Privacy Policy

Privacy Policy

United Way Hastings & Prince Edward, Inc. is committed to protecting the privacy of our donors and stakeholders (consumers, volunteers, agencies, staff, directors, community partners) and maintaining the confidentiality of personal information.

1. Purpose and Privacy Commitment

United Way Hastings & Prince Edward (UWHPE) values the trust placed in us by donors, volunteers, employees, community partners, funded agencies, event participants and other members of our community. We are committed to respecting privacy and protecting personal information that is entrusted to us or collected by lawful means.

This Policy describes how UWHPE collects, uses, discloses, retains, protects and disposes of personal information. It is intended to support compliance with applicable privacy requirements and the fair information principles reflected in the Personal Information Protection and Electronic Documents Act (PIPEDA), where applicable to UWHPE activities.

This Policy should be read together with UWHPE’s Confidentiality Policy, Data Retention Policy and Responsible Use of Artificial Intelligence (AI) Tools Policy. Those policies provide additional requirements for confidentiality, retention and disposal, and the use of personal or sensitive information with AI tools.

2. Scope and Application

This Policy applies to personal information under UWHPE’s custody or control in all formats, including electronic records, paper records, photographs, audio or video, and information maintained on UWHPE’s behalf by authorized third-party systems or service providers.

It applies to personal information relating to prospective, current and past donors; volunteers; employees and contractors; Board members; event and program participants; funding applicants and agency or community contacts where information is personal rather than business contact information; and other individuals who interact with UWHPE.

This Policy applies across UWHPE activities and channels, including fundraising and workplace campaigns, donations and designations, events, volunteer activities, employment, community initiatives, websites, electronic communications and other organizational operations.

UWHPE is an autonomous organization. Where information is shared with another United Way, a workplace, a designated charity or another organization, the sharing will be limited to an identified purpose and handled in accordance with this Policy and applicable requirements.

3. What We Mean by Personal Information

Personal information is information about an identifiable individual. Depending on the activity, this may include:

  • name, home address, personal telephone number and personal email address;
  • donation, pledge, payment, receipting and transaction information;
  • communication preferences and records of interactions with UWHPE;
  • volunteer, employment, contractor or Board-related information;
  • event registration or participation information;
  • photographs, video or other recorded images where an individual is identifiable;
  • information submitted through UWHPE websites, forms, surveys or digital platforms; and
  • other information that identifies an individual alone or in combination with other information.

Business contact information used solely to communicate with an individual in relation to their employment, business or profession may be treated differently under applicable privacy law.

4. Privacy Principles

4.1 Accountability

UWHPE is responsible for personal information under its custody or control, including information transferred to an authorized service provider for processing on UWHPE’s behalf. The Executive Director serves as UWHPE’s Privacy Officer unless another individual is formally designated.

The Privacy Officer is responsible for oversight of UWHPE’s privacy practices, responding to privacy questions and complaints, and supporting implementation and review of this Policy. Staff, Board members and volunteers are responsible for protecting information they access through their UWHPE roles in accordance with the Confidentiality Policy.

Vendors or service providers requiring access to personal or confidential information must be appropriately authorized and are subject to confidentiality and privacy requirements. UWHPE’s Confidentiality Policy requires an appropriate non-disclosure agreement or approved non-disclosure language where a vendor requires such access.

4.2 Identifying Purposes

UWHPE identifies the purposes for collecting personal information before or at the time the information is collected, unless the purpose is otherwise evident and appropriate in the circumstances. Personal information may be collected, used or disclosed for purposes such as:

  • processing donations, pledges and payments and issuing charitable tax receipts;
  • administering workplace giving campaigns and payroll deductions;
  • redirecting or designating donations to another United Way or registered charity as instructed by the donor;
  • maintaining donor relationships, donation history and communication preferences;
  • communicating information about UWHPE, its impact, campaigns, events, volunteer opportunities and other activities;
  • registering and administering events, meetings, programs or community initiatives;
  • recruiting, supporting and administering volunteers, employees, contractors and Board members;
  • administering funding, partnership and community-impact activities where personal information is required;
  • recognizing contributions, where the individual has consented or recognition is otherwise appropriate and permitted;
  • responding to requests, inquiries, concerns and complaints;
  • producing statistics, evaluation, research or aggregate reporting where individuals are not identified unless identification is necessary and authorized;
  • protecting UWHPE, its people, systems and assets against fraud, misuse, legal, financial or security risks; and
  • meeting legal, regulatory, contractual, audit and reporting requirements.

If UWHPE wishes to use personal information for a materially different purpose, it will identify the new purpose and obtain consent where required.

4.3 Consent

UWHPE will obtain meaningful consent for the collection, use or disclosure of personal information where consent is required. Consent may be express or implied depending on the sensitivity of the information, the reasonable expectations of the individual and the circumstances. Collection, use or disclosure without consent will occur only where permitted or required by law.

Individuals may withdraw consent or change communication preferences, subject to legal, contractual, operational or technical restrictions and reasonable notice. Withdrawal of consent may affect UWHPE’s ability to provide a requested service or complete an activity. UWHPE may retain limited information where necessary to honour a do-not-contact request or meet legal obligations.

4.4 Limiting Collection

UWHPE will collect only the personal information reasonably necessary for identified and legitimate purposes and will collect it by fair and lawful means. Staff should avoid collecting personal information simply because it may be useful in the future.

4.5 Limiting Use, Disclosure and Retention

UWHPE will use and disclose personal information only for the purposes for which it was collected, for a related purpose that a reasonable person would consider appropriate, with additional consent where required, or as otherwise permitted or required by law. UWHPE does not sell personal information.

Personal information may be disclosed in limited circumstances, including:

  • to a workplace where information is necessary to administer a workplace campaign or payroll deduction;
  • to another United Way where UWHPE administers a donation associated with that United Way’s community;
  • to a charity selected by a donor for a designated gift, subject to the donor’s instructions and applicable consent;
  • to authorized service providers performing functions on UWHPE’s behalf, with access limited to what is reasonably necessary;
  • to event or program partners where information sharing is necessary to administer participation and the individual has been appropriately informed;
  • to government, regulatory, law-enforcement or other authorities where disclosure is required or permitted by law; or
  • in other circumstances with the individual’s consent or as otherwise permitted or required by law.

Personal information will be retained only as long as required for the purposes for which it was collected and for applicable legal, financial, audit or operational requirements. Specific retention periods and requirements for secure destruction, anonymization and de-identification are established in UWHPE’s Data Retention Policy.

4.6 Accuracy

UWHPE will take reasonable steps to ensure that personal information is as accurate, complete and current as necessary for the purposes for which it is used. Individuals may request correction of inaccurate or incomplete personal information. UWHPE will make appropriate corrections or explain why a requested correction cannot be made.

4.7 Safeguards and Confidentiality

UWHPE will use administrative, physical and technical safeguards appropriate to the sensitivity, amount, format and location of personal information. Access will be limited to individuals who require the information to perform authorized responsibilities.

All staff, Board members and volunteers must comply with UWHPE’s Confidentiality Policy, including its requirements respecting need-to-know access, unauthorized disclosure, inadvertent exposure and the handling of confidential information. Contractors and service providers with access to personal or confidential information are subject to appropriate contractual confidentiality and privacy requirements.

Where personal information is processed or stored using third-party services, UWHPE will take reasonable steps to select and manage providers appropriately. Information may in some circumstances be processed or stored outside Canada and may therefore be subject to the laws of the jurisdiction in which it is processed or stored.

4.8 Privacy Incidents and Breaches

Suspected loss, unauthorized access, disclosure, misuse or other compromise of personal information must be reported promptly to the Executive Director / Privacy Officer. UWHPE will assess the incident, take reasonable steps to contain and mitigate harm, document the response, and provide notifications or reports where required by applicable law.

4.9 Openness

UWHPE will make information about its personal-information practices readily available. This Privacy Policy will be made available on UWHPE’s website and, on request, in another reasonably accessible format where practicable.

4.10 Individual Access

An individual may request information about whether UWHPE holds personal information about them and may request access to that information, subject to legal limitations. UWHPE may require a written request and sufficient information to verify identity and locate the relevant records before releasing personal information.

Where access cannot be provided, in whole or in part, UWHPE will explain the reason to the extent permitted by law. Requests for correction will be handled in accordance with section 4.6 of this Policy.

4.11 Questions, Concerns and Complaints

Questions, access requests or privacy-related complaints should be directed to UWHPE’s Privacy Officer. UWHPE will review privacy complaints and, where a concern is substantiated, take reasonable corrective action, which may include changes to practices, procedures or policies.

Privacy Officer: Executive Director, United Way Hastings & Prince Edward
Email: bhodge@unitedwayhpe.ca

5. Fundraising, Workplace Campaigns and Donor Information

Because fundraising is central to UWHPE’s work, donor information requires particular care. UWHPE may maintain information necessary to administer donations and pledges, issue receipts, understand and steward donor relationships, honour communication preferences, administer workplace campaigns and report on fundraising activity.

Where a donation is made through a workplace, UWHPE may share with the workplace only the information reasonably necessary to administer the campaign or payroll deduction. Where a donor directs a gift to another charity or United Way, UWHPE may provide the information reasonably necessary to administer that direction, subject to the donor’s instructions and consent requirements.

Donor information is subject to the Confidentiality Policy. Retention and disposal of donor information is governed by the Data Retention Policy.

6. Photographs, Video and Events

UWHPE may photograph or record events and activities for documentation, reporting and promotional purposes. Where individuals are identifiable, UWHPE will use reasonable measures appropriate to the circumstances to inform participants and obtain consent where required, with particular care where children, vulnerable individuals or sensitive circumstances are involved.

Event registration information will be collected and used only for identified purposes and will be retained in accordance with the Data Retention Policy.

7. Online and Digital Practices

UWHPE websites and digital services may collect information that individuals submit directly, such as donation, registration, subscription or inquiry information, and may also collect technical information about website use through cookies, analytics or similar technologies.

UWHPE may use cookies, analytics and similar tools to operate and secure its websites, understand website and communication performance, and improve user experience. The information collected and the tools in use may change as UWHPE’s digital services evolve. Where required, UWHPE will provide appropriate notice or choices regarding these technologies.

UWHPE may use third-party platforms for donations, payments, event registration, email communications, analytics, cloud storage or other services. Those providers have their own systems and may process information in jurisdictions outside Canada. UWHPE will take reasonable steps to manage service-provider privacy and security risks consistent with section 4.7.

UWHPE websites or communications may contain links to websites operated by third parties. UWHPE is not responsible for the privacy practices of websites or services it does not operate.

8. Artificial Intelligence and Automated Tools

UWHPE supports responsible use of artificial intelligence and other automated tools where they can improve productivity, innovation and organizational effectiveness without compromising privacy, confidentiality, security or appropriate human judgment.

Use of AI tools is governed by UWHPE’s Responsible Use of Artificial Intelligence (AI) Tools Policy. In particular, staff and volunteers must not enter personally identifiable information, donor information or other restricted or sensitive information into AI tools except where expressly authorized under that Policy and through an approved secure and compliant system.

AI-generated outputs must remain subject to appropriate human review. UWHPE will review its use of AI and automated technologies as practices, risks and applicable requirements evolve.

9. Retention and Secure Disposal

UWHPE’s Data Retention Policy establishes retention periods for categories of personal information, including donor and fundraising records, volunteer information, employee and contractor records, Board member information, and event participant and general contact information.

At the end of the applicable retention period, personal information will be securely destroyed, deleted, anonymized or de-identified as appropriate, subject to legal, financial, audit or other legitimate requirements. A minimal suppression record may be retained where necessary to respect an individual’s communication preferences.

10. Roles and Responsibilities

  • The Board of Directors is responsible for approving this Policy and supporting appropriate oversight of organizational privacy governance.
  • The Executive Director / Privacy Officer is responsible for implementation and oversight of this Policy and for responding to privacy concerns, access requests and incidents.
  • Staff are responsible for following this Policy and related policies and procedures, limiting access and use to authorized purposes, and promptly reporting suspected privacy incidents.
  • Board members and volunteers are responsible for protecting personal and confidential information obtained through their roles and complying with the Confidentiality Policy.
  • Contractors and service providers are responsible for complying with applicable contractual privacy, confidentiality and security requirements.

11. Related UWHPE Policies and Procedures

  • Confidentiality Policy – establishes obligations for staff, Board members, volunteers and vendors to protect personal, privileged and proprietary information and restrict disclosure to authorized, need-to-know purposes.
  • Data Retention Policy – establishes detailed retention periods and requirements for secure deletion, destruction, anonymization and de-identification of personally identifiable information.
  • Responsible Use of Artificial Intelligence (AI) Tools Policy – establishes restrictions and safeguards governing the use of personal, donor, confidential and sensitive information with AI tools.
  • Any applicable information-security, incident-response, electronic-communications, donor-management or records-management procedures adopted by UWHPE from time to time.

12. Policy Review

This Policy will be reviewed at least every three years, or sooner where changes to legislation, technology, organizational practices, risks or related UWHPE policies warrant review. Material changes will be approved by the Board of Directors.

Any questions about protecting the personal privacy of our donors or our privacy policy should be directed to:

Brandi Hodge
Executive Director
Email: bhodge@unitedwayhpe.ca
Ph: 613 962 9531