CRYSTAL CATHEDRAL MINISTRIES OF CANADA (“CCMC”)
OUR COMMITMENT TO PRIVACY AND OUR PRIVACY PRACTICES
CCMC is committed to protecting the privacy, confidentiality and security of the personal information of CCMC members, constituents, supporters and other stakeholders. CCMC values the trust of those CCMC deals with and recognize that maintaining that trust requires that CCMC be transparent and accountable in how CCMC treats the information that you provide to CCMC.
During the course of CCMC’s various activities, CCMC frequently gathers and uses personal information. Anyone from whom CCMC collects such information should expect that it will be carefully protected and that except as otherwise legally required or permitted any use or other dealing with this information is subject to consent. CCMC’s privacy practices are designed to achieve this.
Personal information gathered by CCMC is kept in confidence. CCMC staff are authorized to access personal information based only on their need to deal with the information for the reasons 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. CCMC also take measures to ensure the integrity of this information is maintained and to prevent it being lost or destroyed.
This policy is based on the Ten Privacy Principles contained in the Canadian Standards Association (CSA) Model Code for the protection of personal information and on which the relevant privacy legislation is founded. CCMC has tailored its own ten privacy principles in compliance with the relevant privacy legislation to meet the specific needs and expectations of its stakeholders.
SCOPE OF POLICY
This policy does not apply to the collection, use or disclosure of your contact information or publically available information by CCMC.
In this policy:
“business contact information” means information to contact a person at a place of business, including the person’s name, position, business address, business telephone number, business e-mail address and business fax number.
“CCMC” means the Crystal Cathedral Ministries of Canada which operates a ministry at Surrey, BC.
“collection” means the act of gathering, acquiring, or obtaining personal information from any source, including third parties, by any means.
“consent” means voluntary agreement to the collection, use and disclosure of personal information for specified purposes. Consent may be express or implied. Express consent may be given orally or in writing, if it is clear and does not require any inference on the part of CCMC. Implied consent exists when CCMC can reasonably infer consent based upon your action or inaction.
“disclosure” means making personal information available to others outside of CCMC.
“personal information” means information about an identifiable person that is recorded in any form but does not include his or her business contact information. Personal information includes a person’s age, gender, race, ethnic origin, identification numbers, financial and credit information, personal health information, religious affiliations, donation history, travel history, consumer preference information, personal habits, personal interests and personal history. Personal information does not include information that cannot be associated with a specific person.
“privacy officer” means a person designated by CCMC who is accountable for compliance with this policy by CCMC and whose name and contact information are set out at the end of this policy.
“third party” means a person or organization other than CCMC and you.
“use” means the treatment and handling of personal information by and within CCMC.
CCMC is accountable and responsible for personal information under its control, including information that has been transferred to a third party. In cases where such transfers take place CCMC will ensure that the third party has comparable privacy safeguards in place. CCMC has designated a privacy officer to ensure compliance with this policy.
Ultimate accountability for CCMC compliance rests with the Board of Directors of CCMC who delegate day-to-day accountability to the privacy officer. Other persons within CCMC may be accountable for the day-to-day collection and processing of personal information or may act on behalf of the privacy officer.
CCMC will adopt policies, procedures and practices to protect personal information, receive and respond to complaints and inquiries, train staff regarding privacy policies, procedures and practices and communicate policies, procedures and practices to you.
2. IDENTIFYING THE PURPOSES OF PERSONAL INFORMATION
When collecting personal information CCMC will orally or in writing state the purpose of collection and will provide, on request, contact information for the privacy officer who can answer questions about the collection.
CCMC may collect your personal information for the following purposes:
-to provide and administer resource materials and other related products and services through CCMC;
-to provide administrative services through CCMC;
-to assess applications for membership in CCMC by prospective members;
-to contact members, constituents, supporters or other stakeholders regarding resource materials and other products and services of CCMC;
-to contact members, constituents, supporters and other stakeholders for special events, promotions, fund raising and other similar matters, which are directly or indirectly beneficial to CCMC;
-to administer the policies, procedures and practices of CCMC;
-to thank and publically recognize members, constituents, supporters and other stakeholders;
-to provide members, constituents, supporters and other stakeholders with information about how donated funds are used by CCMC;
-to keep members, constituents, supporters and other stakeholders informed about CCMC activities;
-to promote opportunities for members, constituents, supporters, potential constituents and supporters and other stakeholders to support CCMC;
-to establish and maintain lists of members, constituents, supporters or other stakeholders;
-to conduct surveys or research;
-to compile statistical and historical information about members, constituents, supporters and other stakeholders;
-to establish and maintain subscriptions to publications of CCMC or related organizations;
-to build and maintain relationships among stakeholders within CCMC;
-to disclose information requested by third parties (with permission of members, constituents, supporters or other stakeholders);
-to protect CCMC, you and others from fraud and error and to safeguard the interest of CCMC and its staff and representatives;
-to authenticate your identity;
-to ensure staff and contractors comply with their agreements and legal obligations to CCMC;
-to administer relations with the provincial, state and federal authorities, Crystal Cathedral Ministries in the United States (“CCMUS”), Crystal Cathedral Ministries in other countries (“CCMINT”) and other religious organizations with whom CCMC has relations from time to time;
-to comply with Canada Revenue Agency requirements for gift processing;
-to comply with any legal or regulatory requirement; and
-to use and disclose for any other purpose directly or indirectly related to establishment or operation of CCMC.
The above collections, uses and disclosures are a reasonably necessary part of your relationship with CCMC.
When your personal information is to be used for a purpose not previously identified, the new
purpose will be disclosed to you prior to such use, and your consent will be sought unless the use is permitted or required by law.
CCMC will obtain your consent to collect, use or disclose personal information except where CCMC is permitted or required by law to do so without consent. For example CCMC may collect, use or disclose personal information without your consent where:
-CCMC reasonably expects that obtaining consent would compromise an investigation or proceeding;-CCMC’s use of the information is for acting in an emergency that threatens a person’s life, health or personal security
-CCMC is obtaining legal advice; or
-CCMC needs to deal with an anticipated breach of law;
CCMC will make reasonable efforts to ensure that you understand how your personal information will be used and disclosed.
Your consent may be express or implied and may be given through an authorized representative such as a lawyer or agent. If you are under the legal age, your consent may be obtained from a parent or guardian.
Express consent may be given orally, in writing or electronically. For example, oral consent could be given over the telephone when information is being collected; electronically when submitting an agreement, application or other information; or in writing when signing an agreement or application. CCMC may imply consent if the purpose for the collection of the information would be reasonably obvious to you and is given voluntarily by you for that purpose. Consent may also be implied where CCMC notifies you that CCMC intends to collect, use or disclose information and you do not decline CCMC’s intended action within a reasonable period of time. The manner in which CCMC obtains consent for the collection of personal information will vary with the sensitivity of the information being collected.
You may withdraw your consent at any time, subject to legal or contractual restrictions, provided that CCMC is given reasonable written notice. CCMC will inform you of the likely consequences of the withdrawal of consent, which may include the inability of CCMC to provide certain products or services to you.
4. LIMITS FOR COLLECTING PERSONAL INFORMATION
CCMC will only collect personal information that is reasonably necessary to provide a product or service either directly or indirectly and which is reasonably necessary for the purposes which you consented to. CCMC will collect personal information by lawful means. CCMC may also collect information as permitted or required by law.
5. LIMITS FOR USING, DISCLOSING AND KEEPING PERSONAL INFORMATION
Your personal information will only be used or disclosed for the purpose for which it was collected. CCMC will not use personal information for any additional purpose unless CCMC seeks your consent to do so.
CCMC may periodically use your personal information to conduct surveys in order to enhance CCMC’s provision of products or services.
CCMC will not sell constituent, supporter or other stakeholder lists or personal information to third parties.
Subject to applicable legal requirements, CCMC, CCMUS and CCMINT may transfer personal information between each other. CCMUS may serve as a safe repository for some or all of your personal information. CCMUS and CCMINT will only use or disclose your personal information in accordance with the policies, procedures and practices of CCMC except where CCMUS and CCMINT are permitted or required by law to do otherwise. CCMUS and CCMINT will only use or disclose your personal information for the purposes for which it was collected and to assist CCMUS and CCMINT in carrying out duties on behalf of CCMC except where CCMUS and CCMINT are permitted or required by law to do otherwise.
CCMC will retain your personal information only so long as necessary for the identified purposes or for necessary legal or business purposes. CCMC will also keep your personal information used to make a decision affecting you for a least one year after using it to make the decision. CCMC will also keep personal information that is the subject of a request by you for as long as is necessary to allow you to exhaust recourse with respect to this personal information. Once CCMC no longer has a reason to retain your personal information, CCMC will destroy, erase or make anonymous documents or the records containing personal information.
CCMC will make reasonable efforts to ensure your personal information is as accurate, complete and current as required for the purposes for which it was collected. In some cases, CCMC will rely on you to ensure that certain information, such as your street address, e-mail address or telephone number, is current, complete and accurate.
CCMC will not routinely update your personal information unless it is necessary to fulfill the purposes for which it was collected. You may request amendments to the records at CCMC to ensure the accuracy and completeness of your personal information. If the amendment request relates to information that remains in dispute, CCMC will note your opinion on the file.
7. SAFEGUARDING PERSONAL INFORMATION
CCMC is committed to the safekeeping of your personal information in order to prevent its loss, theft, unauthorized access, disclosure, duplication, use or modification.
Depending on the sensitivity of your personal information, CCMC will employ appropriate security measures to protect the information. The measures may include, for example, the physical security of offices and data centers, the limiting of access on a “need-to-know” basis and the use of passwords and encryption.
CCMC will also use appropriate security measures when disposing of your personal information.
CCMC will require CCMUS, CCMINT and other third parties through contractual or other reasonable means to safeguard your personal information entrusted to them in a manner consistent with the policies, procedures and practices of CCMC.
8. AVAILABILITY OF POLICIES AND PROCEDURES
CCMC is open about the policies, procedures and practices it uses to protect your personal information. Information about these policies, procedures and practices will be made available to you either electronically or in writing. To ensure the integrity of our security procedures and business methods, CCMC may refuse to publically disclose certain information.
CCMC will make the following information available:
-The name, title and address of the person accountable for the polices, procedures and practices and to whom complaints or inquiries can be provided;
-A description of the type of personal information held by CCMC, including a general account of its use;
-A copy of any brochures or other information that explain the policies, procedures and practices; and
-An explanation of what personal information is made available to related organizations.
9. PROVIDING ACCESS TO YOUR PERSONAL INFORMATION
You have a right to access your personal information held by CCMC. Upon request and confirmation of your identity, CCMC will, within a reasonable period of time, tell you what personal information it has, what it is being used for and to whom it has been disclosed. You may be asked to be specific about the information that you would like to access and to submit your request in writing. Depending on the type and amount of information requested, CCMC may charge you a reasonable fee for providing you with access to your information. Where a cost will be incurred by you, CCMC will inform you of the cost and request your direction on whether or not CCMC should proceed with the request.
CCMC will make the information available within 30 days or provide written notice where additional time is required to fulfill the request.
In some situations, CCMC may not be able to provide access to certain personal information. The reasons for not providing this information may include that it is information that would threaten the life or security of another person, information generated in a formal dispute resolution process, information that contains references to other individuals, information that cannot be disclosed for legal, security or commercial proprietary reasons and information that is subject to solicitor-client privilege.
If a request is refused, CCMC will notify you in writing, setting out the reasons for the refusal and resources for redress available to you .
If your personal information is demonstrated to be inaccurate or incomplete, CCMC will amend the information as required. Where appropriate CCMC will send the amended information to third parties to whom the information has been disclosed.
10. COMPLIANCE AND COMPLAINTS
CCMC will, on request, provide you with information regarding its complaint response procedure.
You are to direct any complaints, concerns or questions regarding this policy in writing to the privacy officer. If the privacy officer is unable to address your concern, the issue can be referred to the Board of Directors of CCMC . At any point in this process you may also write to the Privacy Commissioner.
Privacy Officer #14 – 15243 – 91 Avenue Surrey, BC V3R 9K2 Phone: (604) 581-7654 Fax: (604) 581-3798 Email: firstname.lastname@example.org
to view the Policy. For more information or if you have questions, you can contact our privacy officer at #14 – 15243 – 91 Avenue, Surrey, BC, V3R 9K2.”