InspireHealth is committed to protecting the privacy of donor personal information and adheres to legislated privacy requirements. Any personal information we collect is used primarily for donor-related and tax-receipting purposes. We may periodically contact donors to keep them informed about our activities and other mission-related communications which they support. We do not sell, trade or rent out any names or personal information.
If at any time a donor no longer wishes to be contacted by InspireHealth for fundraising purposes or has any questions regarding the privacy of their personal information, they can contact the Chief Privacy Officer of InspireHealth at Privacyofficer@inspirehealth.ca
InspireHealth is committed to ensuring that all personal information is collected used, disclosed and maintained in accordance with applicable law. To make certain that it meets this commitment, InspireHealth will follow the ten privacy principles that have been established by applicable law, as outlined below.
1. Accountability. InspireHealth is responsible for all personal information under its custody or control, including information which it may transfer to third parties for processing.
The Chief Privacy Officer is accountable for InspireHealth’s overall compliance with this policy and acts as the society’s arbitrator on information privacy and security matters. Individual managers also have a responsibility to oversee compliance with this policy for employees under their areas of responsibility.
In addition, each person who has an association with InspireHealth has an individual responsibility to ensure that personal information is protected at all times in accordance with this policy. Each individual receives information regarding the InspireHealth privacy policies and is expected to take personal responsibility for the following:
– being knowledgeable about and following current policies and related procedures;
– reporting to the Chief Privacy Officer possible problems with and improvements to information privacy and security procedures; and,
– helping to resolve problems and implement improvements.
– using contractual or other means to provide a comparable level of protection for information that has been transferred to a third party for processing;
– establishing procedures to receive and respond to inquiries or complaints;
– training staff about the privacy policies and practices;
– developing publicly available information to explain the privacy policies and practices.
2. Identifying Purposes for Data Collected.
Before, or at the time of collection, InspireHealth will identify the purposes for which personal information is collected, used, disclosed and retained. InspireHealth collects donor personal information only for the following purposes:
– to process donations;
– to manage our business, to protect our company assets;
– to administer the volunteer network;
– to keep our donors informed about the programs, services and activities of the society, including the use of their financial support; and
– to ask individuals and organizations for their support for our mission.
Individuals collecting personal information on behalf of the society will be able to identify the purposes for which the information is being collected. If personal information is to be used for a purpose not previously identified, InspireHealth will identify this purpose prior to use and provide individuals with an opportunity to opt-out of this activity.
The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except where applicable law authorizes the collection, use or disclosure without consent of the individual or consent can be implied.
In certain circumstances, the law permits personal information to be collected, used or disclosed without the knowledge and consent of the individual, such as in the investigation of a breach of an agreement or a contravention of a federal or provincial law. InspireHealth may also disclose personal information without knowledge or consent to comply with a subpoena, warrant or court order, or as may otherwise be required or permitted by law.
In obtaining consent, InspireHealth will make reasonable efforts to ensure that individuals are advised orally or in writing of the purposes for the collection, use and disclosure of personal information. In determining the appropriate form of consent, InspireHealth will take into account the sensitivity of the personal information and the reasonable expectations of an individual.
A donor may withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. If consent is withdrawn, InspireHealth will comply with the request within a reasonable time.
However, consent may not be withdrawn if it would frustrate the performance of any legal obligation, and in certain circumstances InspireHealth may not be able to provide or continue certain services or arrangements with the donor, as a consequence of such withdrawal of consent. Donors could contact InspireHealth for further detail on implications of any withdrawal of consent.
4. Limiting Collection of Information
The recording of personal information will be limited to that which is necessary to meet the intended purposes identified by InspireHealth Both the amount and type of information recorded will be limited to the minimum amount necessary. As much as possible, personal information will be collected directly from the individual. However the society may also record personal information from other sources in support of its mission.
5. Limiting use, disclosure and retention
Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by applicable law. Only InspireHealth employees, authorized agents or volunteers with a need to know for organizational purposes, or whose duties reasonably so require, are granted access to personal information about donors and prospective donors. InspireHealth does not sell, barter, rent out or lease its donor or prospective donor information.
InspireHealth will retain personal information only as long as necessary for the fulfillment of the purposes for which it was collected and for legal or business purposes. InspireHealth will maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction.
Information that is no longer necessary or relevant for the identified purposes will be destroyed, erased or made anonymous.
Personal information will be as accurate, complete and up-to-date as is necessary for the identified purposes for which it is to be used. Information will be sufficiently accurate, complete and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about an individual. InspireHealth will update personal information about its donors and prospective donors as and when necessary to fulfill the identified purposes or upon notification by the individual.
Individuals may request amendments to their personal information but InspireHealth may retain the original information for reference purposes only.
InspireHealth will protect personal information by security safeguards appropriate to the sensitivity of the information. InspireHealth will protect personal information disclosed to third parties for processing through contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.
All InspireHealth employees, agents or volunteers with access to personal information will be required to respect the confidentiality of that information by signing a confidentiality agreement, participating in privacy training and implementing methods of protection that include:
– physical measures, for example, locked filing cabinet and restricted access to offices;
– organizational measures, for example, limited access on a “need-to-know” basis;
– technological measures, for example, the use of passwords, encryption and audits.
InspireHealth will make available directly to individuals specific information about its policies and practices related to the management of personal information.
9. Individual access
Upon request InspireHealth will inform an individual of the existence, use and disclosure of his or her personal information and will give the individual access to that information. The individual will be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Personal information will be provided in an understandable form within a reasonable time.
While a person can make a request to see his/her own records and the society must comply, a person has no legal right to access other records or the personal information of other individuals and InspireHealth will not provide access to such records
In certain situations, InspireHealth may not be able to provide access to all the personal information it holds about an individual and exceptions to the access requirement will be limited and specific. These exceptions may include information containing certain references to other individuals, information that
cannot be disclosed for legal, security, or commercial proprietary reasons, and information subject to solicitor-client or litigation privilege.
In providing an account of third parties to which it has disclosed personal information about an individual, InspireHealth will attempt to be as specific as possible. When it is not possible to provide a list of the organizations to which it has actually disclosed information about an individual, InspireHealthwill provide a list of organizations to which it may have disclosed information about the individual.
InspireHealth will correct or amend any personal information if its accuracy and completeness is challenged and found to be deficient. Any unresolved differences as to accuracy or completeness will be noted in the individual’s file.
In order to safeguard personal information, an individual may be required to provide sufficient identification information to permit identity verification. Any such information received will be used only for this purpose.
10. Challenging Compliance
InspireHealth has the following procedure in place for addressing and responding to all inquiries or complaints from individuals about its handling of personal information.
An individual will be able to challenge compliance with this policy by contacting the Chief Privacy Officer. The Chief Privacy Officer will then conduct an internal inquiry as appropriate to ensure the issue is properly discussed, documented and addressed in a reasonable period of time. On conclusion of the inquiry, the Chief Privacy Officer will respond in writing to the complainant, and if a complaint is found to be justified, appropriate measures will be taken, including amending policies and procedures where required.
If a complainant is not satisfied with the outcome they may contact the office of the British Columbia Information and Privacy Commissioner at www.oipc.bc.ca for further information and assistance.
Any individual, including InspireHealth employees and volunteers, who fails to comply with this policy will be subject to disciplinary actions, up to and including termination of employment or volunteer relationship.
Last revised: December, 2016.