Policy on the Collection, Use and Disclosure Of Personal Information

“CRCS Privacy Notice” 

 

  1. The CRCS Privacy Notice and its application

  2. Definitions

  3. CRCS Accountability and Safeguards

  4. How Personal Information is used by the CRCS

  5. Personal Information on the CRCS Website

  6. Consent

  7. Limiting Collection, Use, Disclosure, and Retention

  8. Accuracy and Individual Access

  9. CRCS Privacy Contacts for concerns or questions

 

 

1.  The CRCS Privacy Notice and its application

The Canadian Red Cross Society (“CRCS”) is committed to respecting the privacy of its Donors and Clients. As part of this commitment, we want everyone to know our principles and practices for the collection, use, processing, transfer, storage or disclosure of your Personal Information.

This Privacy Notice outlines our policy and practices on the collection, use, transfer, storage and disclosure of Personal Information about Donors, Clients, and any other non-Red Cross individuals with whom we work.  A separate privacy policy applies to employees, volunteers, and contract staff when they are working on behalf of the CRCS. It requires them to uphold the principles and practices described in this Privacy Notice. The application of this Privacy Notice is subject to applicable laws including legislation, regulations, and the orders or lawful requests of any courts or other lawful authorities.

2.  Definitions

“Client(s)” means an individual(s) who a) is a CRCS Donor; b) has requested or used CRCS services; c) has given his or her information for assessment of needs; or c) registered for CRCS training and who is  not acting in their capacity as CRCS employees, volunteers, students, or contractors.

“Collection” means the act of gathering, acquiring, noting or obtaining by any other means Personal Information about an individual.

“Consent” means giving permission for the collection, use, and disclosure of Personal Information for certain purposes. Consent can be either express or implied and can be given orally, electronically or in writing. Implied consent is consent that can be reasonably inferred from an action or inaction.

“CRCS”, also referred to as “we” or “us”, means The Canadian Red Cross Society.

“Disclosure” means making Personal Information available to someone else.

“Donor(s)” means an individual(s) who makes a donation of money or securities to the CRCS or has indicated to the CRCS or to its agents an intention to make a donation to the CRCS.

“Personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred or determined from such information, but does not include information that is publically available, such as business contact information or information found in a telephone directory.

“Use” means the treatment, handling and management of Personal Information 

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3.  CRCS Accountability and Safeguards

The CRCS takes very seriously its responsibility to protect the personal information in our possession. We are accountable to our Clients and Donors to adopt and regularly review our practices to ensure they align with reasonable business practices appropriate to the level of sensitivity to safeguard personal information against loss or theft, unauthorized access, alteration or disclosure.

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4.  How Personal Information is used by the CRCS

The CRCS uses the Personal Information provided by Clients, Donors and others to facilitate assistance and training, activities, and outreach with the goal of assisting those in need in Canada and abroad. Our initiatives include providing and assisting in the provision of:

  • health and personal care services and programs;
  • Emergency  relief and preparedness services and programs;
  • violence, abuse, neglect and injury prevention services and programs;
  • tracing and reunion services;
  • first aid services and programs;
  • water safety services and programs;
  • training and awareness courses or programs in connection with any of the above

As well as:

  • conducting and facilitating fundraising and appeals;
  • managing our relationship with Clients and Donors;
  • meeting any legal or regulatory requirement of the CRCS;
  • other purposes consistent with the above.

How the CRCS uses Donor Personal Information

The Personal Information of CRCS is never sold or rented to other organizations. The Personal Information of some Donors may from time to time be traded with other reputable organizations in cases where the Donor has not opted out of inclusion in donor trade lists.

Electronic Donations:  The Personal Information of a Donor who donates electronically to the CRCS via our website is not shared with other organizations. However, if a person who initially donates to the CRCS electronically later responds to a CRCS Mail Solicitation, Donor Personal Information (including mailing address and e-mail addresses) may be shared with other organizations unless the donor opts out.

Mail Solicitation:  The Personal Information of  a Donor who responds to donation solicitations through the mail may from time to time be shared with other reputable organizations who share a similar vision to the CRCS. However, Donors are always given the opportunity to opt-out of inclusion in the donor trade lists.

Face-to-Face and Telemarketing:  The Personal Information of Donors who donate through face-to-face canvassers is never shared with other organizations unless they subsequently donate by mail and do not opt-out. Those who donate through Telemarketing may be part of shared lists depending on whether the Donor has previously opted-out of having his or her information shared.

Text-to-Donate:  The CRCS never receives the Personal Information of individuals who donate to us via a text message sent from their cell phone. The management of these donations is handled via a regulated telecommunications body and the CRCS only receives the donation itself.

Donations made Directly to a CRCS Office:  People making donations at a CRCS branch or zone office may note on their donation form that they do not want their Donor Information traded or do not wish further communications from the CRCS. The CRCS will honour any requests from the Donor for information to not be shared or to not receive further communication from the CRCS. If the Donor does not give such indication on the donation form, the Donor’s Personal Information may be included in lists traded with other reputable organizations.

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5.  Personal Information on the CRCS Website

The CRCS is the sole owner of the information collected on the www.redcross.ca  website (“our website”). The CRCS collects information from users at several different points on its website. We will not sell, trade, or rent information gathered from our website to others.   We use IP addresses to analyze trends, administer the site, track users’ movements, and gather broad demographic information for aggregate use.  IP addresses are not linked to personally identifiable information.

Cookies and Web Beacons:  For both anonymous visitors and known visitors to our website, we collect information such as the server your computer is logged onto, the domain name of your internet service provider, your browser type and version (for example, Netscape or Internet Explorer) and your IP address. An IP address is a number that is assigned to your computer automatically and required for using the Internet. We may also derive the general geographic area associated with an IP address. We use “cookies”, sometimes in combination with “web beacons” or similar technology to collect information about how this website is used such as average time spent on this website, pages viewed, and information searched for, access times, response rates to online or e-mail advertising and other relevant information about your online experience. If you are an anonymous visitor, the information in this paragraph does not personally identify you but rather numerically identifies your site and we share this cookie’s information with a third party marketing provider that will use it to deliver marketing about us to you while you visit other sites on the internet. Our third party provider is located in the United States. If you do not want to receive cookies on your computer, you must select the appropriate settings in your browser’s options; however, doing so may limit some of the interactivity our site offers you.

Links to Other Websites:  This website contains links to other sites. Please be aware that the CRCS is not responsible for the privacy practices of other such sites. We encourage our users to be aware when they leave our site and to read the privacy policy of every website that collects personally identifiable information. This Privacy Notice applies solely to information collected by this website.

Security and Confidentiality on our website:  All online transactions and contributions on this site occur through a safe, private, and secure system that protects the on-line Donor's personal information.

Communication with Donors via email:  From time to time we may communicate with a Donor via email. If an Donor does not wish further communication via email, he or she will given an opportunity to opt out. Members and donors can opt out of receiving any type of emails from us at any time by clicking on the unsubscribe link in the email or by contacting us at WeCare@redcross.ca or call us at 1-800-418-1111.

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6.  Consent

When an individual chooses to become of Donor or a Client of the CRCS, he or she is consenting to our collection, use and disclosure of his or her Personal Information in accordance with this Privacy Notice.  We may seek additional consent where required by law or in situations where we consider further consent to be necessary or appropriate.

An individual is free to refuse or withdraw his or her consent to the collection, use or disclosure of his or her Personal Information at any time upon reasonable notice in writing to the CRCS. A Client or Donor may decline to give the CRCS his or her Personal Information but, in some circumstances, this decision may hinder the CRCS ability to provide services to the Client or process the donation of the Donor.

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7.  Limiting Collection, Use, Disclosure, and Retention

Limitations on Collection and Use:  The CRCS strives to identify the purpose for which it is collecting Personal Information at the time it is collected through oral, electronic, or written means, although in extreme circumstances such as emergency response, it may not be possible to do so immediately. Personal Information will be collected, to the extent possible, directly from the individual concerned.  An individual with questions about how the CRCS collects Personal Information may contact us for more information at the Privacy Contacts listed in Section 9 of this Privacy Notice.

Disclosure:  CRCS does not disclose the Personal Information of its Donors or Clients without the Donor or Clients knowledge and consent except when consent is implied. In the case of Donors, implied consent includes donors who do not indicate their desire to “opt-out” of further communications or trade with other organizations. In certain rare circumstances, the CRCS may be permitted or obliged to disclose Personal Information without express consent. These circumstances include but are not limited to:  

  • where required by law or by order or requirement of a court, administrative agency or other governmental tribunal;
  • where we believe, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
  • where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain; or
  • where the information being disclosed or used is in the public domain.

Where the CRCS is obliged or permitted to disclose information without consent, we will not disclose more information than is minimally required in the applicable circumstances.

Retention:  CRCS retains personal information as long as necessary for the fulfillment of the identified purposes for its collection or as otherwise necessary to comply with applicable laws. When personal information is no longer necessary or relevant for the identified purposes, or is required to be retained by applicable laws, CRCS will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. CRCS uses reasonable business practices to ensure we have adequate controls, schedules and practices for information and records retention and destruction which apply to your personal information

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8.  Accuracy and Individual Access

The CRCS endeavours to ensure that any Personal Information provided to it by Clients or Donors is as accurate, current, and complete as necessary in order to meet the reason for which it was obtained.

Access:  An individual may request access to and review of personal information about themselves that is in the possession of the CRCS. Access will be provided within a reasonable business timeframe unless access is declined for one of the reasons described herein. We reserve the right to decline access to Personal Information where:

  1. The identity of the person requesting access can not be confirmed.
  2. The Personal Information is not readily retrievable and the burden or cost of providing it would be disproportionate to the nature or value of the information;
  3. The requested Personal Information does not exist, is not held, or cannot be found;
  4. Disclosure of the Personal Information would compromise the confidentiality of another individual or threaten the safety of another person.
  5. Non-disclosure of the Personal Information is required or permitted by law.

Requests to Change or Delete Information:  An individual may request that the CRCS change or delete Personal Information about themselves that is in the possession of the CRCS. We reserve the right not to change any Personal Information but will append any alternative text the individual concerned believes appropriate. We will make reasonable business efforts to comply with a request to delete an individual’s Personal Information as long as technological restraints or legal constraints do not limit our ability to fulfill the deletion request.

Where a request for access, alteration, or deletion of Personal Information is declined, the individual making the request will be provided with the reasons for declining the request.

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9.  CRCS Privacy Contacts for concerns or questions

In the event of questions about: (i) access to Personal Information;  (ii) the collection, use, management or disclosure of Personal Information by or on behalf of the CRCS; or (iii) this Privacy Notice, there are several options depending on who you are:

  1. Donors:  email wecare@redcross.ca
  2. Clients:  contact the Director General of the CRCS Zone in which you are ordinarily resident. A list of Zones and contact information is available at http://www.redcross.ca/who-we-are/contact-us
  3. Donors, Clients, or other third parties:  email privacy@redcross.ca or write to CRCS Privacy Officer, CRCS National Office, 170 Metcalfe, Ottawa, ON K2P 2P2