2009 – CBWC FOUNDATION
(“CBWCF”, “us” “we”)
Statement of Commitment
To safeguard the personal information entrusted to us and to comply with the Personal Information Protection and Electronic Documents Act and any other applicable legislation, we are committed to the following principles:
- Identifying purposes
- Limiting collection
- Limiting use, disclosure, and retention
- Individual access
- Challenging compliance
“Personal information” means information about an identifiable individual, but does not include the name, title, business address and business telephone number of an employee of an organization.
The CBWC-F, including its directors, officers, employees and volunteers are required to comply with these principles and the Policy and will be given restricted access to personal information solely to perform the services provided by us.
Other persons or organizations who act for, or on behalf of, the CBWC-F are also required to comply with the principles and the Policy and will be given restricted access to personal information solely to perform the services provided for us.
We have designated Lisa Roth to be our Personal Information Compliance Officer.
Any inquiry, request or concern related to privacy matters should be made in writing to the following:
Personal Information Compliance Officer
1150, 550 – 11 Ave. SW, Calgary, AB T2R 1M7
A printed copy of the Policy may be requested by mail or e-mail at the above address.
Collection and Use of Personal Information
The CBWC-F may also use “cookies” and similar technology to obtain information about your visits to our sites and your responses to e-mail from us. While “cookies” help us improve your experience while visiting our sites by allowing us to customize our communications to the services you may desire, you have the option of blocking the “cookies” through your Internet browser or other commercially available software but this may make some of our site’s features unavailable to you.
Protection of Personal Information
Most of your personal information is kept electronically but it could be printed at some point(s) in time. Your printed personal information will be kept under lock and key with restricted access to the office in which it is located or if it is being electronically held, it will be password protected with only those who “need to know” having access to such password. We also use encryption, firewalls and other technology and security procedures to help protect the security of your personal information and to prevent unauthorized collection, use or disclosure of your personal information by other persons.
Disclosure of Personal Information
Our computer technology group does have access to all electronically held documents but all members of the computer technology group have signed confidentiality agreements that prevent them from disclosing any personal or other information to any other person without our prior written consent which consent we will not provide without your prior consent. We may disclose your personal information to third parties on a “need to know” basis with the clear understanding that the personal information is provided under the terms of the Confidentiality Agreement executed by that third party in favour of the CBWC-F. Like most enterprises today, we may use vendors to carry out certain functions in marketing and delivering services to you and we share online data with those vendors to the extent necessary for them to perform their work. Delivery of such information is provided under written agreement which includes a duty of confidentiality on the part of the service provider. The CBWC-F may also share your personal information with other industry and credit-related organizations when necessary to improve operations and to protect against fraud, security and credit risks. The CBWC-F does not share, disclose or sell any of your personal information with other unaffiliated companies or organizations without your prior consent.
Retention and Destruction of Personal Information
Canada Revenue Agency requires that we retain our financial information for a minimum of seven years and accordingly, should our financial information include your personal information, your personal information could be held by us for a minimum of seven years. Your closed file(s) will be kept either on site or in off-site storage facilities where disclosure of their contents is limited to the CBWC-F and its agents only. When we destroy file(s) (whether printed or electronic), we will undertake such destruction in a manner that will eliminate or at least minimize the risks of any personal information being disclosed to any unauthorized person.
Right to Access and Correct
You can review your personal information on reasonable notice, during regular business hours by making that request of the Personal Information Compliance Officer. You have the right to request a correction be made to your personal information. The President of the CBWC-F or his or her chosen alternative within CBWC-F will determine whether that correction should be made or how it should be dealt with within 30 days of the request for correction having been first made to the Personal Information Compliance Officer. You can make an inquiry or complaint directly to the Personal Information Compliance Officer at any time, in writing. Our Personal Information Compliance Officer, Lisa Roth, can be contacted at 1-800-820-2479, by mail at CBWC Foundation 1150, 550 – 11 Ave. SW, Calgary, AB, T2R 1M7, or by email at firstname.lastname@example.org.
In the event that you are not satisfied with the outcome of your request, decision or interaction with the Personal Information Compliance Officer you have a right to appeal to the President of the CBWC-F. To appeal to the President you need only provide written notice of your request for an appeal to the Personal Information Compliance Officer and the Personal Information Compliance Officer is required to forward to the same to the President at which point you will receive a further communication from the CBWC-F regarding whether a meeting or written reply will be provided to you in relation to the issue.
Reasonable Collection and Use of Personal Information
The CBWC-F will collect from its employees and volunteers and use only such personal information as is reasonably necessary for the identified purpose that will be stated (either orally or in writing) at or prior to the time of collection of the personal information.
Type of Personal Information Collected
We confirm that at this point in time, we have collected and will continue to collect personal information on our employees and volunteers relating to, among other things: their past endeavors as relayed to us in the employee’s or volunteer’s resume or as disclosed to us by the employee’s or volunteer’s reference(s) or in the employee’s or volunteer’s initial interview(s); results of psychometric testing; bank account information, job performance; salary; dependents and health benefit information.
Use, Retention and Disclosure of Personal Information
The use and disclosure of the personal information will be limited to the purpose for which it was collected. If information is to be used or disclosed for a new purpose, consent to the new purpose will be obtained orally or where we find it advisable, in writing, from you. We will retain your personal information during the course of having you provide services to the CBWC-F and for a minimum of one year thereafter. The CBWC-F reserves the right to determine exactly when to destroy the personal information after the one year period but, the personal information when destroyed will be destroyed in such a fashion so as to minimize the risk of its disclosure to any unauthorized person.
Our employees’ and volunteers’ personal information will be provided to the persons responsible for human resources for the CBWC-F as well as management of the CBWC-F and to such other persons within the CBWC-F that, in the opinion of the human resource personnel and management of the CBWC-F, are required to have the personal information in order to carry out the purpose for which it was collected. We will also disclose the personal information to any benefit provider that is engaged by the CBWC-F for the purpose of allowing the benefit provider to provide the benefits to the employee. The results of psychometric tests are typically shared among our personnel to encourage an understanding of each co-worker’s common characteristics.
Oversight and Redress
Each employee and volunteer has the responsibility to ensure that any changes in personal information including home addresses or unlisted telephone numbers are provided to us within seven days of the change having been effected.
Protection of Personal Information
Each employee’s and volunteer’s personal information will be either password protected if kept electronically or kept under lock and key if retained in a paper format.
The Personal Information Compliance Officer-Right to Review and Correct
The Personal Information Compliance Officer of the employee or volunteer personal information is Lisa Roth. You can review your personal information on reasonable notice, during regular business hours by making that request of the Personal Information Compliance Officer. You have the right to request a correction be made to your personal information. The CBWC-F will determine whether that correction should be made or how it should be dealt with within 30 days of the request for correction having been first made to the Personal Information Compliance Officer.
You can make an inquiry or complaint directly to the Personal Information Compliance Officer at any time, in writing.
In the event that you are not satisfied with the outcome of your request, decision or interaction with the Personal Information Compliance Officer you have a right to appeal to the President of the CBWC-F. To appeal to the President, you need only provide written notice of your request for an appeal to the Personal Information Compliance Officer and the Personal Information
Compliance Officer is required to forward to the same to the President at which point you will receive a further communication from the CBWC-F regarding whether a meeting or written reply will be provided to you in relation to the issue.