Staff Responsible: Chief Privacy Officer
Oversight by: Finance Audit and Technology Committee
Approval by: Board of Directors
UWCA is committed to maintaining the confidentiality, security, and accuracy of the Personal Information of the United Way’s Personnel and other third parties that is in its possession as a result of its normal business, including with respect to volunteer and charitable operations.
UWCA collects, uses and discloses Personal Information about its Personnel, donors, customers, suppliers and others with whom it has contact in the course of conducting its normal business operations, including for purposes of establishing, managing, or terminating employment and contractual relationships between Personnel and UWCA. This Policy describes and governs the collection, use, and disclosure of Personal Information by UWCA.
This Policy applies to UWCA, and to all Representatives. When a Representative, donor, customer, or supplier provides UWCA with Personal Information, that individual consents to UWCA’s collection, use and possible disclosure of their Personal Information for the designated purpose and agrees to the terms for accessing and correcting data as described below.
The Policy governs UWCA’s activities that are subject to the provisions of applicable privacy legislation, including the Personal Information Protection Act (Alberta). However, as a not-for-profit organization, please note that certain of UWCA’s activities may not be subject to applicable privacy legislation in all instances.
Information, recorded in any form, about an identifiable individual (including, (i) for employees: a home address and phone number, names of partners and spouses, a social insurance number, performance appraisals, medical and benefit information, or hobbies and interests, and (ii) for donors: any donation and billing information).
This does not include the name, title, business address or telephone/facsimile number or business email address of an employee of an organization, when used for business communications. Also, it does not include anonymous, aggregated or non-personal information or statistical data (i.e., information that cannot be associated with or tracked back to a specific individual).
A director, officer, employee, volunteer or independent contractor of UWCA.
An employee or prospective employee of UWCA, as well as any other individuals, including third parties that may provide and have access to Personal Information in UWCA’s possession.
United Way of Calgary and Area and its divisions and affiliates, including any and all internal governance bodies.
Collection, Use and Disclosure of Personal Information
I. Personal Information
II. Collection Rationale
III. Use Or Disclosure Of Personal Information
IV. Protection Of Personal Information
UWCA collects and maintains different types of Personal Information about individuals with whom it interacts (such as those who seek to be, are, or were employed by UWCA, or volunteers, donors, customers or suppliers of UWCA), including:
As a general rule, UWCA collects Personal Information directly from the individual it pertains to. If third parties hold information UWCA requires, UWCA will endeavour to ensure the information has been collected with the appropriate consent.
Where permitted or required by applicable law or regulatory requirements, UWCA may collect Personal Information about an individual without their knowledge or consent.
UWCA collects Personal Information to manage and develop its business and operations, and to support its volunteer and charitable activities, including:
UWCA may use and disclose Personal Information provided it is reasonably required in the following circumstances:
UWCA may use or disclose Personal Information without an individual’s knowledge or consent where it is permitted or required by applicable law or regulatory requirements to do so, including, but not limited to, circumstances relating to the establishment, maintenance or termination of an employment relationship.
UWCA does not sell employee, volunteer, donor or customer information to third parties.
UWCA endeavours to maintain physical, technological, and procedural safeguards that are appropriate to the sensitivity of the Personal Information in question. These safeguards are designed to prevent Personal Information from loss and unauthorized access, copying, use, modification or disclosure. Examples of these safeguards include: password, encryption, and other electronic security means; locked or limited access premises and file cabinets; and the security monitoring methods.
Retention of Personal Information
Except as otherwise permitted or required by applicable law or regulatory requirements, UWCA endeavours to retain Personal Information only for as long as it believes is necessary to fulfill the purposes for which the Personal Information was collected (including, for the purpose of meeting any legal, accounting, or other reporting requirements or obligations). UWCA may, instead of destroying or erasing Personal Information and where this is economically feasible, make it anonymous such that it cannot be associated with or tracked back to a specific individual.
Updating Personal Information
It is important that Personal Information contained in UWCA’s records is both accurate and current. UWCA asks that Personnel, donors, customers and suppliers keep it informed of changes to Personal Information during the course of the individual’s employment, charitable or business relationship with UWCA.
If an individual believes the Personal Information about them held by UWCA is not correct, the individual may request an update of that information by making a request to our Privacy Officer using the contact information set out below.
Accessing Personal Information
An individual may ask to see the Personal Information that UWCA holds about them. If individuals want to review, verify, or correct their Personal Information, they may contact our Privacy Officer at the coordinates set out below. Please note that any such communications must be in writing (whether by traditional or electronic means).
When making an access request, UWCA may require specific information from an individual to confirm their identity and right to access, as well as to search for, and provide that individual with, the Personal Information that it holds about them. UWCA may charge a fee to access Personal Information; but it will advise of any fee in advance. If help is needed in preparing a request, please contact the office of our Privacy Officer. Where Personal Information will be disclosed to an individual, UWCA will endeavour to provide the information in question within a reasonable time, and in most cases, no later than 30 days following the request.
An individual’s right to access the Personal Information that it holds about them is not absolute. There are instances where applicable law or regulatory requirements permit or require UWCA to refuse a Personal Information access request. UWCA also reserves the right to decline to provide access to Personal Information where the information requested:
In addition, the Personal Information may no longer exist, may have been destroyed, erased or made anonymous in accordance with UWCA’s record retention obligations and practices.
In the event that UWCA cannot provide an individual with access to their Personal Information, it will endeavor to inform that individual of the reasons why access has been denied, subject to any legal or regulatory restrictions.
Out of Country Storage and Processing of Personal Information
UWCA has and will invest in new data management systems and software solutions on a routine basis, in order to work with or provide its services to its Personnel, Representatives, donors, customers, suppliers and others. As data processing technologies continually evolve, more systems and software solutions utilize “cloud-based” delivery models, where data processing and storage functionality is delivered from outside UWCA’s premises and through the internet or similar connections to the service provider, and where UWCA does not host the system or software solution within its physical premises. Accordingly, while UWCA maintains its responsibility for the protection of this data and of the Personal Information contained within it, Personal Information collection, use, disclosure, processing and storage may actually occur outside of Canada.
It is important to UWCA that it collects, uses or discloses Personal Information with consent to do so or as otherwise provided in this Policy. Depending on the sensitivity of the Personal Information, consent may be implied, deemed (using an opt-out mechanism) or express. Express consent can be given orally, electronically or in writing. Implied consent is consent that can reasonably be inferred from an individual’s action or inaction. For example, when financial information is requested for donation purposes, UWCA will assume consent to the collection, use, or disclosure of Personal Information for purposes related to that request for information or for other purposes identified by the requesting individual at the time.
Typically, UWCA will seek consent at the time that it collects the Personal Information. In some circumstances consent may be obtained after collection but prior to UWCA’s use or disclosure of Personal Information. If UWCA plans to use or disclose Personal Information for a purpose not previously identified (either in this Policy or separately), it will endeavour to advise an affected individual of that purpose before such use or disclosure.
UWCA may collect, use or disclose Personal Information without an individual’s knowledge or consent where it is permitted or required to do so by applicable law or regulatory requirements.
UWCA assumes that, unless it is advised otherwise, by receiving a copy of this Policy or by continuing to engage in business with UWCA, an individual will have consented to the collection, use and disclosure of their Personal Information as explained in this Policy.
An individual is entitled to change or withdraw their consent at any time, subject to legal or contractual restrictions (and reasonable notice), by contacting our Privacy Officer using the contact information set out below. In some circumstances, a change in, or withdrawal of, consent may limit UWCA’s ability to provide products or services to, or acquire products or services from, that individual.
The work output of Personnel, whether in paper record, computer files, or in any other storage format belongs to UWCA, and that work output, whether it is stored electronically, on paper or in any other format, and the tools used to generate that work product, are always subject to review and monitoring by UWCA.
In the course of conducting UWCA’s business, UWCA may monitor Representative activities and its property. Pursuant to the Ownership of Computer Data, E-mail and Internet Use and Social Media policies, UWCA has the capability to monitor all Personnel’s computer and e-mail use.
Representatives should not have any expectation of privacy with respect to their use of UWCA’s equipment or resources. This section is not meant to suggest that all Representatives will be monitored or their actions subject to constant surveillance – as UWCA has no duty to monitor – it is meant to bring to each Representative’s attention the fact that such monitoring may occur and may result in the collection of Personal Information (e.g. through their use of UWCA’s electronic resources).
Any collection of Personal Information held or used in the course of monitoring will not be more than is necessary for the purpose of the monitoring. Monitoring is or will be done on an “as required” basis and will be in proportion to the risks that UWCA faces. UWCA will conduct any monitoring in the least intrusive way possible. In some instances, when reasonably necessary, UWCA may supplement this monitoring notice with more specific policies or statements as appropriate.
Any violation of this Policy will result in action by UWCA. If any Representative misuses the Personal Information of another Representative, donor, or customer of UWCA, it will be considered a serious offence for which appropriate disciplinary action may be taken, up to and including termination of employment. If any individual or organization misuses the Personal Information of a Representative – provided for the purpose of providing services to UWCA – it will be considered a serious issue for which appropriate action may be taken, up to and including termination of the service agreement or court action.
Any interpretation associated with this Policy will be made by the Privacy Officer. This Policy includes examples but is not intended to be restricted in its application to such examples, therefore where the word ‘including’ is used, it shall mean ‘including without limitation’.
UWCA will review and revise this Policy from time to time to reflect changes in legal or regulatory obligations or changes in the manner in which it deals with Personal Information, and in any event, at least every 12 months. Any revised version of this Policy will be posted, and each Representative is encouraged to refer back to it on a regular basis. Any changes to this Policy will be effective from the time they are posted, provided that any change that relates to why UWCA collects, uses or discloses Personal Information will not apply to a particular Representative, where their consent is required to such collection, use, or disclosure, until UWCA has obtained that Representative’s consent to such change.
This Policy does not create or confer upon any individual any rights, or impose upon UWCA any rights or obligations outside of, or in addition to, any rights or obligations imposed by applicable privacy legislation. Should there be, in a specific case, any inconsistency between this Policy and relevant legislation, this Policy shall be interpreted, in respect of that case, to give effect to, and comply with, such privacy legislation.
This policy is one of a series of related policies addressing the collection, use, disclosure, and security of Personal Information by UWCA, including:
as defined in UWCA’s Employee Handbook.
This Policy shall have effect from October 1, 2013
Frequency: 12 months
Date of last Committee review: September 2019
Date of last amendment: October 2020
Date of last Board approval: December 5, 2020
If an individual has a question about (a) access to Personal Information, (b) the collection, use, management or disclosure of Personal Information, (c) changing or withdrawing consent with respect to Personal Information, or (d) obtaining more information about this Policy or relevant legislation, please contact the office of our Privacy Officer by telephone or in writing or by e-mail at:
105 12 Ave SE #600, Calgary, Alberta
Attention: Privacy Officer
tel: (403) 231-6265
United Way endeavours to answer all questions raised in a timely manner, and advise in writing of any steps taken to address an issue brought forward. If an individual is not satisfied with United Way’s response, they may be entitled to make a written submission to the privacy authority applicable for their jurisdiction.
By using this Site, you represent and warrant that you are the legal age of majority under applicable law to form a binding contract with United Way.
United Way of Calgary and Area (“United Way” or “us” or “we”) grants you a limited non-exclusive, non-transferable license to access and make personal use of the Site for non-commercial use, provided the Site is not modified or downloaded (other than page caching) unless expressly authorized by United Way. You will be fully responsible for any consequences resulting from any such use. This license does not include any right for resale or commercial use of the Site or its content. No derivative use of the Site or its contents or any use of data mining, robots, or similar data-gathering and extraction tools is permitted. Any unauthorized use of the Site will terminate the license and all the limited rights or permission granted by United Way.
2. Privacy and Security
The security of your personal information is very important to us. We use physical, electronic and administrative measures designed to secure your personal information from accidental loss and from unauthorized disclosure. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to the Site. Any transmission of personal information is at your own risk. United Way is not responsible for circumvention of any privacy settings or security measures contained on the Site.
You are prohibited from attempting to circumvent and from violating the security of the Site, including, without limitation: (a) accessing content and data that is not intended for you; (b) attempting to breach or breaching the security and/or authentication measures which are not authorized; (c) restricting, disrupting or disabling service to users, hosts, servers or networks; (d) illicitly reproducing the TCP/IP packet header; (e) disrupting network services and otherwise disrupting United Way’s ability to monitor the Site; (f) using any robot, spider or other automatic device, process or means to access the Site for any purpose, including monitoring or copying any of the material on the Site; (g) introducing any viruses, trojan horses, worm, logic bombs or other material that is malicious or technologically harmful; (h) attacking the Site via a denial-of-service attack, distributed denial-of-service attack, flooding, mailbombing or crashing; and (i) otherwise attempting to interfere with the proper working of the Site.
4. Copyright and intellectual property rights
United Way owns the intellectual property rights, including copyright, or has acquired the necessary licenses, in all information, software, code, text, graphics, images, HTML code, multimedia clips, icons, the selection and compilation of the contents of the Site (collectively the “Contents”).
The Contents on this Site and its compilation is protected by Canadian and international copyright, and trademark laws. Unauthorized use of the Contents may violate copyright, trademark, and other laws. You may make individual copies of the Contents on this Site for non-commercial, personal or educational use only. Repackaging, redistributing or modifying the Contents provided by this Site, in whole or in part, in printed or electronic format, is strictly prohibited.
The United Way name, the United Way trademarks and logos, and all related names, logos, product and service names, designs, images and slogans are trademarks of United Way or its affiliates or licensors. You must not use such marks without the prior written permission of United Way. Other names, logos, product and service names, designs, images and slogans which appear on the Site are the trademarks of their respective owners. Use of any such property, except as expressly authorized, shall constitute an infringement or violation of the rights of the property owner and may be a violation of federal or other laws and could subject the infringer to legal action.
5. Participation in online discussion groups, comments & other communications
You may post or submit comments, suggestions, ideas, questions, or other information to United Way, provided the content is not illegal, obscene, defamatory, threatening, an invasion of privacy, objectionable or infringing of intellectual property rights of third parties, and does not consist of or contain software viruses, commercial solicitation or any form of “spam”. You must not use a false e-mail address, impersonate any person or entity, or otherwise mislead as to the origin of such content.
6. Limitation of liability, disclaimer of warranties and conditions
The Content on the Site is provided for general information purposes only. It is not intended to amount to advice on which you should rely. You must obtain more specific or professional advice before taking, or refraining from taking, any action on the basis of the Contents of the Site.
You understand and agree that your use of the Site, its Contents and any services of items found or attained through the Site is at your own risk. The Contents, products and services are provided in good faith on an “as is” and “as available” basis. Although we make reasonable efforts to update the information on the Site, we make no representation, warranties or guarantees, whether express or implied, with respect to the completeness, security, reliability, suitability, accuracy, currency or availability of the Site or its Contents. United Way disclaims all warranties or conditions, express or implied, in respect of the Contents, products and services on the Site, including without limitation, implied warranties and conditions of merchantability and fitness for any particular purpose or non-infringement.
This disclaimer applies to the fullest possible extent in jurisdictions that limit the exclusion of implied warranties. Your use of the Site is at your own risk and United Way has no responsibility or liability whatsoever for your use of the Site.
United Way uses reasonable efforts to ensure that the Site is secure and generally available. However, there will be occasions when access to the Site will be interrupted or unavailable, and transmission of any information over the internet may not always be secure.
United Way will use reasonable efforts to secure information and minimize any disruption where it is within its reasonable control. However, United Way makes no representations or warranties that the Site, its Content or any services or items found or attained through the Site will be accurate, reliable, error-free or uninterrupted, that defects will be corrected, or that the Site or the server that makes it available are free or viruses or other harmful components.
Except where such exclusions are prohibited by law, under no circumstances will United Way nor its affiliates or their respective directors, officers, employees, agents, service providers, contractors, licensors, licensees, suppliers or successors be liable for negligence, gross negligence, negligent misrepresentation, fundamental breach, damages of any kind, under any legal theory, including any direct, indirect, special, incidental, consequential or punitive damages, including, but not limited to, personal injury, pain and suffering, emotional distress, loss of revenue, loss of profits, loss of business or anticipated savings, loss of use, loss of goodwill, loss of data, and whether caused by tort (including negligence), breach of contract, breach of privacy or otherwise, even if the party was allegedly advised or had reason to know, arising out of or in connection with your use, or inability to use, or reliance on, the Site, any linked websites or such other third-party websites, nor any Contents, Materials, posting or other information thereon even if the party was allegedly advised or had reason to know.
You are granted a limited, revocable, and nonexclusive right to create a hyperlink to the Site, so long as the link does not portray United Way, its officials, its employees, or its Content, products or services in a false, misleading, derogatory, or otherwise offensive matter. You may not use any logo or other proprietary graphic or trademark as part of the link without express written permission.
9. Site policies, modification and severability
11. Geographic Restrictions
The owner of the Site is located in Alberta, Canada. United Way provides this Site for use only by persons located in Canada. This Site is not intended for use in any jurisdiction where its use is not permitted. If you access the Site from outside Canada, you do so at your own risk and you are responsible for compliance with local laws of your jurisdiction.
12. Governing law and jurisdiction
The use of the Site and any purchase made on this Site are governed by the laws in force in the Province of Alberta and Canada. You agree and submit to the exclusive personal jurisdiction and venue of the courts located in Calgary, Alberta. The United Nations Convention on Contracts for the International Sale of Goods will not apply.
13. Description of donation and other tools terms
14. Request for permission or further information
16. Entire Agreement
Contact us – United Way Privacy Officer: firstname.lastname@example.org
Last updated: June 1, 2021