Objective/Background

Canadian Foodgrains Bank collects and stores, in an electronic database, information on donors and volunteers. The policy and procedures below outline how this information is managed and used in order to protect the privacy of the individuals involved, and to respect the Personal Information and Electronic Documents Act passed by Canadian Parliament in 2000. The purpose of the act is to establish rules to govern the collection, use and disclosure of personal information in the private sector, including charities. These rules seek to balance the privacy rights of individuals with respect to personal information and the need of organizations to collect, use and/or disclose that information in the course of their activities. The intent of the legislation is to limit the use of personal information to purposes a reasonable person would consider appropriate in the circumstances.

Policy

  1. Purpose of Donor Information: Canadian Foodgrains Bank will collect and use personal information regarding donors for the following purposes only:
    • issuing receipts and expressing thanks to donors
    • reporting to government agencies as required by law
    • providing information to the donor on Foodgrains Bank and member activities
    • soliciting follow-up donations to Foodgrains Bank
    • analyzing the type and amount of donations over time and in relation to various characteristics such as location and donation designation
  2. Purpose of Volunteer Information: Canadian Foodgrains Bank will collect and use personal information regarding volunteers for the following purposes only:
    • contacting past or present volunteers, or individuals that have expressed an interest in volunteering
    • maintaining information on the availability of volunteers, location, past and present types of volunteer activity, areas of interest in volunteering, and capability and suitability of the volunteer
    • analyzing the number, type and activity level of volunteers
  3. Limiting Information Collection: Canadian Foodgrains Bank will only collect and store personal information necessary to fulfill the above purposes.
  4. Consent: Consent to collect, maintain and use donor and volunteer information for the above purposes is understood to be implicit when a donation is made, and when a person volunteers for Foodgrains Bank or expresses an interest in volunteering, unless explicit instructions are received not to use the information for any of the above purposes.
  5. Accuracy: The donor and volunteer information will be kept accurate and as current as necessary to fulfill the above purposes.
  6. Third Party Disclosure: Canadian Foodgrains Bank will not disclose personal information regarding donors to other organizations, except to member agencies to whom the donation was designated or third parties being used to facilitate a mailing to donors and volunteers. Any disclosure of donor information to member agencies will be permitted if the member agency signs an agreement to use the information only for the purposes outlined above. Disclosure of information to third parties to facilitate a mailing will be governed by an agreement that prevents the third party from using the information for any other purpose. Canadian Foodgrains Bank will disclose information on volunteers to churches, community groups or other organizations only for purposes related to Foodgrains Bank or member activities as outlined in the policies above.
  7. Safeguards: Canadian Foodgrains Bank will take reasonable measures to safeguard individuals’ personal information against loss, theft, unauthorized disclosure, copying, use or alteration.
  8. Openess: This policy regarding personal information privacy will be made available to the public on request, posted on the website, and disclosed through regular communications to donors and volunteers.
  9. Individual Access: Individuals may access their personal information as retained by Canadian Foodgrains Bank to ensure its accuracy and completeness, and to identify to whom it was disclosed. Canadian Foodgrains Bank retains the right to reasonably authenticate requests.
  10. Responsibility: Executive Director is designated as responsible for ensuring Canadian Foodgrains Bank is in compliance with the Personal Information and Electronic Documents Act and the above policies, and responding to any inquiries or complaints regarding Canadian Foodgrains Bank’s personal information privacy policies and practices.
  11. Challenging Compliance: Individuals may challenge Canadian Foodgrains Bank’s compliance with the above policies or the relevant privacy legislation through the Executive Director of the Foodgrains Bank or by making a complaint to the Privacy Commissioner.

Procedures

  1. Staff Training: All staff will be informed about the above personal information privacy policy and its implications, including confidentiality obligations with respect to personal information. This information will be part of any new employee’s orientation.
  2. Safeguards: Donor and volunteer information will be stored in a password protected database available to designated Foodgrains Bank staff only. Staff generating and distributing any reports containing personal information from this database must ensure the information will not be copied or used for any purposes not specified in the personal information privacy policy. It is the responsibility of staff to ensure the necessary precautions are taken to protect this personal information. Phone call enquiries about donor and volunteer information will be directed to staff authorized to deal with this information. Information will only be released after authentication of the request. Written responses regarding donor information will be directed only to the donor themselves, or an appointed agent such as the person’s lawyer, accountant, or estate executor.
  3. Disclosure of Information to Members: Donor information will only be disclosed to member agencies upon a specific request. An agreement with the member agency must be developed and signed limiting how the information can be used before any information is released. This agreement must be in compliance with Foodgrains Bank’s personal information privacy policies and the law.
  4. Disclosure of Information to Other Third Parties: Donor and volunteer information provided to third parties for the purpose of facilitating mailings must be restricted to name and address information only. There must be an agreement with the third party to use the information for the mailing of materials only. The third party must not reuse or sell the information for any other purpose.