Purpose
This Privacy Policy (“this Policy”) has been prepared to ensure Kingston 4 Paws Service Dogs (K4Paws) compliance with the Personal Information Protection and Electronic Documents Act, 2000 (“the Act”), and the Canadian Standards Association Model Code for the protection of personal information, which it incorporates. This Policy affirms K4Paws’ commitment to treating personal information responsibly and to protecting the privacy of our clients, donors, volunteers and other stakeholders. It informs readers of our practices concerning the collection, use, and disclosure of Personal Information collected by K4Paws.
1. Your Privacy Rights
The Act gives you rights concerning the privacy of your personal information. K4Paws is responsible for the personal information we collect and hold. To ensure this accountability, we have developed this policy and trained our employees, contractors, volunteers and representatives about our policies and practices.
Personal information is any information that identifies you, or by which your identity could be deduced. It includes any factual or subjective information, recorded or not, about an identifiable individual, be they a client, donor, volunteer, contractor, staff member, or other individual with whom we are engaged. This includes information in any form, such as a personal email address, credit card numbers, home address, photograph, medical information, family status, birth date. Besides facts about or related to the individual, it may include comments or observations about a service dog or service dog in training associated with them. Personal information does not include business information such as the name, title, business address, or telephone number of an employee of an organization or any publicly available personal information.
2. Purposes for Collection of Personal Information
K4Paws is committed to empowering individuals through the use of specially trained service dogs. To meet this goal, we may collect, use, and disclose personal information to serve our clients or potential clients and to communicate with clients, volunteers, donors, potential donors or other audiences involved in our services. Either before or at the time of collection, we will identify the purpose for which we are collecting the personal information.
The organization may collect your personal information for the following primary purposes, but are not limited to:
(a) Assess applications for a service dog or canine assisted intervention (CAI) dog;
(b) Evaluate applications for volunteering;
(c) Maintain contact with our service dog /CAI dog recipients to monitor the working team;
(d) Evaluate ongoing client needs and to ensure the ongoing welfare of the placed service dog/CAI dog;
(e) Maintain contact with volunteers;
(f) Maintain contact with individuals/families that adopt dogs;
(g) Maintain contact with our service dogs in training to monitor their progress;
(h) Solicit donations and issue donation receipts;
(i) Evaluate donor needs and interests;
(j) Communicate in an ongoing manner with clients, volunteers, donors, and other stakeholders;
(k) Issue newsletters and event notifications;
(l) Evaluate the performance of our services;
(m) Report to regulatory authorities if required to do so.
And, with additional consent to:
(n) Add information to our website, social media, newsletters, displays, presentations and other communications vehicles; and
(o) Provide stories to the media, in grant applications and for other public relations work.
Our organization honours donors’ requests to remain anonymous or having the amount of the donor’s contribution publicly disclosed.
3. Limited Collection
We collect and use your personal information in order to provide you with K4Paws services. Our organization restricts the collection of personal information only to that information that is necessary for the purposes noted above. We are committed to collecting personal information in a fair, open and lawful manner. Wherever possible, we collect your personal information directly from you and in the course of our representation.
You directly provide K4Paws with most of the data we collect by:
(a) Voluntarily submitting an application;
(b) Requesting reference letters and forms be sent directly to us;
(c) Making a donation;
(d) Signing up to receive our newsletter;
(e) Signing up for an event;
(f) Using or viewing our website;
(g) Granting K4Paws consent to gather necessary information from third parties.
In most cases, we shall ask you to specifically consent if we collect, use, or disclose your personal information. Sometimes, your consent may be implied through your conduct with us.
Your provision of personal information to K4Paws means that you agree and consent that we may collect, use, and disclose your personal information in accordance with this Privacy Policy.
If you do not agree with these terms, you are requested not to provide any personal information to K4Paws. Unfortunately, certain services can only be offered if you provide personal information to K4Paws. Consequently, if you choose not to provide us with any required personal information, K4Paws may not be able to offer you those services.
4. Limited Use
We use your personal information to provide our services to you and for the purposes stated in this Privacy Policy.
K4Paws does not disclose your personal information to any third party to enable them to market their products and services.
Our organization stores and maintains personal information in conformity with the requirements of the Act.
5. Disclosure of Your Personal Information
K4Paws may disclose your personal information under certain circumstances, such as:
(a) When we are required or authorized by law to do so;
(b) When you have consented to the disclosure. Express written consent will be obtained if the personal information is sensitive (financial or health information);
(c) When the services we are providing to you require us to give your information to third parties;
(d) When it is necessary to establish or collect fees;
(e) If we engage expert witnesses on your behalf; or
(f) If the information is already publicly known.
K4Paws will collect specific permissions on release forms for general-use items, such as photos, stories, and testimonials for external communication materials. For some events, notice of photographs being taken will be provided and an option for attendees to notify the privacy officer or designated individual if they do not wish to have their photos used in public communications materials, such as social media, website, and e-newsletters.
6. Limited Retention
K4Paws keeps personal information in a secure manner for as long as it is required for the reasons it was collected, or as required by law. The length of time we retain information varies, depending on the service and the nature of the information. This period may extend beyond the end of a person's relationship with us, but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. When your personal information is no longer required for K4Paws' purposes, the information will be destroyed, deleted, erased, or converted into an anonymous form.
We retain a limited amount of information for historical reference in servicing our clients, donors and other stakeholders.
Donation and financial information are kept for seven (7) years and then destroyed. To recognize the total giving history of donors, we keep all historic donation records electronically. However, some files may be deleted if they are more than seven (7) years old and there is no ongoing relationship.
7. Safeguards
Our organization has developed and implemented security safeguards appropriate to the sensitivity of the personal information kept by us. We take appropriate precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification, copying, or disclosure. Among the steps taken to protect your information are:
(a) Restricted file access to personal information;
(b) Deploying technological safeguards like security software and firewalls to prevent hacking or unauthorized computer access;
(c) Internal password and security policies; and
(d) K4Paws does not collect, retain, or store credit card information. We use third party services that are PCI compliant to process donations or payments via credit or debit cards.
Staff, contractors, and volunteers, will be required to sign a statement prior to taking part with us, stating they will abide by our Privacy Policy, both while they are in their role and thereafter.
We ensure that all of our employees, contractors, volunteers, or agents who deal with personal information are trained and are aware of the necessary and appropriate measures required to protect personal information.
8. Accuracy
Our organization is committed to maintaining accurate, complete, and up-to-date personal information. If you are aware of changes to the personal information you have given to us, simply inform us of the changes and we will update our records accordingly. The accuracy of information is up to our discretion. If we disagree and indicate that no error has occurred, a note indicating that you believe that the information is not accurate will be added to your file.
9. Communication with Us
You should be aware that e-mail is not a 100% secure medium. In addition, mail, telephone calls, texts, faxes and transmissions over the internet are all susceptible to possible loss, misrouting, interception, and misuse of the information being communicated or transmitted. You should be aware of this when contacting us to send personal or confidential information.
As do many organizations, K4Paws attempts to strike a reasonable balance between security and convenience. At this time, when we use e-mail, it may be sent as unencrypted plain text. We do this because K4Paws believes that many of our clients and others cannot readily process encrypted e-mail. This is done for their convenience but has the security concern that, if misrouted or intercepted, it could be read more easily than encrypted e-mail. It is up to You to ensure that e-mail communication is protected while in transit. K4Paws recommends the use of password protections when confidential information is sent via email to K4Paws.
10. Filing Questions and Complaints
Individuals can direct any questions, concerns or complaints regarding K4Paws’ compliance with the above principles in writing to our privacy officer. The privacy officer will take appropriate measures to address the question, concern, or complaint. To file an opt-out request, access to your information request, report incorrect information, or file a complaint, please contact our Privacy Officer.
Contact Information Chief Privacy Officer:
Name: Paul Charbonneau, Board Chair
Address: 202-829 Norwest Road, Kingston, Ontario K7P 2N3
Phone: 613.766.4441
Email: paul@k4paws.ca
11. Website
Our website, https://kingstonservicedogs.ca , may contain links to other sites which are not governed by this Privacy Policy. On our website, like most other commercial websites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. K4Paws website logs IP addresses of visitors. This information is used, in aggregate form, to provide statistical measures about site usage. This allows K4Paws to improve the content and design of our website.
12. Changes to This Privacy Policy
We regularly review all of our policies and procedures and may change them from time to time. All changes to our Privacy Policy will be highlighted on our website. You will be provided express written notice of changes to our policies that affect the handling of your personal information.
