Principle 1 Accountability
An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization’s compliance with the following principles.
Accountability for Nanaimo Foundation’s compliance with privacy legislation rests with the designated Privacy Officer.
The role of the privacy officer is to ensure the protection of personal data and compliance with current legislation across the organization. The Foundation Chairman is the CPO- Chief Privacy Officer.
The Privacy officer will respond to all complaints in a timely manner. Complaints and resolutions will be documented. The board will be notified of all complaints and resolutions.
Board members, volunteers, and staff members will be required at all times to respect the confidentiality of a donor’s name, level of gift, and personal circumstances that might identify them if asked to do so by the donor or by motion of the Board. Board members will be required to hold in strictest confidence all matters dealt with by the Board during in-camera meetings and matters related to personnel and property.
The Nanaimo Foundation is responsible for personal information in our possession, including information that has been transferred to a third party for processing. In cases where such transfers take place, the Nanaimo Foundation ensures that the third party has comparable privacy safeguards in place.
Principle 2 Identifying Purposes
The purposes for which personal information is collected shall be identified by the Nanaimo Foundation when or before the information is collected. The Nanaimo Foundation collects personal information concerning our donors for the following reasons:
- To comply with CRA requirements for gifts processing;
- To provide donors with information about how donated funds are used by the Nanaimo Foundation;
- To keep donors informed about the Nanaimo Foundation’s activities;
- To promote opportunities for donors and potential donors to support the Nanaimo Foundation;
- To determine the donor’s motivation in creating a fund and to assist the Nanaimo Foundation in making decisions about distributions from the fund;
- To advise fund-holders of donations made to their funds.
The Nanaimo Foundation will specify the identified purposes, or in writing, to an individual from whom personal information is being collected either at the time of collection or after collection but prior to use or disclosure. The Nanaimo Foundation will state the identified purposes in such a manner that an individual can reasonably understand how the information will be used or disclosed.
Principle 3 Consent
The knowledge and consent of the individual are required for the collection, use or disclosure of personal information, except where inappropriate. Individuals can give consent
- In writing, such as when completing an online donation form or signing any agreements with the Nanaimo Foundation;
- Through an opt-out process, either by checking off a box on a response form or by contacting the Nanaimo Foundation directly;
- Orally, either in person or by telephone.
Individuals may withdraw their consent at any time, by any means, with reasonable notice to the Nanaimo Foundation. However, consent cannot be withdrawn retroactively.
Principle 4 Limiting Collection
The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means.
Some of the types and means by which personal information is collected by the Nanaimo Foundation include:
- Information collected automatically from the Nanaimo Foundation website
- Information collected directly from an individual
- Information collected from public sources
Principle 5 Limiting Use, Disclosure, and Retention
Personal Information shall 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 by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.
- The Nanaimo Foundation does not sell, rent, or trade mailing lists.
- Personal Information is disclosed only to third parties who have signed an agreement by which they agree to adhere to the terms of the Nanaimo Foundation’s privacy policies.
- The Nanaimo Foundation will not disclose an individual’s identity or personal information to third parties except in accordance with the terms of its privacy policies or unless required to do so as a part of an internal investigation or other law enforcement purpose, or as required by law.
Principle 6 Accuracy
Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.
Principle 7 Safeguards
Personal information shall be protected by security safeguards appropriate to the sensitivity of the information.
Protection Methods will include physical measures (e.g. locked filing cabinets, restricted access to office), organizational measures (e.g. security clearances and limiting access on a “need-to-know” basis), and technological measures (e.g. the use of security passwords and encryption).
Principle 8 Openness
An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information. The information made available will include:
- The name or title and contact information of the Privacy Officer, who is accountable for compliance with the Nanaimo Foundation’s policies and procedures, and to whom complaints or inquiries can be forwarded;
- The means of gaining access to personal information held by the Nanaimo Foundation;
- A general description of the types of personal information held by the Nanaimo Foundation;
- A copy of any document that explains the Nanaimo Foundation’s policies, procedures, standards or codes;
- A general description of the types of personal information made available to third parties.
Principle 9 Individual Access
Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.
Principle 10 Challenging Compliance
An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization’s compliance.
Fund Development Policy
General Policies for Fund Development
The policy of the Foundation is to inform, serve, guide or otherwise assist donors who wish to support the Foundation’s activities.
- Donors may determine if their fund will be open or closed.
- Distributions from the distributable earnings will be identified as having come from the fund in correspondence with donors, grantees and the media.
- Fund administration fees will be determined by the Board.
- All planned gift agreements shall be approved by the Board. The board may approve a form of gift agreement to be used for substantially similar gift arrangements in the future.
- A fund agreement is required to establish a fund. The Foundation will collaborate with donors to draft a fund agreement. Approval of the fund agreement will rest with the Board and will require a resolution to confirm the terms of the agreement.
- The foundation will provide donors with a financial report for their fund at least once annually.
The Nanaimo Foundation is committed to providing the highest level of professional service to its donors, grant recipients, stakeholders, and the community it serves. The Foundation values its reputation in the community and takes great pride in our contributions to the community.
If you have a complaint regarding the actions of the Nanaimo Foundation and/or one of its board members, committee members, volunteers, or staff, we encourage you to call our Chairman to discuss your concerns.
A complaint received will be addressed within five business days, at most, by the Chairman. If the complaint involves the Chairman, please contact the Board Vice Chair.
All complaints will be brought forward to the Chairman outlining the nature of the complaint and the steps to be taken to achieve resolution. Any complaint involving the Chairman will be forwarded to the Vice Chair. If at any time a complaint cannot be resolved by the Chairman, the Vice Chair will be notified and brought into the resolution process.
On a regular basis, the Chairman will report to the full Board of Directors on the status, volume and severity of any complaints received.