Approved by the Board of Directors July 23, 2020.
Sixties Scoop Healing Foundation (the “Foundation”) is a Canadian registered charity established to enable change and reconciliation between Indigenous and non-Indigenous people in Canada and, in particular, to heal the impact of the "Sixties Scoop" on Indigenous peoples in Canada by:
- Promoting and implementing programs and services to effect reconciliation between Indigenous peoples and non-Indigenous people and, in particular, with respect to the survivors of the Sixties Scoop, their families, lineages and communities.
- Providing healing and wellness programs and services to survivors of the Sixties Scoop, their families, lineages and communities.
- Commemorating the suffering and impact of the Sixties Scoops on survivors, their families, lineages, and communities.
- Undertaking educational programs, including research and scholarships concerning the Sixties Scoop and its impact on Indigenous people in Canada.
- Receiving and maintaining a fund or funds and applying all or part of the principal and income therefrom, from time to time for its charitable purpose and/or to registered charities under the Income Tax Act (Canada) to further its charitable purpose.
The Foundation takes your privacy seriously and is committed to protecting your personal information.
We are committed to protecting the privacy of our donors, employees, volunteers, website visitors and other stakeholders. We are accountable and transparent in how we treat your Personal Information. The Foundation does not sell, rent or trade its mailing lists or other Personal Information.
The Foundation is responsible for Personal Information under its control and will designate an individual to be accountable for its compliance with these principles.
The Foundation will identify the purposes for which Personal Information is collected at or before the time the information is collected.
The knowledge and consent of the individual are required for the collection, use, or disclosure of Personal Information, except where inappropriate.
The collection of Personal Information will be limited to that which is necessary for the purposes identified by the Foundation. Information will be collected by fair and lawful means.
Personal Information will 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. Personal Information will be retained only as long as necessary for the fulfillment of those purposes.
We will take reasonable steps to keep your Personal Information as accurate, complete and up-to-date as is necessary for the purpose for which it is used.
We will take reasonable steps to keep your Personal Information protected by security safeguards appropriate to the sensitivity of the information.
The Foundation will make easily available to individuals specific information about its policies and practices relating to the management of Personal Information.
Upon request, an individual will be informed of the existence, use, and disclosure of his or her Personal Information, and will be given access to that information. An individual will be able to challenge the accuracy and completeness of the information and have it corrected as appropriate.
An individual will be able to address a challenge about the Foundation’s compliance with these principles to the designated individual(s) accountable for the Foundation’s privacy compliance.
Please read this document carefully.
The Foundation collects Personal Information in different ways, including:
- Direct interactions – you may voluntarily provide us with Personal Information by filling out forms, applying for services, participating in one of our programs, registering to attend one of our conferences, subscribing for our publications or when you communicate with us face to face, over the telephone, by mail, by email, by text, through social media or through other means.
- Automated interactions – when you use our Website we may automatically collect technical data about your equipment and browsing history using cookies and similar technologies (See D below for more information).
- From third party sources – when we receive information about you from third parties such as regulatory bodies, government agencies, social workers or health professionals in connection with the delivery of services to you.
The Personal Information we may collect could include:
- Personal identifiers such as your name, date of birth, place of birth, gender and identification numbers (such as passport, driver’s license, health card, social insurance numbers).
- Images, including photographs and videos.
- Contact information such as your mailing address, telephone number or email address.
- Details of your background relating to your, age, Indigenous status or identity, Indigenous community of origin, family background, childhood history, adoption record, experience in foster care or in the child welfare system, finances, housing or accommodations, physical or mental health.
- Website account information such as your log-in, user name, password information and other security information.
- Information about your device such as your IP address, location or provider and your usage information and browsing history. (See D below for more information).
- Communications such as letters, emails and digital communications that we send to you or that you send to us.
The Foundation identifies the purposes for which Personal Information is collected at or before the time the information is collected.
The Personal Information we collect is used by the Foundation to manage our operations and for various purposes associated with the programs and services we provide. We collect, use, and disclose Personal Information only for purposes that a reasonable person would consider appropriate in the circumstances.
The main purposes for which we generally use Personal Information are:
- To establish and maintain records of Personal Information as required to operate, manage and deliver our programs and services, including our scholarship, research grant, mental health, sharing and healing, reunification, linguistic and cultural teaching, reconciliation and commemoration programs.
- To process your requests when you or apply to participate in one of our programs, to receive services or to receive a scholarship or research funding.
- To review applications for scholarships and research grants and to award scholarships and research grants to qualifying applicants.
- To manage, operate, oversee and administer our programs, services, research grants and scholarships.
- To support and monitor the students and researchers who have been granted scholarships and research grants.
- To raise awareness of our programs and services.
- To respond to your inquiries.
- To support and assist individuals in tracing their Indigenous identity and documentation, to identify their Indigenous community of origin and to search for and reunite with their families and communities of origin.
- To monitor the quality of our programs and to monitor and oversee the quality and performance of any registered charities to which we provide to further our charitable purposes.
- To provide, administer and protect our Website including troubleshooting, data analysis, maintenance and network security.
- To deliver relevant Website content and to provide associated functionality such as technical support and password reminders.
- To organize, promote and provide conferences, workshops and other educational, healing, reconciliation and commemorative events.
- To conduct research.
- To compile statistics regarding the Foundation’s programs and activities.
- To establish, manage or terminate our relationships with our employees, volunteers, consultants and contractors.
- To perform or carry out the terms of any contract between us.
- To respond to your inquiries.
- To send you informational or promotional communications (in compliance with Canada’s Anti-Spam Legislation).
- To record whether you have subscribed or unsubscribed from any of our mailing lists or publications.
- To disclose or share your Personal Information when required to comply with legal or regulatory requirements.
- To monitor the quality of our programs and services and to better understand the needs of our clients/stakeholders so that we can improve our programs and services.
- To prevent and detect fraud and other crimes such as terrorism financing or money laundering.
- To protect our rights, property or safety or that of our scholars, employees, volunteers, contractors, consultants, registered charities that we fund or any other person.
- For other purposes that we have told you about and for which you have given us your consent.
- To fulfill other purposes permitted or required by law.
We do not collect more Personal Information than we need to achieve these purposes.
We only collect, use and disclose Personal Information with your knowledge and consent. Your consent may be expressed orally, electronically or in writing or it may be implied. We are committed to obtaining meaningful consent and use clear explanations and plain language to make sure that our consent processes are understandable and user friendly.
You have the right at any time to withdraw or cancel your consent to the collection, use or disclosure of your Personal Information by contacting the Foundation’s Privacy Officer, at email@example.com
. Withdrawals of consent only take effect from the date of cancellation. They cannot be retroactive. We will let you know if your withdrawal could have any consequences, such as the Foundation being unable to provide you with goods or services.
The Foundation will only collect personal information for the purposes identified in this Policy. If we want to collect information for a different purpose, we will tell you what that purpose is in writing and obtain your consent. We collect Personal Information by fair and lawful means.
We will not collect, use or disclose more Personal Information than is reasonably necessary to meet the identified purposes. We will limit our collection of Personal Information to that which is necessary for the purposes identified by the Foundation.
The Foundation will only use or disclose Personal Information for the purposes for which it was collected, unless we have your consent to use it for a different purpose or if we are required by law. If we want to use or disclose your Personal Information for a new purpose, we will advise you of this purpose in writing and obtain your consent.
We keep Personal Information only as long as necessary to achieve the purposes for which it was collected although we may retain certain Personal Information indefinitely if we are required to do so by Canada Revenue Agency or by our insurers. If you have made a request to access Personal Information, we will keep that Personal Information for as long as is necessary to allow you to fully seek any remedies (exhaust any recourse) that you may have under federal and provincial legislation across Canada.
We do not disclose or share Personal Information more widely than is necessary to achieve the purposes for which it was collected.
We may share Personal Information with the parties set out below for the following purposes:
- With our expert advisors, in connection with specified engagement and data storage and retention activities, subject to agreements requiring them to follow appropriate privacy practices.
- Any third parties that deliver any of our programs.
- Third parties when it is necessary to do so to provide services to you, such as when we refer you to another organization or professional to assist you or provide you with services.
- Service providers, such as those who provide us with IT and system administration services.
- Professional advisors, such as lawyers, auditors, bankers and insurers who provide us with legal, accounting, banking and insurance services.
- Government, regulatory authorities, law enforcement, dispute resolution bodies, courts and similar entities to comply with any legal or regulatory obligation, to detect and prevent crimes or to assert or defend legal rights and interests.
- Any persons or entities where we have a legitimate business reason for doing so, such as to manage risk, to process payments to you or to someone on your behalf or to perform or carry out the terms of any contract between us.
- To the transferee if we transfer, sell or dispose of all or substantially all of our assets or operations
- To anyone we reasonably believe is your agent.
- To other third parties if we have told you about them and you have given us your consent.
We require all third parties to respect the security of your Personal Information and to treat it in accordance with all applicable legal requirements. All third party service providers are required to enter into contractual agreements with us that prevent them from using your Personal Information for their own purposes and require them to use your Personal Information only for specific purposes in accordance with our instructions and all applicable legal requirements.
We keep Personal Information only as long as necessary to achieve those purposes although we may retain certain Personal Information indefinitely if we are required to do so by Canada Revenue Agency or by our insurers.
If the Foundation has used Personal Information to make a decision about you (such as whether to give you a research grant or a scholarship), we will keep that Personal Information for at least one year to allow you access to the Personal Information after the decision has been made.
If you have made a request to access Personal Information, we will keep that Personal Information for as long as is necessary to allow you to fully seek any remedies (exhaust any recourse) that you may have under federal and provincial legislation across Canada.
The Foundation does not sell, rent or trade mailing lists or other Personal Information.
The Foundation has adequate processes and safeguards in place to keep Personal Information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. We will not routinely update Personal Information, unless such a process is necessary to fulfil the purposes for which the Personal Information was collected. To change or modify any Personal Information previously provided to the Foundation, contact the Privacy Officer at firstname.lastname@example.org.
We will take reasonable steps to keep Personal Information in both paper and electronic format protected against loss, theft, snooping, hacking or people collecting, disclosing, copying, using or changing it without authorization. We use security safeguards appropriate to the sensitivity of the information. Our methods of protection include:
- Physical measures - such as areas of restricted access and locked filing cabinets.
- Organizational measures - such as security policies and procedures, employee training on privacy issues, security clearances and limiting access on a "need-to-know" basis.
- Technological measures - such as passwords, encryption, audits as well as strong data security software and systems to protect the Personal Information in the Foundation’s custody from hackers and malicious intruders. Our software is routinely updated to maximize protection of Personal Information.
The Foundation makes all employees, volunteers as well as third party service providers aware of the importance of maintaining the privacy and security of Personal Information. All Foundation employees and volunteers must sign a confidentiality agreement. We require all third party service providers to enter into contractual agreements that require them to respect the security of your Personal Information and to treat it in accordance with all applicable legal requirements.
We securely destroy Personal information so that reconstruction is not reasonably possible. This prevents unauthorized parties from gaining access to the Personal Information.
While we are committed to protecting your Personal Information, our security practices and technology measures cannot guarantee absolute security of Personal Information and we cannot ensure or warrant the security of any information you provide to us. You can reduce risk to your own Personal Information by using strong passwords, keeping your passwords confidential and following other Personal Information security best practices.
If you have any complaints about our privacy practices or procedures, please contact the Privacy Officer. If we identify a gap in compliance, we will take appropriate steps to remedy the situation, including changing our policies and practices if necessary.
If you make a request to the Privacy Officer, we will inform you of the existence, use, and disclosure of your Personal Information and we will give you access to your Personal Information. We will respond to your request within the time periods provided for under applicable laws.
You can challenge the accuracy and completeness of Personal Information and have it changed or corrected as appropriate if there is an error or omission by contacting the Privacy Officer. We will respond to your request within the time periods provided for under applicable laws.
The collection of some Personal Information of children and youth is necessary to provide our services.
We understand that Personal Information relating to children and youth is particularly sensitive, especially the younger they are. Consistent with the position of the Office of the Privacy Commissioner of Canada, we will not collect Personal Information from children under the age of 13 unless we have the consent of their parents or guardians.
We collect the minimum amount of Personal Information of children and youth necessary to achieve our purposes.
Some of the cookies we use are necessary to enable you to use our Website. Other cookies may not be essential but may make it easier for you to use the Website (such as by remembering you when you return to the Website). Some cookies are used for advertising or tracking purposes.
- to identify you when you visit and navigate the Website (authentication)
- to determine if you are logged into the Website (status)
- to store information about your preferences and to personalize the Website for you (personalization)
- as a security measure, to prevent fraud and to protect the Website (security)
- to help us analyze the use and performance of our Website (analysis)
- to allow our advertising partners to track and analyze your behaviour on our Website and across the internet
- to publish interest-based advertisements on our Website that are tailored to reflect your interests (advertising).
We collect the following types of information through cookies:
- your IP address
- your approximate geographic location
- the type of operating system you are using (eg Windows or Mac)
- the type of device you are using
- the type of browser you are using
- your domain name
- which pages you visit on our Website
- the date and time of those requests
We collect this information for the purposes indicated above and to better understand how visitors use our Website, to improve the content of the Website and to improve your interaction with the Website by making it easier for you to get back to the pages you have looked at the next time you visit. Our advertising partners may also collect and use information through cookies on our Website, including third-party cookies which may track your behaviour across the internet.
Our Website may also provide links to third party websites. Clicking on those links may allow third parties to collect or share information about you. We cannot control these third party websites and we are not responsible for the actions or policies of such third parties. You should check the privacy policies of third parties when visiting their websites or when providing any Personal Information to them.
We may collect Personal Information when you interact with our content on third-party sites or platforms, such as Facebook, Instagram or You Tube. This may include data such as comments or feedback, "likes" or shares, profile data or the fact that you viewed or interacted with our content. If you voluntarily post or submit any information on these platforms, your Personal Information may be automatically included in the posting and may be collected and used by others.
The Foundation complies with the requirements of Canada’s Anti-Spam Legislation (“CASL”) as amended from time to time at all times, including when: sending emails or texts from a Foundation account, email address or domain name, obtaining consent from recipients to send emails or texts, managing and responding to requests to unsubscribe and documenting and retaining records of consent. The Foundation does not send commercial electronic messages (“CEMs”) to any person unless it has express or implied consent from the recipient, the CEM includes identification and contact information for the sender and the CEM has an unsubscribe mechanism. To ensure compliance with CASL, the Foundation has written policies and procedures, updates its volunteers and staff regarding CASL requirements and keeps records of consents and requests to unsubscribe. Complaints regarding the sending of CEMs and requests to unsubscribe from CEMs should be directed to the Privacy Officer
Some or all of the Personal Information we collect may be transferred to third party service providers in the course of our normal operations or activities including, without limitation, being stored on servers in cloud-based environments or transferred through other technological measures to trusted third parties to assist us in serving you. Some of our service providers are located outside of Canada and therefore Personal Information may be stored or processed in jurisdictions outside of Canada. As a result, this information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions.
If you have any questions or concerns about our privacy practices or procedures in relation to other jurisdictions, or to exercise any of your rights under the applicable law of other jurisdictions, please contact the Privacy Officer. We will let you know if there are any limitations or exceptions that apply.