This policy outlines United Way Toronto’s (UWT) commitment to respecting the privacy of personal information of individual persons and explains how we collect, use, protect and disclose personal information. This includes the personal information of donors, prospective donors, board members, volunteers, individuals who engage with us on community initiatives, and our staff.
This policy governs the activities of UWT. UWT is an autonomous organization, legally separate from United Way of Canada and other United Ways. While all United Ways share a commitment and respect for personal information privacy, details on how each United Way does so can be obtained by contacting the United Ways individually.
Our Commitment to Protecting Your Privacy
UWT embraces the principles of the Canadian Standards Association Model Code for the Protection of Personal Information and will control the collection, use, and disclosure and disposal of personal information in keeping with those principles.
UWT recognizes that we rely on the support of hundreds of thousands of individuals who engage with us in support of their community. We recognize that information is precious, and our supporters trust us to treat their information with respect for their privacy and a commitment to protecting the confidentiality of data. It is essential that we protect the privacy of the personal information individuals may choose to share with us or that we may gather by other lawful means.
What is Personal Information?
Personal information refers to information about an identifiable individual, but excludes certain business contact information, specifically name, title, business address or telephone number of an employee of an organization. From time to time, UWT may, acting reasonably, collect information about identifiable individuals from published or public sources for the purposes of developing relationships with individuals.
The areas in which UWT collects and uses personal information in accordance with this policy are principally, but not limited to:
Community: UWT’s work to improve social conditions involves working with individuals acting on their own initiative or as representatives of community agencies, governments and other partner organizations that share common social objectives. UWT gathers and uses personal information to keep individuals informed about relevant UWT activities and work, and with permission may share personal information with others who share similar social objectives and a desire for networking. UWT also gathers and uses personal information to provide professional development programs in the sector and with permission, shares personal information with previously identified program partners or vendors for the purposes of conducting program activities.
Donations: UWT will collect and use personal information necessary to process donations and payments, redirect a donation or any part of a donation to another charity as instructed by the donor, issue tax receipts, confirm renewal of giving and maintain a donation history, keep donors informed about giving opportunities and the work of UWT, acknowledge and recognize donations, and comply with federal and provincial regulatory guidelines and reporting requirements.
Workplace Campaign Participation: UWT supports workplace organizations who wish to run internal employee giving campaigns. UWT may be provided with employee names, business contact information and other employee-related information in order to provide personalized campaign pledge tools, whether paper pledge forms or secure online links, to carry out a workplace campaign. UWT will work with organizations delivering workplace campaigns to determine data needs that ensure an optimal experience for employees and which also meets the organization’s personal data management policies. The data provided to UWT is used only for the purposes of setting up the pledge tools. If the employee chooses to make a donation, UWT will retain personal information provided directly by the donor and any associated workplace employment information required to manage the donation. If the employee chooses not to make a donation or request further information, UWT does not retain any information provided by the workplace. In some situations, the workplaces run campaigns that reach beyond employees to include other related individuals such as retirees or contractors. UWT follows the same practices in working with organizations in these situations as with employees.
Volunteering: UWT will collect and use personal information to establish and maintain the volunteer relationship, assist volunteers in performing their volunteering roles and responsibilities, and keep them informed about relevant UWT activities and the work of UWT.
Event Participation: UWT will collect and use personal information necessary to communicate with individuals about events, contests and promotions that they participate in, issues concerning related transactions, information about other events that they may be interested in and the work of UWT; to recognize participation and award prizes; and to comply with federal and provincial regulatory guidelines and reporting requirements.
UWT Employees: UWT collects and uses personal information to establish, maintain, administer and terminate the employment relationship including ongoing obligations regarding benefits, medical history and pension.
Our Privacy Principles
The following principles reflect our pledge to protect the privacy of your personal information:
We are responsible for all personal information in our possession, including any personal information transferred to third parties for handling or administrative purposes.
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 UWT that confirm they have privacy and security standards comparable to our own.
We collect, use and disclose personal information only for certain purposes that we identify to you. The purposes for which personal information is collected will be identified at the time the information is collected.
With your consent, we collect information about you for various purposes, including the following:
- Establish your identity.
- Administer your involvements with us, including your donations, event participation, community engagements, volunteering, or employment, and contact you about your continued involvement.
- Know who our donors, volunteers and other supporters are in order to manage and develop our resources to fulfill our mission to serve the greater good of the community.
- Respond to your information requests.
- Periodically, as we are able, send you literature on United Way or invite you to events or information sessions that are aligned with your interests
- Thank you and, with your consent, publicly recognize your financial or non-financial contributions.
- Share information with other individuals or organizations only with your consent, including organizations which you redirect donations to, volunteer at on our behalf, or interact with on our behalf.
- 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.
We obtain personal information about you lawfully and fairly. 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). For example, if you designate a portion of your gift to another charity, your pledge form provides you an opportunity to instruct us to withhold your personal information from your designated recipient charity. If you direct us to withhold the information, we will pass on the funds to the other charity anonymously. If you take no action, we will identify you when we pass on the funds to the other charity.
You may withdraw your permission to the use and disclosure of your personal information at any time. We will comply, subject to legal, contractual or technical restrictions. For example, if you ask to not 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.
Personal information collected will be limited to that required for the purposes identified by us.
Limiting Use, Disclosure and Retention
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.
We disclose your personal information in the following circumstances:
- In the case of donors giving through direct mail, UWT may exchange name and mailing address information of direct mail donors with compatible organizations, only after you have had an opportunity to decline. This permission is rechecked regularly, and donors can opt out at any time.
- In the case of donors giving through their workplace, your workplace has access to certain personal information in the execution of the Employee Campaign. UWT is respectful of the donor's right to privacy and works with the individuals responsible for the Employee Campaign to limit with whom we share the information, and to only share information necessary for the purposes of the campaign. For example, if you make a donation by payroll deduction, we may provide the information necessary to correctly identify you on your payroll system and the amount of your donation to deduct from your pay. Furthermore, employers may have internal policies on their access and use of employee personal information; United Way respects and works within the requirements of your organization’s policies.
- We share information with other United Ways if we administer a donation belonging to another United Way community. We disclose your information only to the specific United Way involved in your donation.
- If you designate your donation to another charity, we provide your name, workplace if the donation is part of an Employee Campaign, and designation amount to the selected charity for identification purposes. When you make your designation, you have the opportunity to direct us to withhold your information and send the donation on an anonymous basis.
- We may contract with carefully selected third parties to perform services for us or on our behalf. When we select the third parties, we ensure that they use security and privacy standards comparable to our own.
- In all other situations, we will disclose your personal information only with your consent, or as otherwise required or permitted by law.
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.
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.
If you believe any of the information 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.
We maintain appropriate 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 UWT employees, agents and authorized service providers who need the information to fulfill the purpose for which the information was collected. UWT 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, UWT adheres to Payment Card Industry Data Security Standards (PCI DSS).
You may ask whether we hold any personal information about you, see your information and ensure that it is accurate. UWT may ask that you submit your request in writing. UWT 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, UWT will inform you of the approximate cost prior to providing the information to you.
You also have the right to know how we collected your personal information and how we are using it. We will inform you of the specifics to the best of our abilities.
If you have any privacy concerns, you may contact any of our employees that you normally interact with to discuss your concerns or requests. If you are unsure of whom to contact or have further concerns, you may contact the office of our Privacy Officer by email to firstname.lastname@example.org.
You may register a privacy-related complaint by emailing UWT’s Privacy Officer. We will investigate all complaints. If an objection is justified, we will take all appropriate steps to repair the situation, including changing our policies and practices if necessary.
A note about our websites:
We collect two basic types of information on our websites, personally identifiable information which you submit and information about your interaction with our websites using digital markers such as cookies and web beacons. We collect personally identifiable information when you provide it to us by participating in certain activities that require response, registration or donations.
When you visit our websites, we also automatically log information about your visit. The information collected about your visit includes, but is not limited to:
- The current Internet protocol (IP) address and the type of computer operating system you are using (e.g. Microsoft Windows or Mac OS)
- The type of browser you are using (e.g. Firefox or Internet Explorer)
- The referring website that brought you to the UWT website
- Your UDID (for mobile devices)
- The domain name of your Internet Service Provider
- Your activities while visiting the Website (e.g. which of our Web pages you viewed)
UWT may use third parties services, such as Google Analytics to process this information.
UWT and its service providers use this information to analyze the performance and effectiveness of our website, for technical reasons to facilitate navigation through our website and to present personalized content. For example, in order to navigate through our online campaign tool, our Web server must recognize you in order to ensure that your donation is correctly applied and that you are able to navigate securely through the pages related to the campaign.
You may adjust your browser settings to reject digital markers, including cookies, if you so choose. Visiting our website with cookies disabled will have no significant impact on your ability to view our websites. However, session cookies must be enabled to use UnitedWay@work, our online campaign tool used to support workplace campaigns.
UWT also uses technical methods for tracking purposes, including clear gifs (also known as web beacons) in HTML emails that we send to determine whether you have opened those emails and/or clicked on links in those emails. UWT uses this information to analyze the performance and effectiveness of our emails.
You may be able to disable Web beacons in email messages by not downloading images contained in the message you receive (this feature varies depending on the email software you use).
Event registrants and donors on our websites including UnitedWay@work, our online campaign tool used to support workplace campaigns, are linked to secure servers. UWT uses a secure payment service for credit card transactions.
For more information, please contact United Way Toronto’s Privacy Officer at 416-777-2001 or by email at email@example.com.