PROTECTION AND CONFIDENTIALITY OF PERSONAL DATA (Information) POLICY

Updated: June 10, 2024

Yamaska Literacy Council

The Yamaska Literacy Council (“YLC”) is subject to the Act respecting the protection of personal information in the private sector (Law 25). YLC is committed to protecting the confidentiality and security of your personal information in accordance with the principles applicable to the protection of personal information.

 

This privacy policy describes how YLC collects, uses, stores, and communicates personal information during its business activities. It is intended to evolve over time to reflect any changes made in the administration of personal information, to comply with applicable laws and to demonstrate transparency.

CONSENT

YLC only collects and uses personal information with the consent of the individual.

By providing YLC with personal information, you accept the terms and conditions of this policy.

 

If you are not a resident of Quebec, please note that by providing your personal information, you are deemed to consent to: (i) the collection, use and disclosure of your personal information in Quebec; and (ii) the collection, use and disclosure of your personal information in accordance with the laws of the province of Quebec (which may differ from the privacy laws of the jurisdiction of your residence) and this policy.

 

An individual can withdraw their consent by contacting YLC at [email protected]

 

By accessing, visiting, or using the Yamaska Literacy website (www.yamaskaliteracy.ca) or related mobile applications, an individual accepts the terms and conditions of this policy.

DEFINITION OF PERSONAL INFORMATION

By personal information, we mean any information that concerns an individual and which, taken alone or in combination with other information, allows them to be identified.

RESPONSIBILITY

YLC is responsible for the personal information it collects, including personal information communicated to third parties for administrative purposes, processing, or maintenance.

 

The Chairperson of the YLC Board of Director ensures compliance with this policy to meet the following requirements:

  1. To designate a person responsible for the protection of personal information (Privacy Officer).
  2. To establish governance policies and practices in relation to personal information.
  3. To report privacy incidents involving personal information that would present a serious risk of harm and record them in the Confidentiality Incident Register.
  4. To ensure transparency in the collection and use of personal information.
  5. To ensure clear, free, and informed consent in the use and processing of personal information.

PURPOSES OF COLLECTION AND USE

The collection, use and communication by YLC is limited to what is necessary for the operations of YLC. We may use your personal information to conduct data analysis and research to guide our operations. YLC collects personal information for various reasons, including:

  • Follow up on requests from members, volunteers, participants, and donors.
  • Soliciting donations.
  • Processing and accounting of donations made and the production of charitable receipts.
  • Registration of participants for an event, activity, or service.
  • Application for membership and volunteering.
  • Management of contracts and service agreements.
  • Ensuring the operation and maintenance of full functionality of the website and social Media accounts (i.e. Facebook, Instagram, Mailchimp), including fulfillment of service and information requests of members, volunteers, participants, and donors; response to comments and questions; and provision of support for users of the website and social media accounts.
  • For statistical purposes understanding and analysis of usage trends and preferences of our members, volunteers, participants and donors, improvement of the website and social media accounts, and development of new products, programs, services, news features and functionality.
  • For administrative or marketing purposes in accordance with applicable laws relating to commercial electronic messages.

LIMITS ON COLLECTION AND USE

The collection of personal information by YLC is limited to what is necessary for the purposes indicated or clearly implied at the time of collection. It is possible that YLC may collect and use information concerning an individual which comes from a third party when the law authorizes it and with the consent of the person concerned in all other cases.

 

For example, YLC, in the context of fundraising or for participation in events is likely to request and collect the following information when creating a file or processing a service:

  • First and last name
  • Civic address
  • Email address
  • Phone number

If a donor uses a credit card to donate through the YLC website, no information related to this credit card is collected by YLC on its servers. Payment for donations is processed and administered by the banking procedures of a third-party provider, directly on their website.

At no time will YLC share any information with third-parties, or otherwise disseminate it without the consent of the person concerned, except in cases authorized or required by the law.

HOW INFORMATION IS COLLECTED

YLC may collect personal information in various ways, including, but not limited to:

  • By completing an application (for service; to volunteer; for membership)
  • By telephone
  • Via YLC’s website and its related software
  • By responding to a postal request
  • By email

PRESERVATION OF PERSONAL INFORMATION

YLC retains personal information for as long as is reasonably necessary for the purposes for which it was collected or as required by law.

SECURITY OF PERSONAL INFORMATION

YLC applies and ensures that it and its sub-contractors apply appropriate physical, technological, and administrative security measures to maintain the confidential nature of personal information to protect it against theft, loss, disclosure, or unauthorized access.

DESTRUCTION OF PERSONAL INFORMATION

YLC will undertake appropriate security means to destroy personal information when the destruction of information is required and legal.

COMMUNICATION OF PERSONAL INFORMATION

Access to information is limited to the YLC Staff and Board Members assigned for this purpose, and only in the exercise of their work.

 

Under no circumstances will YLC sell, share, or rent this information.

 

YLC does not, under any circumstances, communicate personal information for purposes other than those for which these were collected, except with the consent of the person concerned or as the law requires or permits.

 

Every member of the YLC Staff or Board of Directors is committed to respecting personal information collected by YLC. These people undertake to preserve the confidentiality of information specific to the activities of YLC and not to disclose its content, make any personal use of it, or use it for the benefit of others. This commitment exists from the time members of YLC Staff and Board of Directors begin work for YLC and continues indefinitely. YLC Staff and Board Members will sign an agreement to maintain such confidentiality.

 

YLC undertakes to require confidentiality commitments from these third parties at least as demanding as those provided for in this policy, including controls and measures aimed at protecting the confidentiality, security, and integrity of the information they hold on behalf of YLC, and to avoid theft, loss, disclosure, or unauthorized access to personal information.

 

Despite the above, no method of transmitting or storing personal information by electronic means offers infallible security. Therefore, YLC cannot therefore guarantee that the confidentiality and integrity of personal information cannot be infringed.

REPORTING AND RECORDING PRIVACY INCIDENTS (breach of data)

If, despite efforts to protect personal information, an incident involving this information occurs, YLC will undertake the following actions as soon as the breach is identified:

  1. Collect the information concerning the breach which will be recorded in the Confidentiality Incident Register. This will include recording the personal information concerned, the circumstances, the period (or date) of the breach, the date the breach was noted, and the number of people targeted.
  2. Assess the situation to determine if there is resultant harm and of what kind.
  3. If the breach presents a risk of serious injury, notice will be sent to person(s) affected by the breach, including a description of the measures taken by YLC.
  4. Implement the measures described for those affected by the breach.
  5. A report is made by the Privacy Officer to the Chairperson of the YLC Board of Directors, Le Commission d’accès à l’information du Quebec, and other required authorities.

ACCESS

Subject to relevant laws and upon receipt of a written request from an individual and after verifying their identity, YLC will inform the individual whether it has personal information on that individual and will communicate what personal information it has on them.

 

YLC may refuse a person access to their information in accordance with the relevant laws, in which case it will give reasons for its refusal.

CORRECTING OR UPDATING OF PERSONAL INFORMATION

YLC will make reasonable efforts to ensure that the personal information it holds is accurate and complete as required for the purposes for which it is used. An individual can request a correction or update by contacting YLC.

COMPLAINTS

Anyone about whom YLC holds personal information may complain about non-compliance with this policy in writing.  YLC will process any complaints.

 

If an individual is dissatisfied with YLC’s response to a complaint, or with the policy and practices regarding the processing of personal information, they may file a complaint with the Commission d’access à l’information du Québec on the Commissioner’s website at www.cai.gouv.qc.ca

RESPONSIBLE FOR THE PROTECTION OF PERSONAL DATA

Wendy Seys

YLC’s Privacy Officer, Executive Director

Yamaska Literacy Council

505 rue du Sud, #203

Cowansville, QC J2K 2X9

450-263-7503

[email protected]

Prepared by Executive Director
File Location YLC One Drive: Folder: Policies and Procedures
Paper copy location Cowansville Office files
Date of approval June 10, 2024
Responsible for Updating Executive Director
Amendment Process  

1.               The Executive Director prepares a draft amendment indicating the elements to be modified and sends it to the Chair of the Board in advance.

2.               The amendment is included on the agenda of a meeting of the Board of Directors.

3.               The document is discussed during the meeting and is ratified by a resolution.

4.               The Executive Director makes the changes on the policy.

5.               A copy of the resolution is filed with the original policy kept in the official minute book of YLC .

6.               The amendments are listed below in Updates

 

Updates