August 24, 2011
For the purpose of this policy any mention of Ledarney Manor will include Nova House Inc. Board members and employees.
TABLE OF CONTENTS
1.1 The Ten Principles of PIPEDA Summarized 3
1.2 Personal Information Defined 4
2.0 PURPOSES OF COLLECTING PERSONAL INFORMATION 5
3.0 CONSENT 5
4.0 LIMITING COLLECTION 6
5.0 LIMITING USE, DISCLOSURE AND RETENTION 6
5.1 Use of Personal Information 6
5.2 Disclosure of Personal Information 6
5.3 Retention of Personal Information 7
6.0 ACCURACY 7
7.0 SAFEGUARDS 8
8.0 OPENNESS 8
9.0 INDIVIDUAL ACCESS 8
10.0 COMPLAINTS / RECOURSE 9
1.0 Purpose of Ledarney Manor Privacy
Ledarney Manor is a not-for-profit organization operated as a fundraising venture for Nova House Inc.
Protection and Electronic Documents Act ("PIPEDA"). PIPEDA sets out rules for the
collection, use and disclosure of personal information in the course of commercial
activity as defined in the Act.
1.1 The Ten Principles of PIPEDA Summarized
1.Accountability: organizations are accountable for the personal information they collect, use, retain and disclose in the course of their commercial activities,including, but not limited to, the appointment of a Chief Privacy Officer;
2.Identifying Purposes: organizations are to explain the purposes for which the information is being used at the time of collection and can only be used for those purposes;
3.Consent: organizations must obtain an Individual’s express or implied consent when they collect, use, or disclose the individual’s personal information;
4.Limiting Collection: the collection of personal information must be limited to only the amount and type that is reasonably necessary for the identified purposes;
5.Limiting Use, Disclosure and Retention: personal information must be used for only the identified purposes, and must not be disclosed to third parties unless the
Individual consents to the alternative use or disclosure;
6.Accuracy: organizations are required to keep personal information in active files accurate and up-to-date;
7.Safeguards: organizations are to use physical, organizational, and technological safeguards to protect personal information from unauthorized access or disclosure.
8.Openness: organizations must inform their clients and train their employees about their privacy policies and procedures;
9.Individual Access: an individual has a right to access personal information held by
an organization and to challenge its accuracy if need be; and
10.Provide Recourse: organizations are to inform clients and employees of how to
bring a request for access, or complaint, to the Chief Privacy Officer, and respond
promptly to a request or complaint by the individual.
"Personal information" means any information about an identifiable individual. It includes, without limitation, information relating to identity, nationality, age, gender, address, telephone number, e-mail address, Social Insurance Number, date of birth, marital status, education, employment health history, assets, liabilities, payment records, credit records, loan records, income and information relating to financial transactions as well as certain personal opinions or views of an Individual.
"Business information" means business name, business address, business telephone number, name(s) of owner(s), officer(s) and director(s), job titles, business registration numbers (GST, RST, and source deductions), financial status. Although business information is not subject to PIPEDA, confidentiality of business information will be treated with the same security measures by LEDARNEY MANOR staff, members and Board members, as is required for individual personal information under PIPEDA.
"Client" means anyone requesting information or books or has booked in the past at Ledarney Mano.
"Member" means a person who volunteers on a LEDARNEY MANOR committee, but who is not a current or active board member, or chair of the committee.
"Data base" means the list of names, addresses and telephone numbers of clients and individuals held by LEDARNEY MANOR in the forms of, but not limited to, computer files, paper files, and files on computer hard-drives.
"File" means the information collected in the course of processing a booking, as well
as information collected/updated to maintain /service the account.
"Express consent" means the individual signs for payment or, other forms containing
personal information, authorizing LEDARNEY MANOR to collect, use, and disclose the individual's personal information for the purposes set out in the application and/or forms.
"Implied Consent" means the organization may assume that the individual consents to
the information being used, retained and disclosed for the original purposes, unless
notified by the individual.
"Third Party" means a person or company that provides services to LEDARNEY MANOR in support of the programs, and other services offered by LEDARNEY MANOR, such as credit card companies, persons with whom the individual or client does business, but does not include any Government office or department to whom LEDARNEY MANOR reports in the delivery of such programs, benefits or services.
2.0 Purposes of Collecting Personal Information
Personal information is collected in order to respond to enquiries. The individual is the main source of information. Only that information which is required to make a reservation for an individual or business will be collected. Although the individual's Credit Card Number may be
requested for confirming the reservation, provision of this personal information is collected over the phone and not through this website.
An individual’s expressed written or verbal consent will be obtained before or at the time of
collecting personal information, for the creation of Charitable Tax receipts. The purposes for the collection, use or disclosure of the personal information will be provided to the individual at the time of seeking his or her consent. Once consent is obtained from the individual to use his or her information for those purposes, LEDARNEY MANOR has the individual's implied consent to collect or receive any supplementary information that is necessary to fulfill the same purposes.
Express consent will also be obtained if, or when, a new use outside of this policy is identified.
Express consent will be obtained from the individual prior to disclosing names, photos, images or other identifying items for use in marketing and promoting materials.
cannot be determined. LEDARNEY MANOR retains the right to use and disclose statistical data as it determines appropriate.
4.0 Limiting Collection
Personal information collected will be limited to the purposes set out in this Privacy
Policy, LEDARNEY MANOR applications, and/or other forms.
5.1 Use of Personal Information
Personal information will be used for only those purposes to which the individual has consented with the following exceptions, as permitted under PIPEDA:
LEDARNEY MANOR will use personal information without the individual's consent, where:
- the organization has reasonable grounds to believe the information could be useful
when investigating a contravention of a federal, provincial or foreign law and the information is used for that investigation;
- an emergency exists that threatens an individual’s life, health or security;
- the information is for statistical study or research;
- the information is publicly available;
- the use is clearly in the individual’s interest, and consent is not available in a
- knowledge and consent would compromise the availability or accuracy of the
information, and collection is required to investigate a breach of an agreement.
5.2 Disclosure and Transfer of Personal Information
Personal information will be disclosed to only those LEDARNEY MANOR employees, members of LEDARNEY MANOR committees, and the Board of Directors that need to know the information.
PIPEDA permits LEDARNEY MANOR to disclose personal information to third parties, without an individual's knowledge and consent, to:
- a lawyer representing LEDARNEY MANOR;
- collect a debt owed to LEDARNEY MANOR by the individual or client;
- comply with a subpoena, a warrant or an order made by a court or other body
with appropriate jurisdiction;
- a law enforcement agency in the process of a civil or criminal investigation;
- a government agency or department requesting the information; or as required by law.
PIPEDA permits LEDARNEY MANOR to transfer personal information to a third party, without the individual's knowledge or consent, if the transfer is simply for processing purposes
and the third party only uses the information for the purposes for which it was transferred.
LEDARNEY MANOR will ensure, by contractual or other means that the third party reasonably protects the information and uses it only for the purposes for which it was transferred.
5.3 Retention of Personal Information
Personal information will be retained in client files as long as the file is active and for
such periods of time as may be prescribed by applicable laws and regulations.
LEDARNEY MANOR endeavors to ensure that any personal information provided by the individual in his or her active file(s) is accurate, current and complete as is necessary to fulfill the purposes for which the information has been collected, used, retained and disclosed.
LEDARNEY MANOR will use physical, organizational, and technological measures to safeguard
Organizational Safeguards: Access to personal information will be limited to LEDARNEY MANOR staff that complete invoicing for payments or collections. Personal information provided to members of LEDARNEY MANOR committee(s) will be limited to only that information required to carry out the mandate of that committee such as aggregate statistical data.
Employees and members of Ledarney Manor committee(s) and/or Board of Directors are required to sign a confidentiality agreement binding them to maintaining the confidentiality of all
personal information to which they have access.
Physical Safeguards: Active files are stored in locked filing cabinets when not in use.
Access to work areas where active files may be in use is restricted to Ledarney Manor employees only and authorized third parties.
All inactive files or personal information no longer required are shredded prior to disposal
to prevent inadvertent disclosure to unauthorized persons.
Technological Safeguards: Personal information contained in LEDARNEY MANOR computers and electronic data bases are protected. E-mail and physical and logical access to LEDARNEY MANOR systems is applied in a way that takes reasonable commercial precautions to protect security.
9.0 Individual Access
An Individual who wishes to review or verify what personal information is held by LEDARNEY MANOR, or to whom the information has been disclosed (as permitted by the Act), may make the request for access, in writing, to LEDARNEY MANOR. Upon verification of the individual's identity, LEDARNEY MANOR will respond within 60 days.
If the individual finds that the information held by LEDARNEY MANOR is inaccurate or incomplete, upon the individual providing documentary evidence to verify the correct information, LEDARNEY MANOR will make the required changes to the individual's active file(s) promptly.
If an individual has a concern about Ledarney Manor personal information handling practices, a
complaint, in writing, may be directed to NOVA HOUSE INC., Executive Director.
Upon verification of the individual's identity, NOVA HOUSE INC. will act promptly to investigate the complaint and provide a written report of the investigation's findings to the individual.
Where the NOVA HOUSE INC., Executive Director makes a determination that the individual's complaint is well founded, NOVA HOUSE INC., will take the necessary steps to correct the offending information handling practice and/or revise Ledarney Manor privacy policies and procedures.
Where the NOVA HOUSE INC. Executive Director determines that the individual's complaint is not well founded, the individual will be notified in writing.
If the individual is dissatisfied with the finding and corresponding action taken by LEDARNEY MANOR, the individual may bring a complaint to the Federal Privacy Commissioner at the address below:
The Privacy Commissioner of Canada Email address: www.privcom.gc.ca.
112 Kent Street, Ottawa,
Ontario K1A 1H3
Nova House Inc.
Selkirk, MB R1A 2B3
Amendment to Ledarney Manor Privacy Policies