Effective: May 23, 2018
1. Collection of Personal Information
The Alzheimer Society is committed to identifying the purposes for which Personal Information is collected at or before the time the information is collected, and to documenting the purposes for which Personal Information is collected. The Personal Information we may collect from you includes:
- Contact information, such as your name, address, telephone number and email address;
- Donation information such as date of gift, amount of gift, the campaign you contributed to, and name of your spouse or partner if it was a joint gift;
- Financial information such as your payment methods and preferences, billing and banking information including credit card number and expiry date or chequing account transit numbers. Online financial transactions such as donations and event registrations, are processed using secure web transactions;
- Other Personal Information may be collected to be used for purposes that an individual would consider reasonable in the circumstances. For example, if you have demonstrated an interest in receiving information about Alzheimer’s disease or a related dementia, or participating in fundraising or other related events, we may send you information regarding other fundraising programs and services;
- On a voluntary basis, Personal Information such as your gender, language preference, motivations for supporting the Alzheimer Society, and preferred method of contact is requested when donations are made; and
- On a voluntary basis, Personal Information including acknowledging if you are a person living with Alzheimer’s disease or a related dementia, or if you are a caregiver or family member to a person with Alzheimer’s disease or other related dementia may be requested.
2. Use of Personal Information
The above noted Personal Information we collect from you may be used by the Alzheimer Society and Federation Partners for the following limited purposes:
- To respond to requests for services and information;
- To inform you about activities, special events, and volunteer opportunities;
- To assist in developing new programs, events, and services;
- For fundraising;
- To process donations and issue tax receipts;
- 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;
- For public education purposes;
- For advocacy purposes;
- To save your access credentials to the message board and live chat options on our webpage;
- For voluntary surveys when donations are made to help design profiles of the donor base to aid with creating of messaging and providing content, as well as to refine targeted marketing campaigns to prospective donors;
- To cross-reference Personal Information between and amongst all Federation Partners; and
- To provide newsletters, emails, information and updates.
3. Disclosure of Personal Information
- As part of our fundraising initiatives, Personal Information may be shared with other registered charities;
- Personal Information is shared as necessary with auditors for the Alzheimer Society’s annual audit;
- Banking information is shared with the Alzheimer Society’s banking institution to process donations;
- Surveys mailed back from donors are received along with all other fundraising mail responses at the Alzheimer Society’s third party service provider’s facility, where their staff enters responses into a secure database;
- Personal Information may be shared with contracted third parties during the preparation of fundraising campaigns and used exclusively by them for the purposes of those specific campaigns;
- The Alzheimer Society may share your Personal Information to contracted third party service providers or agents who provide services to or on behalf of the Alzheimer Society such as:
- Hosting, data management and storage services;
- Market analyses, and retention services; and
- Donation processing and receipt production services.
The Alzheimer Society or third party service providers may use servers for such purposes located in the United States or another foreign country. The Personal Information of an individual may be processed and stored in the United States or such other foreign country, and the governments, courts or law enforcement or regulatory agencies of that country may be able to obtain disclosure of through the laws of the foreign country.
Personal Information may also be disclosed without your consent if required by law or by order or requirement of a court, administrative agency or 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.
4. Storing, Processing and Securing Personal Information
The Alzheimer Society stores and maintains Personal Information in conformity with the requirements of the Personal Information Protection and Electronic Documents Act and the Model Code for the Protection of Personal Information created and approved by the Canadian Standards Association. When we use third party service providers for storing or processing of Personal Information, we use contractual or other means to ensure that your Personal Information is protected. In some cases, third party service providers may store or transfer Personal Information in or to countries where compliance with Canadian privacy laws cannot always be guaranteed. Please rest assured that the Alzheimer Society makes reasonable efforts to contract only with trustworthy service providers who are committed to protecting the privacy of your Personal Information.
We use a variety of secure means to store your Personal Information. These include:
- The Alzheimer Society uses technological security measures, including passwords and encryption, to prevent unauthorized access to financial and other Personal Information stored on computer systems;
- Locked cabinets in secure areas are used to store hard copies of financial information;
- Third party providers, agents or vendors are used to provide services to or on behalf of the Alzheimer Society such as secure data storage, data hosting, and data management.
Either the Alzheimer Society or such third party service provider may use servers for such purposes located in the United States or another foreign country. The Personal Information of an individual may be processed and stored in the United States or such other foreign country, and the governments, courts or law enforcement or regulatory agencies of that country may be able to obtain disclosure of Personal Information through the laws of the foreign country.
5. Website Use
The Alzheimer Society may collect and use an individual's IP address, and date and time that the individual accessed our website, to help identify the individual, gather broad demographic information about users of the website, diagnose problems with the Alzheimer Society’s systems, and administer the Alzheimer Society website.
6. The Model Code for the Protection of Personal Information
The Alzheimer Society applies the ten principles of the Model Code for the Protection of Personal Information when collecting, using or disclosing your Personal Information:
a. Developing procedures to protect Personal Information;
b. Developing procedures to receive and respond to complaints and inquiries;
c. Training our staff about our policies and practices respecting Personal Information; and
d. Developing and distributing information to our staff and the general public explaining our policies and procedures respecting Personal Information.
ii. Identifying Purposes
a. conform to obligations imposed by law or statute;
b. meet an emergency need; and/or
c. as required pursuant to a criminal investigation.
You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting the Chief Privacy Compliance Officer. Please note that the withdrawal of your consent may impact on the Alzheimer Society’s ability to serve you and to maintain your relationship with the Alzheimer Society.
iv. Limiting Collection
The Alzheimer Society restricts the collection of Personal Information only to that information that is necessary for the limited purposes noted above. We are committed to collecting Personal Information in a fair, open and lawful manner. For this reason, the Alzheimer Society does not indiscriminately collect Personal Information. We collect Personal Information to fulfill the above-noted purposes only, and for no other purposes.
v. Limiting Use, Disclosure and Retention
The Alzheimer Society is committed to maintaining accurate, complete and up-to-date Personal Information. If you are aware of changes to the Personal Information you have given to us, simply inform us of the changes and we will update our records accordingly. You may check and correct your Personal Information by contacting the Alzheimer Society and the Chief Privacy Compliance Officer assigned to oversee the day-to-day care and control of Personal Information by writing or emailing your request to the address set out below.
The Alzheimer Society has developed and implemented security safeguards appropriate to the sensitivity of the Personal Information kept by us. We also ensure that any of our employees who deal with Personal Information are properly trained and are aware of the necessary and appropriate measures required to protect Personal Information. Any Personal Information kept by us is disposed of or destroyed once it is no longer needed to meet the purposes for which it was collected.
The Alzheimer Society makes information about its policies and practices respecting the collection and maintenance of Personal Information available to all interested parties. We are pleased to answer any questions that you may have regarding the collection and maintenance of Personal Information. Please forward any questions in writing or email to the address set out below.
ix. Individual Access
You can also request access to your Personal Information held by us. However, we reserve the right to confirm the identity of the person seeking access to Personal Information before complying with any access requests. Please forward your access request in writing or email to the address set out below.
x. Challenging Compliance
As noted above, the Alzheimer Society has designated an official who is responsible for the day-to-day care and control of Personal Information. This official will receive and respond to all information requests regarding our privacy policies or about your Personal Information under our care and control. We investigate all complaints received by us and will respond in writing in a timely manner. If any complaint is found to be justified, then we will take appropriate measures to resolve the matter to the satisfaction of the complainant.
7. Additional Information
If you would like more information about our policies, or if you would like to access or correct the Personal Information we have about you in our records, then please contact our Chief Privacy Compliance Officer by email or in writing, as provided below:
ATTENTION: CHIEF PRIVACY COMPLIANCE OFFICER
The Alzheimer Society of Ontario
20 Eglinton Avenue West, 16th floor
Toronto, ON M4R 1K8