The Canadian Civil Liberties Association (“CCLA”, “we”, “us” and “our”) is committed to protecting your privacy through ensuring that your Personal information (as defined below) is safeguarded and is not used or disclosed in ways to which you have not consented. This privacy policy (“Policy”) explains the ways in which we collect, use and disclose your Personal Information. It applies to any Personal Information that is collected by us, whether it is collected in person, over the telephone, in writing, or electronically, including through this website (the “Site”).
CCLA complies with the Personal Information Protection and Electronic Documents Act as well as provincial privacy legislation, to the extent that it is applicable to us and to our activities. By providing us with your Personal Information and using our Site you accept this Policy and consent to its terms, as well as any other terms that are described to you when your Personal Information is collected. If you do not consent, please do not use the Site or otherwise provide your Personal Information to us.
This Policy may be amended or updated at our discretion from time to time. Please check the Site from time to time for such amendments. By continuing to access and use the Site, you accept and consent to the terms of the then current Policy, as amended.
“Personal Information” is information about an identifiable individual. Personal Information includes your name, residential address, telephone number, fax number, e-mail address, and questions or comments submitted by you on the Site.
Publicly available information, such as business contact information or a public directory listing of your name, address, telephone number or information that is aggregated and not associated with a specific individual, including demographic information and statistics, is not considered Personal Information.
When you visit our Site or interact with us, we may collect i) Personal Information, and ii) anonymous information that is not Personal Information about you.
Personal Information is collected by us when you provide it to us, such as when you provide us with your contact information or send us an email, when you meet with us in person, or when you phone us with an inquiry. We may also collect Personal Information from third parties, but only if the third party has indicated to us that they have obtained your consent to share your Personal Information with us.
We may collect the following types of Personal Information about you:
We do not collect the IP addresses of individuals who use this Site.
We collect certain non-personal information which is recorded by the standard operation of our internet servers on an anonymous basis, such the number of times a specific Site page is read.
This non-identifiable information is used on an aggregate basis and in a non-personally identifiable form, including: (i) for Site and system administration purposes; (ii) to improve the Site; (iii) to conduct internal reviews of the number of visitors to the Site; (iv) to help us better understand visitors’ use of our Site; (v) to respond to specific requests from our visitors; and (vi) to protect the security or integrity of our Site when necessary.
When you use the online donation forms on our Site, we collect and store some information on your computer. This information will be stored in a “Cookie,” which is a file created on your computer’s hard drive. With most Internet browsers, you can erase Cookies from your computer hard drive, block the creation of Cookies, or receive a warning before a Cookie is stored, although doing so may affect your use of the Site and your ability to access certain features of the Site. Please refer to your browser instructions or the help section of your browser to learn more about these functions.
Our Site may use Web beacon, gif, or other technologies. When you access certain of our web pages, a non-identifiable notice of that visit is generated. These technologies usually work in conjunction with Cookies. If you don’t want your Cookie information to be associated with your visits to these pages, you can set your browser to turn off Cookies. If you turn off Cookies, Web beacon and other technologies will still detect visits to these pages, but the notices they generate cannot be associated with other non-identifiable Cookie information and are disregarded.
We collect and use Personal Information primarily for the purposes of:
We do not collect more Personal Information than we require for the purposes for which Personal Information is being collected, unless we are required or permitted by law to collect additional information.
We will not share your personal information with third parties, unless we have obtained your prior consent to do so or are required to do so by law.
We will notify you of the purposes for which we are collecting your Personal Information. This notice will be provided at or before the time that we collect Personal Information about you so that you may refuse to provide us with your Personal Information or indicate that we may not use your Personal Information for certain purposes. Depending on the way in which Personal Information is collected, this may be done orally or in writing.
We will not refuse to provide you with any product or service if you refuse to provide us with certain Personal Information, unless we are unable to provide the product or service to you without this Personal Information. You may also withdraw your consent to allow us to use your Personal Information at any time upon providing us with reasonable notice, subject to legal or contractual restrictions. If you decide to withdraw your consent to allow us to use your Personal Information, we will explain the consequences of this withdrawal to you.
When Personal Information that has been collected is to be used for a purpose that we have not previously identified, we will communicate the new purpose prior to using the information for the new purpose, unless the new purpose is required or permitted by law.
Other than as required described in this Policy, or as allowed by law (for example, in response to a court order or subpoena, or to comply with local or federal regulations), your Personal Information will not be used for any other purpose without your consent.
Sometimes we disclose Personal Information to third parties for processing, such as for computer backup services and/or archival storage services, payment processing services, communications services, or other third party services related to services rendered by us. For example, we use a mass email service called Constant Contact to help send out our press releases, daily news links and e-bulletins. When we use third party services we ensure through contractual means that those third parties agree to only use the Personal Information for the purposes to which you have consented and agree to provide a level of protection to the information comparable to that adopted by us.
We actively endeavour to keep all Personal Information within Canada. Our donor database as well as our website and email are hosted in Canada. Despite this commitment, there are times when we will not be able to conduct our mandated activities or provide the required services while maintaining all data in Canada. We cannot, for example, guarantee that emails we send you are not routed through other countries. As a result, your Personal Information may be processed and stored outside of the province in which it was collected (including transfers within or outside of Canada). If your Personal Information is transferred outside of Canada, under the laws of certain other jurisdictions, in certain circumstances, foreign courts, law enforcement agencies, or regulatory agencies may be entitled to access your Personal Information without notice to you.
We implement security safeguards to protect Personal Information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We use physical, organizational and technological measures to protect Personal Information, such as locked filing cabinets, firewalls, encryption, confidentiality agreements, and employee education.
We will keep Personal Information only for as long as it remains necessary for the purposes for which it was collected, or as required by law. We use secure means of disposing of Personal Information, including shredding and professional eletronic waste disposal.
We want to make sure that the information that we have collected about you is accurate, complete, and current. However, we will not routinely update this information unless it is necessary for us to do so to fulfill the purposes for which we collected the information.
Since we generally rely on you to inform us if there have been any changes to the Personal Information that we have collected about you, please let us know if any of this information has changed.
If you have any questions about the accuracy of information that we have collected about you, you can have access to that information in order to verify and update it, unless we are permitted or required under applicable laws to refuse your access to such information.
You may write to or email our Privacy Officer at the address below to request access to Personal Information that we have about you. We will respond to requests within 30 days.
We are accountable for all Personal Information in our custody and control and have designated a Privacy Officer who is ultimately accountable for the handling of all Personal Information in our custody and/or control, and for ensuring that the principles described in this Policy are being complied with.
We make information about our privacy policies and practices readily available. If you have any concerns, complaints, or if you would like further information regarding our privacy policies or practices, please contact our Privacy Officer at:
Abby Deshman, Privacy Officer
Canadian Civil Liberties Association
215 Spadina Avenue, Suite 210
Toronto, Ontario M5T 2C7
Email: adeshman@ccla.org
Phone: 416-363-0321 ext. 223
Fax: 416-861-1291
If you have any questions about your privacy rights or complaints you may also contact the Privacy Commissioner of Canada at:
Office of the Privacy Commissioner of Canada
112 Kent Street
Place de Ville, Tower B, 3rd Floor
Ottawa, ON K1A 1H3
Fax: 613-947-6850
Inquiries: 1-800-282-1376
You may also contact the appropriate provincial privacy commissioner, if applicable. Please contact our Privacy Officer if you would like us to provide you with contact information for provincial privacy commissioners.
Date: May 16, 2014