Hope Air is committed to protecting the privacy of the Personal Information of its clients/ patients, and their families, as well as donors, social workers, health professionals, volunteers, our employees and all other stakeholders. Hope Air values the trust of those being served and dealt with, and of the public. Hope Air recognizes that maintaining this trust requires transparency and accountability in how information that anyone chooses to share with Hope Air is collected and treated. During the course of Hope Air’s various activities Personal Information is frequently gathered and used. The information collected will be used in support of Hope Air’s mission and to keep people informed about Hope Air’s activities. Anyone from whom such information is collected should expect that the information will be carefully protected and that any use of or other dealing with this information is subject to consent.
“Personal Information” means any information about an identifiable individual. Examples of personal information collected by Hope Air may include, but are not limited to: age, gender, address, telephone number, email address, date of birth, amounts donated, and income information. For the purposes of this policy, “Personal Information” also includes Personal Health Information.
“Personal Health Information” refers to identifying information about an individual relating to his or her physical or mental health, the providing of services to the individual, and the individual’s eligibility for Hope Air services.
Hope Air takes full responsibility for Personal Information under our control and has designated the Chief Executive Officer (“CEO”) as Hope Air’s Privacy Officer who is responsible for ensuring compliance.
Hope Air is responsible for Personal Information in the organization’s possession, including information that has been transferred to a third party for processing. In instances where such transfers take place, inquiries are made to determine that appropriate privacy safeguards are in place.
The purposes for which Personal Information is collected shall be identified by Hope Air when or before the information is collected. Hope Air will state the identified purposes in such a manner than an individual can reasonably understand how the information will be used or disclosed.
Purposes for which Hope Air may collect Personal Information include, but are not limited to:
- determining eligibility of a person for Hope Air’s services
- delivery of Hope Air’s programs and services
- facilitating the recruitment of staff members and volunteers
- to comply with CCRA requirements for gift processing
- conducting public education, outreach and advocacy activities
- providing updates about news and events
- conducting fundraising activities, and
- managing relationships with stakeholders.
The individual is the main source of his or her Personal Information, but Hope Air may obtain information directly from a third party where required. For example, a patient’s medical appointments are confirmed directly with healthcare providers, as is a patient’s medical fitness to travel.
Hope Air makes every reasonable effort to ensure that individuals are aware of the purposes for which the information is collected at the time of collection.
Individuals can give consent:
- in writing, such as when completing a donation or registration form;
- through an opt-in process, either by checking off a box on a response form or by contacting Hope Air; or
- orally, either in person or by telephone.
Individuals will not receive electronic messages or be added to our mailing list unless we have received consent from them to do so at the time their contact information is collected.
Individuals may withdraw consent at any time, by any means, with reasonable notice to Hope Air. However, failure to provide personal information to Hope Air may prevent us from being able to provide the requested services and/or programs. If an individual chooses to withdraw their consent, Hope Air will discuss any consequences that may result. Individuals can withdraw consent by sending an email to firstname.lastname@example.org. Please provide us with your exact name and address (mail and email).
Hope Air may also collect, use and disclose Personal Information without consent if that information is considered by law to be in the public domain. Sources of public information include telephone and professional directories, newspapers, periodicals and public registries.
The collection of Personal Information shall be limited to that which is necessary for the purposes identified by Hope Air. Information shall be collected by fair and lawful means.
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.
Under no circumstances are contact lists or other Personal Information sold, rented or leased to third parties. Personal Information will be disclosed only to those Hope Air staff members and volunteers that need to know the information for the purposes of their work or official duties.
Hope Air may transfer Personal Information to a third party supplier, if the transfer is simply for processing purposes and the third party only uses the information for the purposes for which it was transferred. An example of this might include providing information to a commercial airline when booking a flight for a client.
Under certain exceptional circumstances, Hope Air may have a legal duty or right to disclose Personal Information without the individual’s knowledge or consent.
Given the nature of our work, Personal Information is kept for a significant period of time as defined by best practices and legal requirements, and may extend beyond a client’s relationship with Hope Air. Personal Information is archived by Hope Air for statistical purposes.
Hope Air uses its best efforts to ensure that any Personal Information provided by an individual in his or her active file(s) is kept by Hope Air as current and complete as possible. Hope Air relies on individuals to disclose all relevant information and materials at the time of collection and subsequently when updates are required. Individuals are requested to notify Hope Air of any change in Personal Information. Information contained in inactive files is not updated.
Personal Information shall be protected by security safeguards appropriate to the sensitivity of the information.
Hope Air’s safeguards are intended 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.
Hope Air makes its employees aware of the importance of maintaining the confidentiality of Personal Information, and exercises care in the disposal and destruction of Personal Information to prevent unauthorized parties from gaining access to it. All employees and volunteers having access to Personal Information are required to sign a confidentiality waiver.
Hope Air’s methods of protection will include appropriate physical measures, organizational measures and technological measures.
Third party consultants are expected to safeguard personal information entrusted to them in a manner consistent with the policies of Hope Air, and are required to sign a confidentiality agreement as part of all contracts. Examples of third party consultants include mailing services and data analysis providers.
Hope Air will be open about its policies and practices relating to the management of Personal Information and will make all policies and practices readily available in a form that is generally understandable.
If anyone has any additional questions or concerns about privacy, Hope Air invites individuals to contact Hope Air by phone or email, and all concerns will be addressed to the best of Hope Air’s ability.
Individual Access and Correction
Upon request, with limited exceptions, 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. Where appropriate, the amended information will be transmitted to third parties having access to the information in question.
Also, with limited exceptions, Hope Air will give individuals access to the information retained about them within a reasonable time, upon presentation of a written request and identification satisfactory to Hope Air.
Upon request, Hope Air will provide such information about third parties to whom personal information has been disclosed, as it deems appropriate in the circumstances.
All individuals are able to address a challenge concerning compliance with the above principles to our Privacy Officer. Hope Air maintains procedures to receive and respond to complaints or inquiries about its policies and practices relating to the handling of Personal Information. Hope Air’s complaint procedure is easily accessible and simple to use. Individuals who make inquiries or lodge complaints will be informed by Hope Air of the existence of relevant complaint procedures. If the complaint is found to be justified, Hope Air will take appropriate measures, including the revision of Personal Information and, if necessary, amendment of Hope Air’s policies and practices.
When you make a donation to Hope Air online, a secure connection is established and your information is encrypted to prevent interception during the transaction. This secure connection is maintained until the transaction is completed or terminated. The software that enables these processes is routinely updated to maximize protection of your information. If you provide us with your postal address, email address or telephone number, you may receive periodic communication regarding Hope Air’s services or upcoming events, or responding to any request you have made.
Hope Air is not responsible for the contents of any “off site” internet information referenced by or linked to the Hope Air website. The inclusion of any link does not imply endorsement by Hope Air of the external site. Use of any such linked website is at the user’s own risk. This Policy describes the privacy practices of Hope Air as such relate to its website only.
How to Contact the Privacy Officer
124 Merton St., Ste. 207
Toronto, ON M4S 2Z2
Further information on privacy and your rights in regard to your personal information may be found on the website of the Privacy Commissioner of Canada at www.priv.gc.ca.
Last modified: Aug 16, 2017
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