ARK is committed to safeguarding the personal information entrusted to us by our members, donors, volunteers and by prospective and selected project recipients. We manage your personal information in accordance with Alberta’s Personal Information Protection Act and other applicable laws. This policy outlines the principles and practices we follow in protecting your personal information.
This policy applies to ARK and to any person providing services on our behalf. A copy of this policy is provided to any stakeholder on request.
What is personal information?
Personal information means information about an identifiable individual. This includes an individual’s name, home address and phone number, age, sex, marital or family status, an identifying number, financial information, educational history, etc.
For members and donors, this includes an individual’s name, home address, email address and phone number. For donors this also includes donation amounts and donation dates and might also include a credit card number.
For volunteers, this includes an individual’s name, home address, email address, phone number, employment status, emergency contact, volunteer interests, educational history as well as a declaration of any history of unpardoned convictions in the past five years and of medical conditions that might affect volunteering.
For potential and selected project recipients, this includes the name, home address and contact information of parents or guardians, the name, age, medical history and physical limitations of the child or youth on whose behalf application is made, the names and ages of siblings, home type, age and ownership status, household income and contact information for occupational therapist or social workers who are knowledgeable about the family. For selected project recipients this also includes confirmation of income, home ownership and personal net worth.
What personal information do we collect?
We collect only the personal information that we need for the purposes of conducting ARK business, including personal information needed to:
- Communicate with members, volunteers and prospective and selected project recipients about ARK activities and fundraising initiatives
- Provide tax receipts (once charity registration is in effect) to donors
- Select project recipients according to our selection process
- Plan and raise money for projects to meet the needs of selected project recipient
We normally collect personal information directly from members, donors, volunteers and prospective and selected project recipients. For prospective project recipients, we might also obtain personal information from those who nominate a recipient or family, or from an OT or social worker who has been authorized by a prospective or selected project recipient to provide information to us.
We inform our stakeholders, before or at the time of collecting personal information, of the purposes for which we are collecting the information. The only time we don’t provide this notification is when information is provided for an obvious purpose (for example, producing a credit card to make a donation when the information will be used only to process the payment).
We ask selected project recipients for express consent for disclosure of private information about the family of a project recipient as we may not be able to successfully fundraise for a project if the selected project recipient were unwilling to provide this consent and information. Where express consent is needed, we ask for consent in writing.
A member, donor, volunteer or prospective project recipient may withdraw consent to the use of personal information at any time. A selected project recipient may also do so, unless personal information is necessary for us to fulfil our legal obligations. We will respect your decision, but we may not be able to complete a project if we do not have the necessary personal information or if we do not have your consent to disclose some personal information.
We may collect, use or disclose member, donor, volunteer and prospective or selected project recipient personal information without consent only as authorized by law. For example, we may not request consent when the collection, use or disclosure is to determine suitability for an honour or award, or in an emergency that threatens life, health or safety.
We ask for consent to collect, use or disclose personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law. We may assume your consent in cases where you volunteer information for an obvious purpose.
We assume your consent to continue to use and, where applicable, disclose personal information that we have already collected, for the purpose for which the information was collected.
How do we use and disclose personal information?
We use and disclose client personal information only for the purpose for which the information was collected, except as authorized by law. For example, we may use member contact information to provide a newsletter update about ARK activities.
ARK does not sell personal information to any third parties.
If we wish to use or disclose your personal information for any new business purpose, we will ask for your consent. We may not seek consent if the law allows this.
What is personal employee information?
Although ARK has no employees, volunteers are considered employees under the act.
Personal employee information is personal information about a volunteer which is collected, used or disclosed solely for the purposes of establishing, managing or terminating a volunteer work relationship.
We can collect, use and disclose your personal volunteer information without your consent only for the purposes of establishing, managing or ending the employment or volunteer relationship. We will provide current employees and volunteers with prior notice about what information we collect, use or disclose and our purpose for doing so.
What personal employee information do we collect, use and disclose?
We collect, use and disclose personal employee information to meet the following purposes:
- Determining eligibility for volunteer work, including verifying qualifications and references
- Establishing training and development requirements
- Assessing performance and managing performance issues if they arise
- Complying with requirements of funding bodies (e.g. lottery grants)
- Complying with applicable laws (e.g. Canada Income Tax Act, Alberta Employment Standards Code)
We only collect, use and disclose the amount and type of personal employee information that is reasonable to meet the above purposes. The following is a list of personal employee information that we may collect, use and disclose to meet those purposes.
- Contact information such as your name, home address, telephone number, email ID
- Criminal background checks
- Employment or volunteer information such as your resume (including educational background, work history and references), reference information and interview notes, policy acknowledgement forms, background verification information, workplace performance evaluations, emergency contacts, etc.
- Other personal information required for the purposes of our volunteer relationship
We will inform our employees and volunteers of any new purpose for which we will collect, use, or disclose personal employee information, or we will obtain your consent, before or at the time the information is collected.
We will obtain your consent to collect, use and disclose your personal information for purposes unrelated to the employment or volunteer relationship.
What information do we provide for employment/volunteer references?
In some cases, after your volunteer relationship with us ends, we will be contacted by other organizations and asked to provide a reference for you. It is our policy not to disclose personal information about our volunteers to other organizations who request references without consent. The personal information we normally provide in a reference includes:
- Confirmation that an individual was a volunteer, including the position, and date range of the volunteering
- General information about an individual’s job duties and information about the volunteer’s ability to perform job duties and success in the volunteer relationship
How do we safeguard personal information?
We make every reasonable effort to ensure that personal information is accurate and complete. We rely on individuals to notify us if there is a change to their personal information that may affect their relationship with our organization. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible. In some cases we may ask for a written request for correction.
We protect personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information. Some information is retained on cloud storage, with controls on the individuals who have access to the folders. The most sensitive information is retained in hardcopy format only by the Chair.
We use appropriate security measures when destroying personal information, including shredding paper records and permanently deleting electronic records.
We retain personal information only as long as is reasonable to fulfil the purposes for which the information was collected or for legal or business purposes.
Access to records containing personal information
Individuals have a right to access their own personal information in a record that is in the custody or under the control of ARK subject to some exceptions. For example, organizations are required under the Personal Information Protection Act to refuse to provide access to information that would reveal personal information about another individual.
If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record.
You may make a request for access to your personal information by writing to Kevin Quan, ARK PIPA Officer at email@example.com. You must provide sufficient information in your request to allow us to identify the information you are seeking.
You may also request information about our use of your personal information and any disclosure of that information to persons outside our organization. In addition, you may request a correction of an error or omission in your personal information.
We will respond to your request within 45 calendar days, unless an extension is granted. We may charge a reasonable fee to provide information, but not to make a correction. We do not charge fees when the request is for personal employee information. We will advise you of any fees that may apply before beginning to process your request.
Questions and complaints
If you have a question or concern about any collection, use or disclosure of personal information by ARK or about a request for access to your own personal information, please contact Kevin Quan, ARK PIPA Officer at firstname.lastname@example.org.
If you are not satisfied with the response you receive, you should contact the Information and Privacy Commissioner of Alberta:
Office of the Information and Privacy Commissioner of Alberta
Suite 2460, 801 – 6 Avenue, SW
Calgary, Alberta T2P 3W2
Phone: 403-297-2728 Toll Free: 1-888-878-4044