The Lung Association – Ontario (TLA) is committed to protecting the privacy of the personal information of its employees, volunteers, members, clients and other stakeholders. We value the trust of those we deal with, and of the public. We acknowledge that maintaining this trust requires us to be transparent and accountable in how we treat the information you choose to share with us.
During the course of our various activities, we frequently gather and use personal information. This information may be obtained directly from you or collected from third parties that have the right to disclose this information to us.
Our policy regarding how personal information entrusted to us is collected, used, disclosed or retained reflects the principles set forth in the Personal Information Protection and Electronic Documents Act (Canada). View it here.
What is personal information?
Personal information is any information that contributes to the identification of an individual and includes details that can be used to distinguish, identify or contact a specific individual.
Business contact information and certain publicly available information, such as names, addresses and telephone numbers as published in telephone directories, are not considered personal information in this context.
Personal information collected by TLA
TLA collects personal information to support program delivery, to establish, maintain and manage our relationship with our clients, employees, donors, volunteers and members, and for research, fundraising, public education and advocacy purposes.
TLA collects personal information when an individual:
Personal information collected may include:
- Contact information such as home address, telephone number, e-mail address (when e-mail message was sent to TLA through the website, the time the message was sent and the IP address from which it was sent is automatically collected)
- Demographic information such as age and gender
- Lung health information (for program delivery and advice)
- Credit card or bank account information
- Language and communications preferences
- Service or event-specific information such as name and phone number of an emergency contact individual, dietary restrictions and accommodation preferences.
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Use of personal information
CLIENTS AND CUSTOMERS
Registering for a program or event: When a client or customer registers for a TLA program or event, or requests a publication or resource, they may be asked for personal information such as name, email address, mailing address, phone number emergency contact information, special dietary requirements and accommodation preferences.
We collect this information to facilitate participation in the event and to provide the programs or resources requested. We will use the emergency contact information only as required in the event of an emergency.
When an individual registers with TLA for lung health programs, or is referred by their health care professional, information about their lung health is collected.
This information is collected to identify the individual, recommend/deliver specific programs, provide advice on health care resources, or for research purposes.
With the individual’s permission, TLA may also send them information about other products or programs of interest. An individual may opt out of receiving such communications at any time by contacting us as set out in the “Contact us” section below.
EMPLOYEES AND VOLUNTEERS
Access by employee and volunteer to their personal information: Access to personal information is restricted to authorized employees who have a legitimate reason to access it. An employee or volunteer may access and verify his/her personal information subject to some exceptions, for example, the law requires that we refuse access to information that would reveal personal information about another individual. If access is refused, the reason for refusal will be provided.
Employees’ personal information: TLA uses personal information about employees in order to establish, manage and terminate the employment relationship. This includes:
- Personal information collected in the hiring process, including information on resumes and application forms (contact information, personal and professional history, qualifications, emergency contact information, results of criminal records checks, information collected from references)
- Payroll information including, social insurance number, rate of pay, hours of work, deductions, bank account information, any court orders
- Benefit information including premiums or contributions, coverage information, date of birth, marital status, dependent information, medical information
- Performance information including work history, performance reviews, discipline and related notes, documentation on job qualifications, internal competition information
- For other purposes identified when the information is collected.
Volunteers’ personal information: TLA uses personal information about volunteers for the purposes of recruiting volunteers, establishing and managing an effective volunteer program, and for other purposes identified when the information is collected. This includes:
- Personal information collected in the recruiting process including information on application forms (contact information, personal and professional history, qualifications) and information collected from references
- Information related to the volunteer’s services including availability, schedule, duties, and notes related to volunteer qualifications
DONORS AND OTHER STAKEHOLDERS
When a donation is made, TLA collects the donor’s name, address, and credit card or bank information for the purpose of processing the donation and issuing a tax receipt.
As a form of appreciation, and to remind others of the ongoing need for support, TLA may publicly recognize the donor’s name, unless the donor indicates their preference not to be recognized in any way. The donor’s name may be published in association with the range of the dollar amount of the donation.
Donations may also be made in honour or in memory of someone, or to sponsor a participant in one of our events. TLA collects personal information about the recipient of the donation, or the family of the recipient in the case of a donation in memory, such as their name, addresses and contact information. We collect this personal information in order to notify the recipient of the donation. We do not use or disclose the recipient’s personal information for any other purpose unless they give us permission to do so. The donor has the option to decide whether they would like to be identified as the sender of the donation. We do not publish the amount of any donation made in honour or in memory.
As the sponsor of a participant in one of our events, the donor has the option to decide whether or not the amount of the donation may be publicly available.
Opportunity to provide TLA financial support: TLA may occasionally provide its clients, employees, volunteers and others stakeholders with the opportunity to donate to TLA through our direct mail, telemarketing or other fundraising programs. We collect and keep only as much personal information about donors and prospective donors as we need in order to raise funds efficiently.
You may opt out of receiving donation opportunities by contacting us as set out in the “Contact us” section.
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Mailing lists and newsletters
If an individual signs up for a newsletter, TLA uses their email and/or home address, as applicable, to send the newsletter and other information requested. TLA provides regular communications to its clients, employees, donors, volunteers and other stakeholders through both regular postal mail and electronic mail. Any personally identifiable information provided by you will be used for the purpose of delivering the mailing item, research and/or marketing. An individual may opt out of receiving such communications at any time by contacting us as set out in the “Contact us” section below.
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The “help” portion of the toolbar on most browsers shows how to prevent the browser from accepting new cookies, how to have the browser notify when a new cookie is received, or how to disable cookies altogether.
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Disclosure of personal information
Research: From time to time TLA conducts research through surveys, interviews with clients or donations. In all cases clients and donors are informed that the information they are providing is being used for research purposes only and that all information will be kept confidential.
Employee and volunteer personal information: TLA may disclose personal information of an employee or volunteer to others solely in connection with the purpose for which the information was collected, as consented to by the individual, or as required or permitted by law.
If an employee or volunteer wishes to limit the sharing of their personal information as permitted by law, the individual may submit a request to the Privacy Officer specifying which items of personal information are to be limited and to whom these items are to be restricted. The Privacy Officer will advise the individual whether the requested information can be restricted as requested.
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Outside service providers
The term ‘outside service provider’ includes vendors, consultants and service delivery partners or agencies.
TLA may contract with outside service providers to perform certain services on its behalf. These organizations are given only the information necessary to perform those services, and we take steps to ensure that such information is securely transferred and stored and is used only for the purposes intended.
Service providers with whom we share personal information may perform activities in the United States or another country in which case personal information is subject to laws in the United States or that other country. For example, personal information may be shared in response to valid demands from government authorities, courts and law enforcement officials in the country where the data resides.
TLA agreements with service providers set out our expectations regarding privacy and protection of personal information; specifically, they require that the service provider:
- Maintain the confidentiality and security of personal information provided by TLA and use it only in compliance with applicable privacy laws.
- Prohibit access, use or disclosure of personal information for any purpose other than providing the services covered by the agreement.
- Report immediately to TLA any access, use or disclosure of personal information provided by TLA other than for the provision of the services covered by the agreement.
- Provide access controls and safeguards for the secure management, retention and destruction of personal information provided, as applicable.
TLA and our service providers may provide personal information in response to a legal requirement to do so, or in the case of a breach of agreement or infringement of law to a fact-finding entity, or as otherwise required or permitted by law.
Donors: From time to time TLA exchanges the names and addresses of its donors with other like-minded charities to further our fundraising efforts. As a matter of course, TLA routinely provides its donors the opportunity to decline the use of their name and address for such purposes. A donor can also opt out of the program by contacting us as set out in the “Contact us” section below.
Social Media / Forums: If you voluntarily submit or post any information, photographs or other content to any TLA forums, Twitter pages, Facebook pages or other social networking pages/sites, certain elements of your personal information may be automatically included in the posting, including your user name and email address, and this information may be collected and used by others. TLA has no control over and is not liable for the collection, use or disclosure of any posted user content by users of such forums and social media networking pages. Any personal information posted, used or disclosed via such sites is not subject to this Policy.
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TLA may disclose your personal information to a government institution that has asserted its lawful authority to obtain the information or where we have reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the disclosure of information, or to comply with court rules regarding the disclosure of records and information, or to protect the rights and property of TLA or otherwise as permitted or required by law.
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Security – Safeguarding personal information
TLA takes reasonable measures to ensure that our systems keep personal information safe from loss or theft, unauthorized access, use, copying, disclosure or modification. Safeguards include but not limited to:
- Designated IT Director accountable for information security controls and ongoing oversight
- Firewalls, intrusion-detection, anti-virus, strong passwords, and other software solutions for technical security
- Confidentiality sign-off by all employees
Retention and disposal of personal information: The length of time TLA keeps personal information varies depending on the service and the type of information. Personal information is kept for as long as it may be reasonably needed for service, research, legal or business purposes. When personal information is no longer required for these purposes, it is securely destroyed or deleted.
Access to and correction of personal information: Individuals have the right to access and correct inaccuracies in the personal information TLA has about them in our records. To do so, they should contact TLA as described in the “Contact us” section below. To protect individual privacy, TLA will take reasonable steps to help verify the individual’s identity before granting access or making corrections to personal information.
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Linking to outside websites
Links to third-party websites from TLA website are provided for the convenience of our users. TLA has no control over, and therefore has no responsibility or liability for, the manner in which the organizations that operate such linked websites may collect, use, disclose or otherwise treat your personal information.
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To review or update one’s personal information in TLA’s possession, or withdraw consent for the collection, use and/or disclosure of one’s personal information or name from an e-mail or other mail list, please contact us at:
The Lung Association – Ontario (TLA)
18 Wynford Dr., Suite 401
(416) 864-9911 | 1 – 888 – 344 – LUNG (5864) | firstname.lastname@example.org
Further information on privacy in general and on individual rights in regard to personal information is available on the website of the Privacy Commissioner of Canada at www.privcom.gc.ca.
UPDATED: September 26, 2017