Privacy Policy

Last Updated June 2013


The Canadian Psoriasis Network (“CPN”, “we”, “us” or “our”) recognizes the importance of privacy and is committed to maintaining the accuracy, confidentiality and security of your personal information. This privacy policy describes the personal information that we collect, how we manage that information and the circumstances under which we may disclose that information.

The CPN’s privacy policy is based upon the Canadian Centre for Philanthropy’s Ethical Fundraising and Financial Accountability Code, the Canadian Standards Association’s Model Code for the Protection of Personal Information as well as the requirements of applicable privacy legislation. As this policy is subject to change due to legal and regulatory requirements, we encourage you to periodically check our website for updates to this policy.

 

Personal Information

Personal information is any information about an identifiable individual, other than an individual’s business title or business address or telephone number. Personal information (for example name, address, age, credit card information, banking information) does not include information that cannot be associated with or tracked back to a specific individual. Information that is publicly available, such as a telephone book listing, is also not considered to be personal information.

 

Types of Information Collected

 

1) Personally identifying information

The CPN only collects personally identifying information about donors, clients, volunteers and event participants for fundraising, public education and advocacy purposes, program and service delivery, as well as to establish, maintain and manage our relationship with you.

Your provision of personal information to the CPN means that you agree and consent that we may collect, use and disclose your personal information in accordance with this privacy policy. If you do not agree with these terms, please do not provide any personal information to us. Failure to provide your personal information to the CPN may prevent us from offering you the services and/or programs you have requested. We will discuss the impacts of withdrawal of consent with you at that time.

The information the CPN collects is the minimum amount we need to establish and maintain a service, volunteer, participant, donor or program relationship with you. This includes:

  • contact and identification information, such as your name, address, telephone number and e-mail address
  • donation information such as date of gift, amount of gift, the campaign you contributed to, name of spouse or partner if it was a joint gift
  • financial information such as your payment methods and preferences, billing and banking information (credit card number and expiry date or chequing account transit numbers, in order to process your donation); for online financial transactions such as donations and event registrations, we process standard credit card information (card number, card type and expiration date) via a secure, 128-bit encrypted Secure Sockets Layer (SSL) session. SSL is the proven standard for secure web transactions.

We may be required by law to collect certain information about you. For example, some of the information the CPN collects is needed in order to satisfy the requirements of the Canada Revenue Agency (CRA) (for example, processing income tax receipts).

The CPN generally collects your personal information directly from you and only with your consent. However, if the individual who has a relationship with the CPN is a minor, information may be collected from a parent or legal guardian. In addition, the CPN will not collect or use personal information about you from a third party without your express consent. The CPN will usually obtain your consent at the time that we collect your personal information. If the purpose for using your personal information changes from the time since such consent was obtained, the CPN will advise you of this purpose before such use or disclosure.

 

(2) Website generated information: “cookies”

In order to improve our website on an ongoing basis, we may use cookies to track your visit. The CPN also uses cookies to provide users with certain features (for example, customized delivery of information) based on your location.

A cookie is a small amount of data that is transferred to your browser by a web server and can only be read by the website that gave it to you. It functions as your identification card. It is not a program and cannot be executed as code or deliver viruses. The CPN does not analyze or report on individual user sessions, and never redirects cookies to any other servers.

Cookies can also customize the site to your particular interests or store your personal information, such as passwords or user IDs.

Most browsers are initially set to accept cookies. You can set your browser to notify you when you receive a cookie – this gives you the chance to decide whether to accept it. To learn more about cookies and how to change your settings, please use the help function in your browser.

You can use the CPN website without cookies, but you may have to re-enter information each time you visit.

 

How does the CPN use your personal information?

The CPN uses your personal information, to process donations, to respond to your requests for services and information, to keep you informed about our activities, and for fundraising.

The CPN makes every attempt to use anonymous or aggregate information whenever possible. We may also use information that does not personally identify you in the following ways:

  • to assist in the development of new programs, events, and services
  • to provide donation recipients with summary or aggregate information about our donations, programs and services
  • for internal research purposes
  • to develop advertising based on donor preferences

 

Disclosure of your Information?

The CPN shares your personal information only with employees and/or volunteers who require such information to establish, manage and maintain our relationship with you. We may also disclose your personal information to third party service providers whom we engage to mail our fundraising material, process your donation, or answer your inquiry. These third party providers only have access to personal information that is needed to perform their services and may not use it for any other purpose. They are bound by agreements that obligate them to protect your personal information. Note that in working with our service providers, your personal information may be accessible in, or transferred to, a foreign jurisdiction. Such information may be provided to law enforcement or national security authorities of that jurisdiction in order to comply with foreign laws.

There are circumstances where the use and/or disclosure of personal information is justified or permitted without consent. These circumstances may include:

  • where required by law or by order or requirement of a court, administrative agency or other governmental tribunal
  • where the Society believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group
    where the information is public.

Fundraising helps to ensure the on-going stability and quality of the services and programs we provide to Canadians living with psoriasis. We may exchange donor information with other registered charities. If you do not wish us to trade your name in this manner, or if you do not want to receive any marketing or fundraising materials from us, please contact our Executive Director at _____. Please allow up to 12 weeks for your request to be processed, as mail campaigns may already be in progress.

The CPN aims to ensure that any personal information provided is accurate, complete and current as required for the purposes for which the information is used.

 

Protecting your Personal Information

The CPN takes reasonable measures to ensure that personal information is kept safe from loss or theft, unauthorized access, use, copying, disclosure or modification. Safeguards include physical, organizational and technical measures, including but not limited to:

  • Restriction of employee access to files on a “need to know” basis;
  • Confidentiality undertakings by all employees;
  • Locking up personal information and never leaving it unattended and in plain view;
  • Firewalls, anti-virus, strong passwords and software solutions for technical security; and
  • Regular reviews of privacy compliance initiatives.

The CPN trains all staff on privacy best practices and ensures that employees are aware of the importance of safeguarding any personal information that they are privy to.

 

Retention of Personal Information

The CPN keeps personal information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the program, service or event and the nature of the information, for example we keep financial information for 6 years, in accordance with CRA rules and regulations. The retention period may extend beyond your relationship with us. When your personal information is no longer required for CPN purposes, the information is either physically destroyed or deleted.

 

Links to other Websites

The CPN may provide links to other websites which we believe are of interest to people with psoriasis. As the CPN has no control over the content of any of these websites, these links may be updated or deleted as we deem appropriate.

Please be aware that the CPN is not responsible for the privacy practices of other websites that we link to. We encourage you to read the privacy statements of each and every website that requests personal information from you.

 

Inquiries or Requests for Access

If you have any questions about this privacy policy, or would like to access your personal information, please contact our Executive Director. Please note that as we cannot guarantee the security of Internet mail, all formal requests to access personal information should be made in writing.

Executive Director
Canadian Psoriasis Network
PO Box 8706
Ottawa ON K1G 3J1

Please note that a fee may apply in processing your request depending on the type and volume of information requested.

If you are not happy with the way that the CPN has handled your inquiry, or have a concern about our privacy practices that you feel we have not addressed satisfactorily, you can contact the Privacy Commissioner of Canada at:

112 Kent Street
Ottawa, Ontario
K1A 1H3
Tel: 1 800 282-1376
Fax: (613) 947-6850