PRIVACY POLICY VERSION 2

Approved by the Board of Directors July 23, 2020.
A. INTRODUCTION
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:
The Foundation takes your privacy seriously and is committed to protecting your personal information.  
The purpose of this Privacy Policy is to give you information on how the Foundation collects, uses, discloses and processes your personal information, including any personal information you may provide through our website (the “Website”) or through other means.

Our Commitment

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.

What is Personal Information?

"Personal Information" means information about an identifiable individual, including any information about you or that can be used to identify you. For the purposes of this Privacy Policy, Personal Information means any information provided to or collected by the Foundation about an identifiable individual.

Scope of this Privacy Policy

This Privacy Policy applies to any Personal Information provided to or collected by the Foundation through our website (“Website”), by email, facsimile, postal mail, hand delivered, verbally or any other means.

Purpose of this Privacy Policy

The purpose of this Privacy Policy is to give you information about what Personal Information the Foundation collects from you, why we collect it and how we use it, as well as what happens if you choose not to disclose certain Personal Information to us.  This Privacy Policy is based on the principles outlined in the Canadian Standards Association's Model Code for the Protection of Personal Information, set out in Schedule 1 of Canada’s Personal Information Protection and Electronic Documents Act. These principles are:
1.
Accountability:
The Foundation is responsible for Personal Information under its control and will designate an individual to be accountable for its compliance with these principles.
2.
Identifying Purposes:
The Foundation will identify the purposes for which Personal Information is collected at or before the time the information is collected.
3.
Consent:
The knowledge and consent of the individual are required for the collection, use, or disclosure of Personal Information, except where inappropriate.
4.
Limiting Collection:
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.
5.
Limiting Use, Disclosure and Retention:
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.
6.
Accuracy:
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.
7.
Safeguards:
We will take reasonable steps to keep your Personal Information protected by security safeguards appropriate to the sensitivity of the information.
8.
Openness:
The Foundation will make easily available to individuals specific information about its policies and practices relating to the management of Personal Information.
9.
Individual Access:
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.
10.
Challenging Compliance:
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.
We will only collect, use and disclose your personal information in accordance with this Privacy Policy.
YOUR USE OF THIS WEBSITE SIGNIFIES YOUR AGREEMENT WITH THE TERMS OF THIS PRIVACY POLICY.  IF YOU DO NOT AGREE WITH THIS PRIVACY POLICY, PLEASE DO NOT USE THE WEBSITE OR SUBMIT ANY PERSONAL INFORMATION TO US.
Please read this document carefully.
B. HOW THE FOUNDATION COLLECTS PERSONAL INFORMATION
"Personal Information" means information about an identifiable individual, including any information about you or that can be used to identify you. For the purposes of this Privacy Policy, Personal Information means any information provided to or collected by the Foundation about an identifiable individual and applies regardless of how the information is collected, whether by email, facsimile, hard copy, verbally or any other means.
The Foundation collects Personal Information in different ways, including:
C. WHAT PERSONAL INFORMATION IS COLLECTED BY THE FOUNDATION
The Personal Information we may collect could include:
D. IDENTIFYING THE PURPOSES FOR WHICH PERSONAL INFORMATION IS COLLECTED
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:
We do not collect more Personal Information than we need to achieve these purposes.
E. CONSENT FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION
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 cprince@argylepr.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.
F. LIMITING COLLECTION OF PERSONAL INFORMATION
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.
G. LIMITING USE, DISCLOSURE, AND RETENTION OF PERSONAL INFORMATION
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:
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.
H. ENSURING ACCURACY OF 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 cprince@argylepr.com.
I. PROTECTION OF PERSONAL INFORMATION
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:
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.
J. ACCOUNTABILITY, OPENNESS AND CHALLENGING COMPLIANCE
The Foundation is responsible for Personal Information under our control.  We have designated a Privacy Officer to be accountable for our compliance with these principles and to oversee questions relating to privacy and this Privacy Policy.  If you have any questions about this Privacy Policy, including how to exercise your legal rights, or if you would like specific information about how we manage Personal Information, please contact the Privacy Officer at cprince@argylepr.com.
We also make this Privacy Policy and other privacy policies and practices easily available by posting them on this Website.
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.
K. ACCESS TO PERSONAL INFORMATION AND CORRECTION OF PERSONAL INFORMATION
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.
L. PROTECTING THE PRIVACY OF CHILDREN AND YOUTH
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.
If you are a child or youth, you should review this Privacy Policy with your parents or guardians to make sure that you understand and consent to everything in it.  If you are under the age of 13, you should not access our Website or provide us with any Personal Information unless your parent or guardian has consented.  If we discover that we have collected Personal Information from a child under the age of 13 without parental consent, we will delete that Personal Information.
M. INFORMATION COLLECTED THROUGH TECHNOLOGY AND SOCIAL MEDIA
A cookie is a small text file that is placed on your device when you visit a website and can last either for the duration of your visit (a “session cookie”) or for repeat visits (a “persistent cookie”). When you visit our Website we may automatically collect information about you using cookies and other similar mechanisms that work in the same way.  We use the word “cookie” in this Privacy Policy to refer to all files that collect information in this manner.
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.
We use cookies for the following purposes:
We collect the following types of information through cookies:
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.
You have choices when it comes to cookies.  All major browsers allow you to disable cookies.  If you do not want information collected through the use of cookies, you can disable it by changing the setting of your Internet browser.  If you disable cookies, you may be unable to access some features on our Website.
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.
N. COMPLIANCE WITH CANADA’S ANTI-SPAM LEGISLATION
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
O. OTHER JURISDICTIONS
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.
In addition to the rights listed in this Privacy Policy, other jurisdictions, such as the European Union (“EU”) grant other rights with respect to Personal Information.  If you reside in the EU, these rights include the rights to access your Personal Information; to have us erase it; to obtain and reuse it for your own purposes and to restrict its processing.  Certain limitations on or exceptions to these rights may apply.  If you are an EU resident, we may have to process or store your Personal Information outside of the EU.  We use contracts with third party service providers and other mechanisms to protect your Personal Information in accordance with this Privacy Policy and applicable law.
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.
P. CHANGES TO PRIVACY POLICY
We may make changes to this Privacy Policy from time to time, such as in response to developments and changes in privacy law.  When we post changes to this Privacy Policy on our Website, we will change the “last updated” date at the top of this Privacy Policy.  If possible, we will post notices of significant changes before they take place.  We will not reduce your rights under this Privacy Policy without your consent. Your continued use of this Website after any changes are made signifies your agreement with the terms of the revised Privacy Policy.