OUR GUIDING PRINCIPLES
The Sir Mortimer B. Davis – Jewish General Hospital Foundation [the “Foundation”] is committed to protecting the privacy of our donors and to upholding Canadian and Provincial privacy principles and laws. In the course of our fundraising activities, we frequently gather and use personal information. We value the trust placed in us by our donors and volunteers, and recognize that maintaining this trust requires us to be transparent and accountable in our treatment of personal information that is entrusted to us. As a donor or volunteer of the Jewish General Hospital Foundation, your right to confidentiality and privacy will be protected.
The following policy reflects our commitment to safeguard our donors’ and volunteers’ personal information.
DEFINITION OF PERSONAL INFORMATION
“Personal Information” is any information that can be used to distinguish, identify or contact a specific individual. This includes information as to whether an individual has donated to the Jewish General Hospital Foundation, and how much has been donated. Business contact information and certain publicly available information, such as names, addresses and telephone numbers that are published in telephone and online directories are not considered personal information.
COLLECTION OF PERSONAL INFORMATION
The Foundation collects personal information by fair and lawful means only and limits collection of personal information to that which is necessary for purposes identified. These purposes include:
- Processing of your donation and the preparation of your charitable tax receipt, if applicable in compliance with CRA requirements for gift processing;
- Recognizing your gift in our publications and/or in physical formats around the hospital such as plaques in the various departments and divisions;
- Providing information about how donated funds are used by the hospital;
- Communicating with you periodically in print, verbally or electronically in order to provide information about funding needs related to medical research and patient care, our programs, services, special events, opportunities to volunteer, etc.;
- Building and maintaining a relationship with you, understanding your needs and tailoring our approach to serve you better;
- Complying with legal and regulatory requirements
- The Foundation will make a reasonable effort to ensure you are aware of the purposes for which the information is collected at the time of collection, either verbally or in writing.
OBTAINING YOUR CONSENT TO COLLECT, USE OR DISCLOSE PERSONAL INFORMATION
We collect, use or disclose your personal information only with your consent. Your consent can be expressed, deemed or implied in relation to the collection of your personal information.
Expressed consent is given explicitly and can be given orally, electronically or in writing.
Deemed consent is when the purpose of the collection, use or disclosure, would be considered obvious to a reasonable person and you voluntarily provide personal information to the Foundation for that purpose (e.g. providing your email address to receive a tax receipt via email).
Implied consent is when it can reasonably be concluded that consent has been given by an action you’ve taken, or when you decide not to take an action (e.g. not notifying us that you want to discontinue receiving invitations to events by email).
Personal information of donors and volunteers will not be used or disclosed for purposes other than those for which it was collected, except with consent of our donors and volunteers or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes and may be disclosed to the Jewish General Hospital to ensure the use of your gifts as directed.
“The Foundation does not trade, rent or sell any personal information to third parties.”
The Foundation’s website contains online forms that allow visitors to make a donation. The credit card information provided on these forms is used only to process these donations and is not retained by the Foundation. Online donations to the Foundation are processed through a third-party provider. We are responsible for the information that has been transferred to a third-party provider and we ensure that the third-party provider has privacy safeguards in place. The security and privacy policies of the third-party provider are available by clicking on the Security Policy link at the bottom of each page of our website at jghfoundation.org.
Similar to other websites, our website uses a standard technology called cookies to collect information about how our website is used and the traffic it generates. A cookie is a very small text document, which often includes an anonymous unique identifier. When you visit a website, that site’s computer asks your computer for permission to store this file in a part of your hard drive specifically designated for cookies. Each website can send its own cookie to your browser if your browser’s preferences allow it, but to protect your privacy, your browser only permits a website to access the cookies it has already sent to you, not the cookies sent to you by other sites. Cookies are used to remember information you gave us so you don’t have to re-enter it each time you visit our site, which allows for faster and simpler navigation. This information is gathered to perform statistical analysis of user behavior and characteristics. This is done to allow us to better design our website and to improve the content to meet the needs of our visitors. This information will not be shared or sold for commercial purposes.
Our website contains links to other websites. When you leave our website via links and enter other sites, you are subject to the privacy and security policies of those sites.
The Foundation makes every effort to ensure that all transactions that occur on its website are secure and protected from error, loss and unauthorized access. Password protocols, access restrictions and firewalls are used to protect personal information received when an online donation is made. Our software is updated at a minimum, annually, to maximize protection of such information. We store personally identifiable data with Secure Socket Layer (SSL) encryption to protect information that is entered on our site. SSL is the industry-standard protocol. All off-line information is securely stored and accessible only by authorized Foundation staff.
The Foundation safeguards will protect personal information against loss, theft, or destruction as well as unauthorized access, disclosure, copying, use or modification, regardless of the format which the information is held.
Foundation staff is authorized to access personal information based only on their need to deal with the information for the purpose(s) for which it was collected. Each employee and volunteer must sign an agreement stating that maintaining confidentiality is a condition of their employment or volunteer status with the Foundation. Staff and volunteers are aware of the importance of maintaining the confidentiality of personal information and care is exercised in the disposal and destruction of personal information to prevent unauthorized parties from gaining access to it.
Certain services such as the distribution of annual mail appeal letters are provided by third party contractors (e.g. mail houses) who are carefully selected and who are also required to sign a confidentiality agreement binding them to the Foundation’s privacy policies.
OPTING OUT, ACCESSING OR UPDATING PERSONAL INFORMATION
The Foundation offers its donors and volunteers the opportunity to limit or opt out of future contact by the Foundation. To limit or withdraw your consent, please contact the Foundation at firstname.lastname@example.org or call (514) 340-8251. We rely on our donors and volunteers to provide us with accurate personal information that is used on an ongoing basis, and the Foundation makes reasonable attempts to keep this information up-to-date. To verify, change or modify any personal information previously provided to the Foundation, write to us at JGH Foundation, 3755 chemin de la Côte Sainte-Catherine, Room A-107, Montréal, QC, H3T 1E2, call us at (514) 340-8251, or email us at email@example.com.
Donors and volunteers may ask whether the Foundation holds any personal information about them and can verify and determine its accuracy by calling (514) 340-8251 or by writing to:
The JGH Foundation
Attention: Data Privacy Officer
3755 chemin de la Côte Sainte-Catherine, Room A-107,
Montréal, QC H3T 1E2
Via email: firstname.lastname@example.org.
Requests for access to personal information will be addressed within 30 days of a formal request being made.
COMPLIANCE WITH CANADA’S ANTI-SPAM LEGISLATION (“CASL”)
The Foundation communicates electronically (email) with its donors and volunteers to provide information about advances in medical diagnosis, treatment and research at the Jewish General Hospital. We also communicate with our donors to inform them about activities in the Foundation, funding opportunities and ways to donate or to volunteer their services. As a registered charity, the primary purpose of our electronic messages is to raise funds and provide awareness in support of the Jewish General Hospital.
CASL addresses the sending of Commercial Electronic Messages or CEMs. In those cases where our CEMs do not fall under the CASL’s charitable or other exemptions, the Foundation takes every reasonable step to ensure that it has active, express or implied consent in accordance with CASL legislation before sending the message. The Foundation provides the opportunity at the bottom of every electronic message for receivers to easily update their preferences or unsubscribe to receiving electronic messages, and identifies the Foundation as the sender and provides its mailing address.
To ensure compliance with CASL, the Foundation has written policies and procedures and updates its governance committee and its staff on the directives of CASL. Records of consents and requests to unsubscribe are kept. Complaints regarding the sending of CEM’s and requests to unsubscribe should be directed to the Foundation’s Data Privacy Officer, via email at email@example.com or in writing to: JGH Foundation, Attention: Data Privacy Officer, 3755 chemin de la Côte Sainte-Catherine, Room A-107, Montréal, QC H3T 1E2.