Personal Information Policy
FARLEY FOUNDATION is committed to respecting the privacy rights of all individuals by ensuring that their personal information is collected, used and disclosed in an appropriate manner.
FARLEY FOUNDATION collects personal information about donors, sponsors and benefactors. This facilitates communication with such individuals, which in turn enables FARLEY FOUNDATION to undertake fundraising to support its programs and services. FARLEY FOUNDATION also collects personal information about its employees and volunteers for purposes of personnel management and administration and fundraising activities.
The Personal Information Protection and Electronic Documents Act (“PIPEDA”) is federal legislation governing the collection, use and disclosure of personal information, amongst other things, which came into effect in Ontario on January 1, 2004. The principles established in the personal information policy of FARLEY FOUNDATION correspond to the principles set out in the Canadian Standard Association’s Model Code for the Protection of Personal Information, and conform with the requirements of PIPEDA. FARLEY FOUNDATION may review and revise its personal information policy from time to time. In the case of amendment, a notice will be posted on www.farleyfoundation.org, or published in appropriate FARLEY FOUNDATION publication.
FARLEY FOUNDATION is responsible for all personal information under its control. The board of directors will designate an individual, known as the “Privacy Officer”, who will be accountable for compliance with the personal information policy of FARLEY FOUNDATION. The Executive Director of FARLEY FOUNDATION shall be the Privacy Officer.
FARLEY FOUNDATION is committed to protecting personal information, and accordingly will include an appropriate level of protection in contractual arrangements with third parties or obtain appropriate assurances from third parties who receive personal information from FARLEY FOUNDATION.
FARLEY FOUNDATION will ensure that all donors, sponsors, benefactors, volunteers, employees and other interested individuals have the opportunity to review, on request, and update their personal information on file with FARLEY FOUNDATION. All such persons may direct questions and concerns to the Privacy Officer.
2. Identifying the Purposes for Collection, Use and Disclosure of Personal Information
FARLEY FOUNDATION will identify the purposes for which it collects, uses and discloses personal information from time to time. Common purposes for the collection, use and disclosure of personal information include:
i. to maintain complete and accurate files on all donors, sponsors, benefactors, volunteers and employees;
ii. to solicit support, both through fundraising efforts and otherwise, from donors, sponsors, benefactors and volunteers, and to communicate effectively with such individuals, which enables FARLEY FOUNDATION to fulfil its objectives and mandate;
iii. to comply with lawful requests from governmental agencies such as Canada Customs and Revenue Agency and the Ontario Human Rights Commission; and
iv. to maintain complete and accurate personnel files.
Written notification of such purposes will be communicated to interested individuals by posting the personal information policy on www.farleyfoundation.org, by notice published in an appropriate FARLEY FOUNDATION publication, or in such other manner as is feasible in the circumstances.
FARLEY FOUNDATION may identify additional purposes for the collection, use and disclosure of personal information. FARLEY FOUNDATION will communicate such additional purposes by way of a notice posted on www.farleyfoundation.org or by notice printed in an appropriate FARLEY FOUNDATION publication.
There may be situations where consent is given orally, either in person or over the telephone. If FARLEY FOUNDATION obtains oral consent from an individual, a note of that consent should be recorded by FARLEY FOUNDATION and, if applicable, be included in the file of the donor, sponsor, benefactor, volunteer or other interested individual providing such oral consent.
The consent of an individual may be withdrawn at any time. FARLEY FOUNDATION generally requires such withdrawal to be in writing, but will recognize verbal communication of withdrawal of consent when it is appropriate to do so in the circumstances.
4. Limitations on the Collection of Personal Information
FARLEY FOUNDATION will only collect personal information which is necessary for the purposes which have been identified. Personal information shall be collected by fair and lawful means, and will not be collected for unspecified or improper purposes.
5. Limitation on the Use, Disclosure and Retention of Personal Information
Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual providing the personal information or except where use or disclosure is required or permitted under a legal duty or right. FARLEY FOUNDATION does not disclose, or share personal information about its donors, sponsors or benefactors.
FARLEY FOUNDATION will establish appropriate procedures for the retention of personal information.
FARLEY FOUNDATION will make every reasonable effort to ensure that personal information collected by it will be as accurate, complete and up-to-date as possible for the purposes for which the information is to be used.
FARLEY FOUNDATION will on an ongoing basis make every effort to ensure the accuracy and completeness of personal information under its control. An individual providing personal information will have the opportunity to do so in an accurate and complete manner.
FARLEY FOUNDATION will develop a procedure to enable an individual to update personal information on file, on request. FARLEY FOUNDATION will review regularly the accuracy and completeness of personal information on file.
FARLEY FOUNDATION endeavours to maintain adequate procedural and technical security to protect personal information under its control and will implement security measures appropriate to the sensitivity of the information.
FARLEY FOUNDATION shall ensure that its employees keep all personal information confidential and comply with the security standards established by FARLEY FOUNDATION.
FARLEY FOUNDATION shall require third parties to whom personal information is disclosed to commit to an appropriate level of security in respect of such information in compliance with the standards established by FARLEY FOUNDATION.
On the disposal or destruction of personal information, FARLEY FOUNDATION shall take the necessary precautions to prevent third parties from accessing such information and to maintain the confidentiality of such information.
FARLEY FOUNDATION will make available to any interested individual specific information about FARLEY FOUNDATION’s policy relating to personal information which is under the control of FARLEY FOUNDATION. FARLEY FOUNDATION will facilitate access to its personal information policy, and will make available information concerning the identity of its Privacy Officer, and the means by which a person can communicate with the Privacy Officer. FARLEY FOUNDATION will also ensure that individuals are given access to their personal information.
9. Individual Access to Personal Information
An individual providing personal information to FARLEY FOUNDATION has the right to access such information, and the right to ensure the accuracy and completeness of such information. An individual will be able to address the accuracy and completeness of his or her personal information and have it amended, if inaccurate or incomplete.
FARLEY FOUNDATION will respond promptly to any request by an individual for access to his or her personal information.
FARLEY FOUNDATION will maintain a complete record of third parties to whom personal information has been disclosed, and will make such record available to an individual whose personal information has been so disclosed.
10. Questions and Concerns Regarding Compliance with this Policy
An individual providing personal information to FARLEY FOUNDATION may address any question, concern or complaint regarding FARLEY FOUNDATION compliance with the personal information policy to the Privacy Officer.
FARLEY FOUNDATION will establish a procedure for processing any complaint about the personal information policy to ensure that all complaints are dealt with in an objective, fair and expeditious manner.