Privacy Policy

POLICY STATEMENT AND PURPOSE

Save the Children Canada is committed to protecting your privacy. We value the trust of our employees, volunteers, donors, members, supporters, and all others who work with us, and we recognize that maintaining your trust requires that we be transparent and accountable in how we handle your personal information. For that reason, we call our Privacy Policy and Practices “Our Commitment to Your Privacy.”

In carrying out our various programs and activities, we collect, use, disclose, and retain Personal Information. Anyone from whom we collect such information can expect that it will be carefully protected and that the use of this information is subject to consent. This Privacy Policy explains how Save the Children Canada collects, uses, discloses, retains, and safeguards the Personal Information of employees, volunteers, donors, members, supporters, and all others who work with us.

Save the Children Canada adheres to applicable personal privacy laws and guidelines, including the Personal Information Protection and Electronic Documents Act (PIPEDA), the Freedom of Information and Protection of Privacy Act (FIPPA), Canada’s Anti-Spam Legislation (CASL), and other relevant provincial and federal legal requirements. Save the Children is also a member of Imagine Canada and the Association of Fundraising Professionals, and adheres to the privacy guidelines published by those organizations.

By engaging with Save the Children Canada, accessing our website, making a donation, participating in our programs, volunteering, or otherwise providing Personal Information to us, individuals acknowledge that their information will be handled in accordance with this Privacy Policy.

DEFINITIONS

For the purposes of this Policy:

“Personal Information” means information about an identifiable individual. Personal Information may include names, addresses, telephone numbers, email addresses, donation histories, payment information, volunteer records, and other information necessary to carry out charitable activities and operations.

SCOPE

This Privacy Policy applies to Save the Children Canada and governs the collection, use, disclosure, retention, and protection of Personal Information obtained through our programs, services, events, fundraising activities, websites, social media channels, volunteer activities, and other interactions with donors, members, volunteers, beneficiaries, employees, contractors, and members of the public.

This Policy applies to all Personal Information collected by Save the Children Canada throughout Canada, whether information is collected in person, by telephone, by mail, by email, through online forms, or through third-party service providers acting on our behalf.

This Policy does not apply to:

· Information that has been anonymized so that it cannot reasonably identify an individual;

· Third-party websites, platforms, or services that may be linked to or accessed through our website or communications. Such third parties maintain their own privacy practices. Individuals should review the privacy policies of third parties before providing third parties with Personal Information

POLICY DETAILS

What types of Personal Information Do We Collect, Use, and/or Disclose, and Why?

With your express or implied consent, Save the Children collects, uses, and discloses Personal Information from supporters when they make a donation or opt in to receive communication from us. The potential purpose(s) of collection, use, and/or disclosure of Personal Information may be as follows:

Personal Information may also be collected, used, and/or disclosed for any of the following purpose(s):

· Any other purpose for which the information was requested and for which you have given permission, including but not limited to statistical and research purposes.

· As otherwise permitted by law.

Additionally, certain information is collected by the organization’s website to measure site traffic, statistical trends and online behaviour. Please see below for information on the use of cookies.

Job Applicant Information

In the context of its recruitment process, Save the Children Canada collects, uses, and discloses Personal Information about applicants to employee positions, as well as non-employee positions, such as internships, secondments, and students.

Save the Children Canada collects, uses, and/or discloses Personal Information to establish an employment relationship with the job applicant, and for various purposes, including: authenticating the candidate, identifying and attracting suitable candidates, performing initial candidate screening, evaluating suitability for positions, complying with legal obligations and processes, preventing and investigating security incidents or fraud, contacting applicants about employment opportunities, and verifying references.

Where permitted by applicable law, Personal Information is collected by the organization either directly from the applicant, or through background check providers, medical assessment providers, professional social media networks (e.g. LinkedIn), references and recruitment providers. The organization may also collect Personal Information from within the Save the Children network if the applicant is a current or former employee of one of the organizations within its network.

Personal Information of job applicants is collected, used, and retained in the organization’s Applicant Tracking System and Human Resources Information System. Save the Children Canada has appropriate technical and organization security measures in place, appropriate to the sensitivity of the Personal Information. Personal Information will be retained until the job applicant notifies the organization that the applicant no longer wishes to be contacted or once it is no longer needed, in accordance with the law.

Indigenous Data and Privacy

Save the Children Canada respects Indigenous Peoples’ rights to govern all data about their communities. The organization follows the First Nations principles of OCAP® with respect to the collection, use, disclosure, and retention of first nations’ data.

If a person identifies an error or omission in their Personal Information, they may request a correction. If the organization does not agree to the correction, the person may require the organization to attach a statement of disagreement, noting that a correction was requested but not made. Where someone requests a correction, the organization notifies any party that has received the information within the previous year of the correction or statement of disagreement.

How Do We Collect Personal Information?

We collect Personal Information about our donors and other interestholders in various ways, including from:

· donation reply coupons;

· our website and other charitable giving web sites;

· the phone;

· in-person;

· purchase order forms;

· personal cheques from first-time donors;

· third party suppliers, from whom we obtain confidentiality and protection of privacy commitments;

· public domain sources such as published directories or other organizations’ public documents such as annual reports, which facilitate our prospect research;

· list trading with other progressive, like-minded charities, from which confidentiality and protection of privacy commitments are obtained.

Donor List Trading and Third Party Suppliers

To help us find new supporters and to operate our fundraising programs cost-effectively, we may at times trade a small segment of our direct mail donor list with other progressive and like-minded charities whose purpose is aligned with ours, but only after you have had an opportunity to decline, and you may opt out of this arrangement at any time.

By agreeing to allow us to exchange your contact information, you help us to gain potential new supporter names and new support for vital, non-profit work.

Similarly, to enable us to provide a high level of donor service in a cost-effective manner, we may share your Personal Information with third party fundraising services suppliers after you have had an opportunity to decline the arrangement. These organizations enter into confidentiality and privacy protection agreements with us, and do not keep any donor information on file for longer than is needed to complete their work for us.

Privacy Practices and Safeguarding Personal Information

Save The Children Canada is responsible for the Personal Information in its possession and control, including information shared with a third party for processing. When information is shared with a third party, contracts are in place to ensure that the shared information is adequately protected.

Personal Information gathered by Save the Children Canada is kept in strict confidence. Certain staff members have authorized access to Personal Information based on their need to deal with the information for the reason(s) for which it was obtained. Safeguards are in place to ensure that the information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered. We also take measures to ensure that the integrity of this information is maintained and to prevent it from being lost, stolen or prematurely destroyed.

Personal Information is protected through physical, organizational, and technical measures. Access to Personal Information is restricted to employees and other agents of the company who require it to perform their job duties and to those otherwise authorized by law.

Data in Save the Children’s Salesforce CRM is encrypted and access is restricted as outlined above. Access to data is managed through profiles, roles, and sharing settings. Users login securely with Microsoft enabled Single Sign On and Multi Factor Authentication. Additionally, login restrictions, IP ranges, audit logs, and activity monitoring may be used to further strengthen security and control access.

No credit card details are stored in our customer database (see below for more information).

Furthermore, the company’s computer network systems and databases are secured by complex passwords. Physical files are kept in locked filing cabinets within locked rooms. The company ensures that employees who handle client Personal Information are aware of and understand the importance of maintaining the confidentiality of such information.

We collect, use and disclose Personal Information only for purposes that a reasonable person would consider appropriate under the circumstances.

Data Breach

In the event of a suspected or actual privacy breach of Personal Information, the organization investigates immediately. Identified individuals affected by the breach will be contacted as soon as possible, or where there is a risk of significant harm to an individual. After a suspected or actual breach, the organization reviews security protocols and implements any necessary safeguards to protect personal privacy.

Web Sites and Electronic Commerce

When you browse the Save the Children Canada’s web site, you do so anonymously. We collect only

the domain name (e.g. Sympatico, Gmail, etc.), and not the e-mail address of a visitor to our site.

At times, we may request web site visitors provide us with Personal Information, such as their name, e-mail address and postal address, for purposes such as corresponding with us, registering at our site, making a donation, entering a contest, or participating in an on-line survey.

Donors through our web site are linked to an industry-standard secure payment service for credit card transactions. Your credit card information is encrypted as it leaves your computer using Secure Socket Layer (SSL) 128-bit encryption, which is currently the strongest export-grade encryption available. This means that any data you send from your computer to Save the Children Canada is safe and secure.

The details of your donation are then retrieved from the server by Save the Children Canada using SSL 128-bit encryption. This ensures encryption is interpreted only by the intended recipient. Our software is routinely updated to maximize the protection of any information sent to us on-line.

Our web site uses cookies in a limited way. Cookies are small files containing information that a web site uses to track a visit. Both persistent and session cookies are used by many web sites. We only use session cookies. Session cookies do not remain on your computer at the end of your visit, and cannot be used to obtain any personally identifiable details. We use session cookies to better understand how our web site is used, to ensure our information and dynamic content are served up to visitors correctly, and to improve the performance of our web site for users, particularly the way search pages are delivered.

Copyright

All information contained on Save the Children Canada’s web site is copyrighted and is the property of Save the Children Canada unless otherwise stated, all rights reserved. Canadian copyright law and international treaties protect the textual, graphic, audio and audiovisual material on our site. You may not copy, distribute, or use these materials except as necessary for your personal, non-commercial use. Any trademarks remain the property of their respective owners.

External Links

There are links on the www.savethechildren.ca web site that take you to other web sites outside of our service. Any links provided to third party web sites outside of www.savethechildren.ca are provided solely for your convenience. The operation and content of such third party web sites are beyond our control, and we do not endorse in any manner whatsoever or accept any responsibility for the content or other material that may be contained on such web sites, the use of such web sites, or any other products or services advertised on or sold through any such web sites. We will not be liable under any circumstances for any damages whatsoever, direct or indirect, resulting from any use of our web site or any other third party web site linked to our web site, whether or not we are advised of the possibility of such damages.

Social Media Moderation Policy

Social channels are managed by Save the Children staff. We encourage sharing in an open and friendly environment. These guidelines are meant to help foster a positive experience for our supporters.

Please ensure that your comments and photos on social channels:

• Are relevant to our mandate

• Respect others and do not include discriminatory, hateful or harassing language

• Do not reveal any personal details – such as phone numbers, etc.

• Do not use inappropriate, offensive, sexist or racist language

We reserve the right to remove comments that we feel breach our guidelines.

SMS/MMS TEXT MESSAGING PROGRAM

Save the Children Canada offers a mobile messaging program. Frequency of commercial and transactional messages may vary. Users may opt-in or out of receiving messages at any time. If you do not wish to continue participating in the program or no longer agree to these terms you can reply “STOP” to any mobile messages from us in order to opt out of the program.

Please ensure you review the “Terms and Conditions” before participating in the program.

Your privacy is extremely important to us. We will only use information you provide through the program to transmit your mobile messages and respond to you, if necessary. This includes, but is not limited to, sharing information with platform providers, phone companies (carriers), and other vendors who assist us in the delivery of mobile messages. WE DO NOT SELL, RENT, LOAN, TRADE, LEASE, OR OTHERWISE TRANSFER FOR PROFIT ANY PHONE NUMBERS OR CUSTOMER INFORMATION COLLECTED THROUGH THE SMS PROGRAM TO ANY THIRD PARTY. Nonetheless, we reserve the right at all times to disclose any information as necessary to satisfy any law, regulation or governmental request, to avoid liability, or to protect our rights or property. When you complete forms online or otherwise provide us information in connection with the program, you agree to provide accurate, complete, and true information. You agree not to use a false or misleading name or a name that you are not authorized to use. If, in our sole discretion, we believe that any such information is untrue, inaccurate, or incomplete, or you have opted into the Program for an ulterior purpose, we may refuse you access to the program and pursue any appropriate legal remedies.

Retention and Disposal

Save the Children Canada retains Personal Information in accordance with applicable privacy laws to ensure the people it relates to have a reasonable opportunity to obtain access to their Personal Information.

When Personal Information is no longer required, it is archived or permanently deleted, safely, and securely. Personal Information is destroyed in such a way that it cannot be reconstructed or retrieved. The Organization takes reasonable steps to protect the security and confidentiality of Personal Information being destroyed or transferred. The Organization maintains a disposal record setting out which Personal Information was destroyed or transferred and when.

Updating of Privacy Policy and Contact Information

We regularly review our privacy practices, and update our Privacy Policy when warranted. Please check our web site www.savethechildren.ca on an ongoing basis or contact our Privacy Officer at privacy@savethechildren.ca for the most up-to-date information on our privacy practices.

Please contact our Privacy Officer about accessing, correcting and/or the deleting your Personal Information.

Further information on privacy and protection of Personal Information may be found on the web site of the Privacy Commissioner of Canada at https://www.priv.gc.ca/en/

All employees are expected to comply with this Policy and to seek clarification as needed from their manager or from People & Culture. Failure to comply with this Policy may result in disciplinary action up to and including termination of employment.

Managers and supervisors are responsible for overseeing compliance with this Policy by employees in their area of responsibility, which includes:

· Having oversight on the day-to-day collection, use, disclosure, and safeguarding of Personal Information under their control

· Ensuring staff with access to Personal Information are aware of and receive training on privacy protection procedures and practices established by SCC for the collection, use, disclosure, and safeguarding of personal information

· Watching for and identifying opportunities to correct conditions that may threaten the confidentiality, integrity, or security of information

· When entering into an arrangement with a third party (e.g., supplier, service provider), managers and supervisors shall ensure that any arrangements include appropriate privacy protection provisions to safeguard personal information in the custody of a third party.