1. FCSS Privacy Notice and its application
Client(s) means an individual(s) who a) is a FCSS Donor; b) has requested or used FCSS services; c) has given his or her information for assessment of needs; or c) registered for FCSS training and who is not acting in their capacity as FCSS 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. FCSS, also referred to as we or us, means Four Chambers Safety Specialists Inc. 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 FCSS or has indicated to the FCSS or to its agents an intention to make a donation to the FCSS. Personal Informationâ 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
3. FCSS Accountability and Safeguards
The FCSS 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.
4. How Personal Information is used by the FCSS
The FCSS 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;
- AED Donations and related safety products;
- 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 FCSS;
- other purposes consistent with the above.
How the FCSS uses Donor Personal Information
The Personal Information of FCSS 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 FCSS via our website is not shared with other organizations. However, if a person who initially donates to the FCSS electronically later responds to a FCSS 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 FCSS. 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 FCSS 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 FCSS only receives the donation itself. Donations made Directly to a FCSS Office: People making donations at a FCSS 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 FCSS. The FCSS will honour any requests from the Donor for information to not be shared or to not receive further communication from the FCSS. If the Donor does not give such indication on the donation form, the Donors Personal Information may be included in lists traded with other reputable organizations.
5. Personal Information on the FCSS Website
When an individual chooses to become of Donor or a Client of the FCSS, 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 FCSS. A Client or Donor may decline to give the FCSS his or her Personal Information but, in some circumstances, this decision may hinder the FCSS ability to provide services to the Client or process the donation of the Donor.
7. Limiting Collection, Use, Disclosure, and Retention
Limitations on Collection and Use: The FCSS 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 FCSS collects Personal Information may contact us for more information at the Privacy Contacts listed in Section 9 of this Privacy Notice. Disclosure: FCSS does not disclose the Personal Information of its Donors or Clients without the Donor or Client’s 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 FCSS 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 FCSS is obliged or permitted to disclose information without consent, we will not disclose more information than is minimally required in the applicable circumstances. Retention: FCSS 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, FCSS will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. FCSS 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.
8. Accuracy and Individual Access
The FCSS 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 FCSS. 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:
The identity of the person requesting access can not be confirmed.
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;
The requested Personal Information does not exist, is not held, or cannot be found;
Disclosure of the Personal Information would compromise the confidentiality of another individual or threaten the safety of another person.
Non-disclosure of the Personal Information is required or permitted by law.
Requests to Change or Delete Information: An individual may request that the FCSS change or delete Personal Information about themselves that is in the possession of the FCSS. 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.
9. FCSS 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 FCSS; or (iii) this Privacy Notice, email firstname.lastname@example.org