Board members, staff and volunteers of SCAC are required to comply with the Policy and may be given restricted access to personal information solely to fulfill the purposes as set out in this Policy.
PRINCIPLE 1 – ACCOUNTABILITY
1.1 SCAC is responsible for personal information which we collect, use or distribute and any personal information in our custody or under our control.
1.2 SCAC has appointed a Privacy Officer who will be responsible for overseeing the Policy as well as any inquiries, requests or concerns relating to privacy matters. The Privacy Officer may, from time to time, designate one or more individuals within SCAC to act on his behalf.
1.3 Each Board member, staff and volunteer is responsible for maintaining and protecting the personal information under its control and is accountable, for such information, to the Privacy Officer.
PRINCIPLE 2 – PURPOSES
2.1 SCAC is committed to ensuring that the purposes for which personal information is collected, used, or disclosed are identified and are reasonable and appropriate in the circumstance.
2.2 SCAC will collect personal information for a variety of purposes, such as:
- Church Membership registration and listings;
- Church Directories
- Volunteer and leadership development;
- Program and service registration, administration and delivery;
- Counseling and prayer support; and
- Church administration (tithing, offerings, payments owing, etc.)
Business contact information and certain publicly available information, such as names, addresses and telephone numbers as published in telephone directories, are not considered as personal information.
PRINCIPLE 3 – CONSENT
3.1 SCAC will obtain reasonably informed consent to collect, use or disclose personal information except where we are authorized to do so without consent.
3.2 Consent can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the person voluntarily provides personal information for that purpose.
3.3 In general, the use of products and services or the acceptance of employment or benefits, constitutes implied consent for SCAC to collect, use and disclose personal information for all identified purposes. Consent may also be implied where the person is given notice and a reasonable opportunity to opt-out of his or her personal information being used for certain purposes and the person does not opt-out.
3.4 An individual may refuse or withdraw consent at any time, subject to legal and contractual restrictions and reasonable notice. The choice to provide personal information is always the individual’s. Decision to withhold particular information may impact one’s ability to meet specific requirements for the provision of certain services.
3.5 The following are examples of when we may collect, use or disclose the personal information without consent:
- When the collection, use or disclosure of personal information is permitted or required by law;
- When collection is clearly in your best interest and we are unable to obtain your consent in a timely way;
- In an emergency that threatens an individual’s life, health or personal security;
- When disclosure is required for archival purposes;
- When the personal information is available from a public source (e.g. a telephone directory);
- When the personal information is available through observation at a public event to which you attended voluntarily;
- When we require legal advice from a lawyer;
- For the purposes of collecting a debt or other obligation;
- To protect ourselves from fraud;
- To investigate an anticipated breach of an agreement or a contravention of law;
- When the personal information is voluntarily disclosed by the person to whom it applies by using equipment or data owned by SCAC (e.g. through the use of church computers, email addresses etc.).
PRINCIPLE 4 – LIMITING COLLECTION
4.1 SCAC will limit the collection of personal information to that which is necessary for identified purposes. SCAC will only collect personal information by fair and lawful means and for purposes that a reasonable person would consider appropriate in the circumstances.
PRINCIPLE 5 – LIMITING USE, DISCLOSURE AND RETENTION
5.1 SCAC will not use or disclose personal information for purposes other than for those for which it was collected except with the consent of the individual or as required or permitted by law.
- We encourage our members and contacts to share their prayer requests so that we as a church may pray together. We recognize some of the requests are sensitive and very personal. We will ensure that the personal information contained in our prayer request list be limited only to the amount necessary.
5.2 SCAC will only retain personal information as long as it is needed for the purposes for which it was collected or consented to.
5.3 When personal information collected is no longer relevant to its purpose or when it is permitted by law, SCAC will ensure that it is deleted, destroyed or made anonymous in a secure manner.
PRINCIPLE 6 – ACCURACY
6.1 SCAC will take reasonable efforts to ensure that personal information is accurate and complete.
6.2 SCAC will update information when it is necessary to fulfill the purpose for which the information was collected or when an individual notifies us. If an individual finds any inaccuracies in SCAC information, he/she should inform SCAC office or relevant ministry head. Appropriate corrections will be made promptly. In some cases, SCAC 4
relies on the individual to ensure that certain information, such as mailing address, email address and telephone number, is complete and accurate.
PRINCIPLE 7 – SAFEGUARDS
7.1 SCAC shall stress to Board members, staff and volunteers the importance of safeguarding the confidential nature of personal information. In the course of daily operations, access to personal information is restricted to those Board members, staff and volunteers whose job responsibilities require them to access it, on a “need to know” basis.
7.2 SCAC will routinely review and update our security measures which will include: Physical measures such as locking filing cabinets and restricted access to offices as appropriate; Organizational measures, such as security clearances and policies governing access to information; Technological measures, such as the use of passwords and encryption.
7.3 SCAC shall protect personal information disclosed to third parties by contractual agreement that stipulates the confidentiality and safeguard requirements that are comparable to our own.
PRINCIPLE 8 – OPENNESS
8.1 SCAC is committed to making its privacy policies and procedures available and clear to all interested parties.
8.2 Any questions or concerns regarding our policy or procedure may be directed in writing to our Privacy Officer.
PRINCIPLE 9 – INDIVIDUAL ACCESS
9.1 Board members, staff, volunteers, donors, candidates and contacts have the right to access their personal information, subject to limited exceptions including, but not limited to:
- Situations of solicitor-client privilege
- Situations where disclosure may reveal the personal information of another individual
- Situations where the health or safety of an individual may be jeopardized
- Situations where the information was provided confidentially, such as the references for candidates
9.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought and should be 5
forwarded to the attention of the Privacy Officer. A reasonable fee may be charged for providing access to personal information, in which case we will inform the individual prior to proceeding.
9.3 If access cannot be provided, SCAC will notify the individual, in writing, of the reasons for refusal.
PRINCIPLE 10 – CHALLENGING COMPLIANCE
10.2 The procedure of SCAC for dealing with complaints is as follows:
- Record the date and nature of a complaint when it is received
- Acknowledge receipt of the complaint promptly
- Review the matter fairly and impartially, providing to the individual, where possible, access to all relevant records
- Notify the individual of the outcome of the investigation promptly and clearly
- If the complaint is found to be justified, we will take appropriate measures, including, if necessary, amending our policies and practices. We will also, if and as required, correct any inaccurate or incomplete information when possible.
10.3 If the Privacy Officer is unable to resolve the concern, the individual may also write to the Federal Privacy Commissioner.
10.4 The contact information for the Privacy Officer is as follows:
SCARBOROUGH CHINESE ALLIANCE CHURCH
139 Silver Star Blvd, Scarborough, ON M1V 4V8