Policy Statement
Tropicana Community Services Organization (TCSO) seeks to meet human needs and improve social conditions by mobilizing the community’s volunteer and financial resources in a common cause of caring.  This policy outlines TCSO’s commitment to respecting the privacy of personal information of individuals and helps to understand how to collect, use, protect, access disclose and dispose of personal information.

Purpose
The purpose of this policy is to outline the organization’s expectations when it comes to

the policy to, direct staff on how to treat your information; ensure respect your personal privacy and do our best to maintain confidentiality; and ensure we obey the laws regarding the protection of personal information.

Guidelines
We will tell you why we ask for personal information and how we will use the information you give us. We will only ask for information that we need to provide service to you. 

Accountability
TCSO is responsible for all personal information in our possession, including any personal information transferred to third parties for handling or administrative purposes.  TCSO’s Chief Privacy Officer establishes and oversees the appropriate privacy practices and governance. TCSO may ask permission to use your personal information for other purposes, such as to help you apply for other services, or advocate for you at your request.

All employees, volunteers) and authorized service providers of TCSO are required to protect the confidentiality of your personal information. All employees and agents are required to sign and adhere to a Code of Conduct & Ethics which ensures they are informed about the importance of privacy protection. TCSO provides employees and volunteers with periodic information to ensure they are knowledgeable about our privacy policy, related policies, and privacy developments.

Where we choose to have certain services, such as data processing, provided by third party service providers, we select the service providers carefully. We take all reasonable precautions to ensure that the service providers protect your personal information. These service providers enter into agreements with TCSO that confirm they have privacy and security standards comparable to our own.

Identifying Personal Information
We only collect the personal information that we determine we need for identified purposes below. We may collect relevant information, including your:

  • Name
  • Contact Information including telephone number, address, and email address
  • Identification Documents
  • Date of Birth
  • Donor Information
  • Event or Program Participant Information
  • Employee Information
  • Volunteer Information
  • Transaction Information
  • Communications including when you communicate with us or respond to communications from us via email, chat, audio or video calls, or physical documents
  • Device Information such as information about your operating system, browser, software applications, IP address, geolocation, security status and other similar device information to improve your experience, to protect against fraud, and manage risk
  • Website Use Information, such as browsing behaviour on TCSO’s website and links, as well as other data gathered from the use of web tools (for example, cookies) to better understand your interests and needs so that we can serve and support you better

We obtain personal information about you lawfully and fairly. We may collect personal information about you when you voluntarily provide it to us, from third parties, and/or from sources that are available to the public. You can choose not to provide us with certain information in some situations, but if you make this choice, we may not be able to address your needs. We collect, use and disclose personal information only for certain purposes that we identify to you. The purposes for which we collect the personal information are identified at the time we collect it.

We may use cameras or other recording devices in and around our premises, in online meetings, and other locations for business activities and the security of our people and property.

From time to time, TCSO may, acting reasonably, collect information about identifiable individuals from published or public sources for the purposes of developing relationships with individuals.

Identifying Purposes
With your consent, we collect information about you for various purposes, including to:

Establish and verify your identity.

  • Ensure we have accurate and up to date information about you
  • Process transactions, including processing donations and payments, redirecting a donation or any part of a donation to another charity as instructed by the donor, issuing tax receipts, confirming renewal of giving and maintaining a donation history
  • Administer your involvements with us, including your donations, event participation, certain networking and mentoring programs, community engagements, volunteering, or employment, and contact you about your continued involvement
  • Engage and manage prospective, current, and past donor relationships
  • Establish and maintain the volunteer relationship, including to assist volunteers in performing their volunteering roles and responsibilities and to keep them informed about relevant TCSO activities and the work of TCSO
  • With your consent, publicly recognize your financial or non-financial contributions
  • Generate statistics and aggregate reporting to help us and our partner organizations understand where we can have greater impact on the community
  • Meet legal and regulatory requirements and inquiries
  • Protect you and us against fraudulent actors, behaviours and transactions
  • Protect TCSO against other legal, regulatory, financial, or business risks
  • Use it as otherwise permitted by law.

Privacy Consent: We collect, use or disclose your personal information with your permission, except where otherwise required or permitted by law. Your permission may be expressed (orally, electronically or in writing) or may be implied (by an action or inaction).

Your Choices: During your relationship with us, we may communicate with you using the contact information you have provided, to inform you about TCSO issues, activities and opportunities that we think may be of interest and value to you.

Changing or Withdrawing Consent: You can manage or withdraw your privacy consent and communication preferences at any time to opt-out of some or all of these consents and communications by reaching out to us. To manage your privacy consent and communication preferences, you can reach us by phone, email, or postal mail. For communication preferences, you have the additional option to visit our website.

We will comply with your change or withdrawal, subject to legal, contractual or technical restrictions. For example, if you ask not to receive any mail from us, we take steps to suppress donation requests or general information, but we will still mail you a tax receipt for a donation or send you a statement of your outstanding payments against your pledged donation. Due to printing and distribution schedules, you may continue to receive some communications that were in process before we received your request. If there are various options to how we may handle your request, we will explain the options so that you can choose how you wish us to handle your request.

Limiting Collection
Personal information we collect will be limited to that required for the purposes identified by us.

Limiting Use, Disclosure and Retention
Use: We use your information for the purposes identified to you. When we intend to use your personal information for a purpose not identified to you when the information was collected, we will identify the new purpose and obtain your permission prior to use.

We do not sell your personal information.

Retention and Storage
We will keep your personal information only as long as it is necessary to satisfy the purposes for which it was obtained, or as required by law. We have guidelines and procedures for the retention and destruction of personal information. When we destroy personal information, we will use safeguards to prevent unauthorized parties from gaining access to that information during the process.

As your personal information is retained, we store the personal information that we collect electronically on premises at the TCSO offices, or at the offices of our third party service providers, as applicable. As such, your personal information may in some circumstances be stored in a jurisdiction outside of the one in which you reside, but we ensure that your personal information is protected in accordance with the data protection requirements of that jurisdiction.

Accuracy
We maintain appropriate procedures to ensure that personal information in our possession is as accurate and up to date as is necessary for the purposes for which it is to be used. We rely on you to provide us with any changes to your personal information, and in particular to your contact information. Failure to notify us of changes to your personal information may negatively impact the way we communicate with you, transact with you, and/or fulfil our legal and regulatory obligations.

If you believe any of the information which we have collected about you is incorrect or incomplete, you have the right to ask us to change it or delete it. If your personal information is inaccurate or incomplete, we will make the necessary changes. Where appropriate, we will transmit any material amendments to your personal information to our third-party

Safeguards
We keep your personal information in strict confidence. We maintain appropriate physical, technical and organizational safeguards to protect your personal information against loss, theft, unauthorized access, disclosure, copying, use or modification.

Access to your personal information is restricted to TCSO employees, agents and authorized service providers who need the information to fulfill the purpose for which the information was collected. TCSO will protect your personal information by safeguards that are appropriate to the sensitivity of that information and the format of the information, whether electronic or physical.

Our procedures include physical security measures, organizational measures including security clearances and limiting access on a “need-to-know” basis, and technological measures such as the use of passwords and encryption. When it comes to the handling of electronic records for payment purposes, TCSO adheres to Payment Card Industry Data Security Standards (PCI DSS).

You are also responsible for helping to protect the security of your personal information. For instance, safeguard any sensitive records you have in connection with TCSO, like donation information and transaction records.

Individual Access
You may ask whether we hold any personal information about you, how we collected your personal information, how we are using it, and which third parties have access to it. You may request to see copies of your information we collected and ensure that it is accurate. TCSO may ask that you submit your request in writing with sufficiently specific information to enable us to search for and provide you with personal information we hold about you. TCSO will need to confirm your identity prior to disclosing any information to you and may charge a reasonable fee to cover the cost of providing the information to you. If a fee is charged, TCSO will inform you of the approximate cost prior to providing the information to you.

TCSO seeks to respond to access requests in a reasonable amount of time, subject to the complexity, volume, and sensitivity of the request. We will inform you of the specifics to the best of our abilities, to the extent required by law.

Where we are able to fulfil your request, we will make the personal information or the information about your personal information available to you in a form that is generally understandable. If we are unable to provide any of the requested personal information, we will tell you why.

We will gladly share information about our privacy policies and procedures. If you have any questions or concerns, please contact Karen Soltau, (437) 913-9320.

You may also contact the Privacy Commissioner of Ontario, if you have concerns, by calling 416 326-3333 or for more information at www.ipc.on.ca.