fulfill legal and regulatory requirements.
4.3 Rossbrook House collects information only by lawful and fair means. This includes through the completion of various forms and documents related to the activities of Rossbrook House, through discussions and exchanges of correspondence with various sources and through day-to-day observations of, or interactions with, participants and stakeholders.
5.0 Personal Information Collection and Disclosure
5.1 The knowledge and consent of the individual are required for the collection, use or disclosure of personal information. Rossbrook House will make a reasonable effort to ensure that individuals are aware of the purpose(s) for which the information is collected at the time of collection. An individual’s consent is required before confidential information is released to outside parties.
5.2 Consent can be given:
- in writing;
- electronically, either by website response form or emailing Rossbrook House;
- orally, either in person or by telephone. The time and date of the disclosure will be documented by the Chief Privacy Officer.
5.3 Consent is not required for the collection of personal employee information that is necessary for the administration of the employer/employee relationship.
5.4 There are a variety of circumstances where Rossbrook House may need to disclose some personal information about participants or other constituents. However, with the exception of those circumstances where disclosure is required and permitted by law, Rossbrook House will limit any such disclosure of personal information to a “need to know” and confidential basis.
5.5 Rossbrook House will also ensure that an individual’s personal information is used only for the purpose(s) for which it was collected. Subject to the foregoing, Rossbrook House may disclose an individual’s personal information to the following:
- independent contractors, directors or volunteers;
- a third party who requires such information in order to assist in:
- medical matters;
- educational matters;
- providing programs and/or services to that individual;
- the general administration and/or operations (including record keeping and fundraising activities);
- the Rossbrook House Foundation Inc. Rossbrook House may share personal information with Rossbrook House Foundation Inc., including information respecting your support and financial contribution(s) to Rossbrook House in order to coordinate the recognition of such support and to update you on the activities of Rossbrook House, invitations to events, and the like.
5.6 Rossbrook House will not disclose an individual’s personal information to any third party for the purpose of enabling that third party to market its products and/or services to that individual.
5.7 Rossbrook House will advise individuals of their right to refuse or to withdraw consent to the collection, use or disclosure of personal information. Rossbrook House will record and respect those choices at all times.
6. Children’s Privacy Statement
6.1 Rossbrook House takes our responsibilities to children and youth seriously. In addition to the steps it takes to safeguard the privacy and integrity of personal information submitted by adults, we adhere to the following principles and practices regarding personal information requested from program participants under 18 years old.
6.1.1. We collect participants’ information to assist with reporting age and gender number totals. No individual names appear in participation reports made available to third parties.
6.1.2. Names of program participants may be disclosed to Police Officers or Child and Family Service Officials when appropriate inquiries are made.
6.1.3 If, at any time, a parent or guardian withdraws his or her consent to our use, disclosure or retention of personal information collected about his or her child, the information will be promptly deleted.
6.2 If you have any comments or questions on policies related to your child’s data or about our commitment to protecting your child’s privacy, please contact our Chief Privacy Officer at the address noted in Section 7.2.
7. Accuracy of Personal Information
7.1 Rossbrook House will make every reasonable effort to keep personal information accurate, complete and up-to-date as necessary for the purpose(s) for which it is to be used. In the event that a constituent becomes aware of errors in their personal information, Rossbrook House would very much appreciate receiving appropriate notification and corrective information. In such an event, Rossbrook House will correct the information in the records and make reasonable efforts to communicate the error to any appropriate parties that were misinformed.
7.2 To verify, correct or have personal information removed from the Rossbrook House database, contact Rossbrook House by e-mail: privacy@rossbrookhouse.ca or in writing at the following address:
Attn: Chief Privacy Officer, Rossbrook House
658 Ross Avenue
Winnipeg, Manitoba, R3A 0M1
8. Internet Related Policies
When one visits www.rossbrookhouse.ca, the visitor’s personal information and email address will not be recorded. Rossbrook House uses standard web server log files to count visitors and evaluate the site’s technical capacity. This information is used to find out how many people visit the website to make the pages more useful to visitors, and to evaluate the site’s technical capacity. Rossbrook House does not send unsolicited email.
9. Security Safeguards for Information Storage
9.1 Rossbrook House will protect personal information in a secure environment by using safeguards that ensure specific individual information will not be made available to any unauthorized person. Paper-based and other similar records containing personal information will be kept in a locked location when not in use. Electronic records will be kept on a secure electronic medium with access protected by password.
9.2 When personal information is no longer required Rossbrook House will take appropriate procedures to destroy, delete, erase or convert it to an anonymous form.
9.3 Rossbrook House will educate its employees about the laws surrounding individual rights to privacy and ensures that employees are up to date on Rossbrook House’s policies and procedures for protecting personal information under its control. A breach of privacy may result in disciplinary action up to and including dismissal.
10. Challenging Compliance
Rossbrook House will investigate all complaints regarding compliance with this Privacy Policy. Resolving such complaints and any concerns related to them is important to Rossbrook House. If a complaint is found to be justified, appropriate measures will be taken to resolve the complaint including, if necessary, amending Rossbrook House’s policies and procedures. An individual will be informed of the outcome of the investigation regarding their complaint.
11. Review and Changes
Rossbrook House reserves the right, at its sole discretion, to change, modify, add or remove portions of this Privacy Code at any time. At minimum, this policy and its related procedures will be reviewed every three years or as required in the event of legislative changes.