Privacy Policy

Your privacy is our priority. Naramata Centre meets all legislative requirements with respect to privacy and embraces the ethical guidelines of Imagine Canada (formerly, the Canadian Centre for Philanthropy).

Any personal information we collect from you is used to verify your identity, to identify your preferences, enroll you in a program or workshop you want to take, process a payment for goods or services you receive, process donations you give to the Centre, keep you informed about our activities, and ask for your support in achieving our mission. We do not lend, exchange, rent or sell our supporter or participant lists to any other organizations.

We value the trust of those we deal with and recognize that maintaining this trust requires full transparency and accountability in matters of privacy.

Preamble

Naramata Centre recognizes the value of its relationships with supporters, donors, 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 information that is entrusted to us. Accordingly, Naramata Centre complies with the federal Personal Information Protection and Electronic Documents Act (PIPEDA) and the provincial Personal Information Protection Act (PIPA), and embraces ethical guidelines established by Imagine Canada.

Our privacy policy adheres to the 10 principles that comprise the Canadian Standards Association Model Privacy Code and form the basis of both pieces of legislation. These principles, and Naramata Centre’s related policies, are set forth below.

Principle 1 - Accountability

An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization's compliance with the following principles.

We recognize our responsibility for personal information in our possession. Accountability for Naramata Centre’s compliance with privacy legislation rests with the Executive Director, who has been designated as the Centre’s Privacy Officer.

Principle 2 - Identifying Purposes

The purposes for which personal information is collected shall be identified by Naramata Centre when or before the information is collected.

The purposes will be limited to those which are related to our mission, programs, facilities and operations and which a reasonable person would consider to be appropriate in the circumstances. We collect personal information from program participants and guests in order to provide appropriate program leadership, care and safety. We collect personal information concerning our donors to comply with the Canada Revenue Agency (CRA) requirements for gift processing:

• To thank and publicly recognize donors;
• To provide donors with information about how donated funds are used;
• To keep donors informed about Naramata Centre's activities;
• To promote opportunities for donors and potential donors to support Naramata Centre;
• To build and maintain relationships.

Naramata Centre will specify the identified purposes, orally or in writing, to the individual from whom personal information is being collected either at the time of collection or after collection but prior to use or disclosure. We will state the identified purposes in such a manner that an individual can reasonably understand how the information will be used or disclosed.

Principle 3 - Consent

The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate.

The manner in which Naramata Centre obtains consent for the collection of personal information varies with the sensitivity of the information being collected. PIPA makes provision for express, implied or deemed consent, depending on the situation. Because of the nature of the information we collect, in most cases we will obtain implied consent at the time of collection. The principle requires "knowledge and consent", and Naramata Centre will make a reasonable effort to ensure that individuals are aware of the purposes for which the information is collected at the time of collection. Individuals can give consent: (a) in writing, such as when completing a donation or registration form; (b) through an opt-out process, either by checking off a box on a response form or by contacting Naramata Centre; (c) orally, either in person or by telephone. Individuals may withdraw consent at any time, by any means, with reasonable notice to Naramata Centre.

The Centre may collect, use and disclose personal information without consent if that information is considered by law to be in the public domain. Sources of public information include telephone and professional directories, newspapers, periodicals and public registries.

Principle 4 - Limiting Collection

The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means.

Naramata Centre will not collect information indiscriminately. The Centre will specify the types of information collected, limited to that which is necessary and reasonable to fulfill the purposes identified. The Centre will collect personal information by lawful means and will not mislead individuals about the purposes for which information is being collected.

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, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

When the Centre uses personal information for purposes other than those given at the time of collection, consent will be obtained for these purposes. The Centre does not sell, rent or trade mailing lists. Personal information will be retained as long as the purpose for which the information was originally collected remains valid.

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.

The Centre will use its best efforts to ensure that information that is used on an ongoing basis and information that is used to make a decision about an individual (such as a donation recognition category), is accurate, complete and up to date.

Principle 7 – Safeguards

Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.

The Centre’s safeguards will protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We will make our employees aware of the importance of maintaining the confidentiality of personal information, and we will exercise care in the disposal and destruction of personal information to prevent unauthorized parties from gaining access to it. All employees and volunteers having access to personal information are required to sign an oath of confidentiality. Our methods of protection will include physical measures (e.g. locked filing cabinets, restricted access to offices), organizational measures (e.g. security clearances and limiting access on a "need-to-know" basis) and technological measures (e.g. the use of passwords and encryption).

Principle 8 – Openness

An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information.

Naramata Centre will be open about privacy policies and procedures with respect to the management of personal information and will make them readily available in a form that is generally understandable. The information made available will include: (a) the name or title and contact information of the Privacy Officer who is accountable for compliance with Naramata Centre’s policies and procedures, and to whom complaints or inquiries can be forwarded; (b) the means of gaining access to personal information held by the Centre; (c) a description of the types of personal information held by the Centre; (d) and a copy of any document that explains the Centre’s policies, procedures, standards or codes.

Principle 9 - Individual Access

Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Naramata Centre will respond to an individual's request within a reasonable length of time, but no longer than one month. While our response will typically be provided at no cost to the individual, depending on the nature and amount of information involved, we reserve the right to impose a cost. The requested information will be made available in a form that is generally understandable. For example, where the Centre uses abbreviations or codes to record information, an explanation of those codes will be provided. Where possible, we will provide sources for the information. For the Centre to provide an account of the existence, use and disclosure of personal information, an individual may be asked to provide additional information to aid in the search. The additional information provided will only be used for this purpose. When an individual successfully demonstrates the inaccuracy or incompleteness of personal information, the Centre 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 designated individual or individuals accountable for the organization's compliance.

The name of the Privacy Officer will be known to staff. Information on how to contact the Privacy Officer will be identified to other individuals periodically. The Centre will maintain procedures to receive and respond to complaints or inquiries about its policies and practices relating to the handling of personal information. The complaint procedures will be easily accessible and simple to use. Individuals who make inquiries or lodge complaints will be informed by the Centre of the existence of relevant complaint procedures. If a complaint is found to be justified, the Centre will take appropriate measures, including revision of the personal information and, if necessary, amendment of the Centre's policies and practices.

Updating of Privacy Policy

We regularly review and update our privacy policy. Please check our web site for our most current Privacy Policy.

How to contact the Privacy Officer

Inquiries, complaints or access requests should be addressed to: Executive Director - Privacy Officer, Naramata Centre, Box 68, Naramata, BC V0H 1N0, or achurch@naramatacentre.net.