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Rotary Club of Newmarket

 Privacy Policy

At Rotary Club of Newmarket, we are committed to providing our customers and members with exceptional service.  As providing this service involves the collection, use and disclosure of some personal information about our customers and members, protecting their personal information is one of our highest priorities.

We will inform our customers and members of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our customers’ and members’ personal information and allowing our customers and members to request access to, and correction of, their personal information.

Definitions:

Personal Information –means information about an identifiable individual. E.g.,  name,  home address and phone number, email address. 

Privacy Officer – means the individual designated responsibility for ensuring that Rotary Club of Newmarket complies with this policy.

Policy 1 – Collecting Personal Information

1.1  Unless the purposes for collecting personal information are obvious and the customer and member voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2  We will only collect customer and member information that is necessary to fulfill the following purposes:

·         To verify identity;

·         To identify customer and member  preferences;

·         To deliver requested products and services

·         To enrol in a program;

·         To send out membership information;

·         To contact our customers and members  for fundraising;

·         To ensure a high standard of service to our customers and members

 Policy 2 – Consent

2.1  We will obtain customer and member consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).

2.2  Consent can be provided orally, in writing or electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the customer and member voluntarily provides personal information for that purpose.

2.3  Consent may also be implied where a customer and member is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, the marketing or fundraising and the customer and member does not opt-out.

2.4  Subject to certain exceptions (e.g., the personal information is necessary to provide the service or product, or the withdrawal of consent would frustrate the performance of a legal obligation), customers, members can withhold or withdraw their consent for Rotary Club of Newmarket to use their personal information in certain ways.  A customer’s or member’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product.  If so, we will explain the situation to assist the customer and member in making the decision.

2.5  We may collect, use or disclose personal information without the customer’s and member’s knowledge or consent in the following limited circumstances:

·         When the collection, use or disclosure of personal information is permitted or required by law;

·         In an emergency that threatens an individual's life, health, or personal security;

·         When the personal information is available from a public source (e.g., a telephone directory);

·         When we require legal advice from a lawyer;

·         For the purposes of collecting a debt;

·         To protect ourselves from fraud;

·         To investigate an anticipated breach of an agreement or a contravention of law

3.1  We will only use or disclose customer and member personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:

·         To conduct customer and member surveys in order to enhance the provision of our services;

·          To contact our customers and members directly about products and services that may be of interest.

3.2  We will not use or disclose customer and member personal information for any additional purpose unless we obtain consent to do so.

3.3  We will not sell customer and member lists or personal information to other parties

Policy 4 – Retaining Personal Information

4.1  If we use customer and member personal information to make a decision that directly affects the customer and member we will retain that personal information for at least one year so that the customer and member  has a reasonable opportunity to request access to it.

4.2  Subject to policy 4.1, we will retain customer and member personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

 Policy 5 – Ensuring Accuracy of Personal Information

5.1  We will make reasonable efforts to ensure that customer and member personal information is accurate and complete where it may be used to make a decision about the customer and member or disclosed to another organization.

5.2  Customers, Members may request correction to their personal information in order to ensure its accuracy and completeness.  A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.

A request to correct personal information should be forwarded to the Privacy Officer

5.3  If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year.  If the correction is not made, we will note the customers’, members’ correction request in the file.

 Policy 6 – Securing Personal Information

6.1  We are committed to ensuring the security of customer and member personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.

6.2  The following security measures will be followed to ensure that customer and member personal information is appropriately protected:

These may include: the use of locked filing cabinets; physically securing offices where personal information is held; the use of user IDs, passwords, encryption, firewalls; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access; contractually requiring any service providers to provide comparable security measures].

6.3  We will use appropriate security measures when destroying customer’s and member’s personal information such as shredding documents, deleting electronically stored information.

6.4  We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.

Policy 7 – Providing Customers, Members Access to Personal Information

 7.1  Customers, Members have a right to access their personal information, subject to limited exceptions.

Example: Solicitor-client privilege, disclosure would reveal personal information about another individual, health and safety concerns

7.2  A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer.

7.3  Upon request, we will also tell customers and members how we use their personal information and to whom it has been disclosed if applicable.

7.4  We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

7.5  A minimal fee may be charged for providing access to personal information.  Where a fee may apply, we will inform the customer and member of the cost and request further direction from the customer and member on whether or not we should proceed with the request.

7.6  If a request is refused in full or in part, we will notify the customer or member  in writing, providing the reasons for refusal and the recourse available to the customer, member .

 Policy 8 – Questions and Complaints:  The Role of the Privacy Officer or designated individual

8.1  The Privacy Officer or designated individual is responsible for ensuring Rotary Club of Newmarket’s compliance with this policy.

8.2  Customers, Members should direct any complaints, concerns or questions regarding Rotary Club of Newmarket’s compliance in writing to the Privacy Officer.

Contact information for Rotary Club of Newmarket Privacy Officer or designated individual:

Contact: Peter Ginsberg ... pcg@rogers.com