Privacy Policy
The Hamilton/Burlington Society for the Prevention of Cruelty to Animals (hereinafter “HBSPCA”) recognizes the importance of privacy and is committed to maintaining the accuracy, confidentiality and security of your personal information. We adhere to the principles of PIPA (Personal Information Protection Act), PIPEDA (Personal Information Protection and Electronic Documents Act), CASL (Canada’s Anti-Spam Legislation) and any other applicable legislation to protect the privacy and confidentiality of the personal information of donors, members, employees, directors, volunteers, clients and other stakeholders. The HBSPCA values the trust of those we deal with, and of the public, and recognizes that maintaining this trust requires that we be transparent and accountable in how we treat the information individuals choose to entrust with us.
During the course of our various activities, events, and through the conducting of our programs and services, the HBSPCA gathers and uses personal information to carry out its work and other day-to-day activities. It is reasonable for a person to expect the HBSPCA to carefully protect the personal information it collects and that any other use other than those for which it was collected, will be disclosed, and subject to consent.
This Privacy Policy describes the personal information that is collected from you by the various departments within HBSPCA, how we manage that personal information, and how that personal information is used.
HBSPCA is responsible for the personal information that our organization collects, and stores and uses. To ensure accountability and ease of access in this regard, HBSPCA has designated a Director of Data Systems, Analytics, Privacy and Architecture to oversee compliance by HBSPCA with this Privacy Policy. The contact information for our Privacy Director may be found towards the end of this Privacy Policy.
All departments within HBSPCA are required to act in accordance with this Privacy Policy, and your personal information will never be used or disclosed in a way not described in this Privacy Policy.
1. Defining Personal Information
We consider “Personal Information” to mean any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information, other than business contact information (i.e.: name, title, business address). Personal information may include age, marital status, religion, employment history, race, home address, home telephone number, identifiable photos and donor histories and files.
Personal information may be provided to us through correspondence, online donations, event or program registration, contest entries, requests for information, surveys, questionnaires, sales of products or services or other forms of communication.
This information may be collected and used by HBSPCA for the purposes of:
· providing and/or evaluating a service
· processing and receipting a donation or order
· recognizing a contribution
· identifying attendees at an event
· responding to information and product requests
· completing product orders or shipping contest prizes
· providing publications/products and email news or updates you have requested
Entering your information helps us to ensure that we can acknowledge and issue correct charitable receipts to donors, as well as provide products, information and services such as news alerts and action bulletins.
In addition, our website uses Google Analytics tracks general information about visitors, such as their domain name, time of visit, IP address and which pages are being accessed. This information is used only in aggregate form, to perform statistical analyses of user behaviour and characteristics, in order to measure interest in and use of the various sections of our site(s) so as to improve design and navigation and to gather marketing information for internal purposes only.
2. Privacy Practices
Personal information gathered by HBSPCA will be treated with respect. We are responsible for all personal information in our possession.
All employees, agents and authorized service providers of HBSPCA are required to protect the confidentiality of your personal information. We keep your personal information and the business you do with us in strict confidence.
Where we choose to have certain services provided by third party providers, we select the service providers carefully. We take all reasonable precautions to ensure that the service provider protects your personal information. These service providers enter into confidentiality agreements and do not keep any personal information on their files.
Our staff are authorized to access personal information based only on their need to deal with the information for the reasons for which it was obtained. Safeguards are in place and continue to be enhanced to ensure that information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was gathered. We also take measures to ensure the integrity of this information is maintained.
We collect, use and disclose personal information only for purposes that a reasonable person would consider appropriate in light of the circumstances. We routinely offer individuals we deal with the opportunity to opt not to have their information shared for purposes beyond those for which it was explicitly collected.
3. Identifying Purposes
We collect, use or disclose information only for use in the administration of our programs, including animal adoption, microchip registration, pet health insurance registration, TNR clinics, owned animal clinic appointments and animal foster care and to keep you informed and up to date on the activities of HBSPCA, including programs, services, special events, fundraising, and opportunities to volunteer.
4. Consent
HBSPCA obtains the consent of individuals before or when it collects, uses or discloses personal information, except where authorized by law.
5. Limiting Collection
HBSPCA will limit the collection of personal information to that which is necessary for the purposes identified by the Hamilton/Burlington SPCA. Personal information shall be collected by fair and lawful means.
6. We do not sell your personal information
HBSPCA does not sell its donor list. If it rents, exchanges or otherwise shares its donor list, it will abide by the Canadian Marketing Association Code of Ethics and Standards of Practice and honour donors’ requests to be excluded from such lists.
HBSPCA may disclose your personal information to individuals or organizations that are our service providers. Where we disclose personal information to individuals or organizations that perform services on our behalf, we will require those service providers to use such information solely for the purposes of providing services to Humane Canada and to have appropriate safeguards for the protection of that personal information.
Please note that there are circumstances where the use and/or disclosure of personal information may be justified or permitted or where HBSPCA is obliged to disclose information without consent.
Such circumstances may include:
1. Where required by law or by order or requirement of a court, administrative agency or governmental tribunal
2. Where Humane Canada believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group
3. Where it is necessary to establish or collect monies owing to Humane Canada
4. Where it is necessary to permit Humane Canada to pursue available remedies or limit any damages that we may sustain
5. Where the information is public
Where obliged or permitted to disclose information without consent, Humane Canada will never disclose more information than is required.
7. Limiting Use, Disclosure and Retention
HBSPCA will not use, disclose or retain personal information other than for the purposes for which it was collected, except with the consent of the individual, or as permitted or required by law.
In addition, third party service providers may be engaged by HBSPCA to perform a variety of functions. These third party suppliers have access to personal information only if needed to perform the functions for which they are retained. We always direct that such third party suppliers may only use any personal information provided to them for the purpose of performing their roles and may not retain it or use it for any other purpose. In these cases, where the information is transferred to a third party, we will demand reasonable assurance that the third parties will protect your information in conformity with our privacy practices. HBSPCA will not otherwise disclose your personal information for purposes other than those for which it was collected, except as may be permitted or required by law, or with your consent.
8. Use of Credit Card and Banking Information
The HBSPCA recognizes that, for the purposes of donations or purchases, supporters may provide us with their banking or credit card information. We only use this information to process the transaction as intended by the supporter.
Credit card transactions processed offline are processed through Level 1 PCI DSS (Payment Card Industry Data Security Standard) service providers and payment gateways. Our credit card processing service providers and payment gateways are reviewed annually, or whenever a provider is changed. Offline credit card information is never retained.
Credit card transactions processed online through our website are passed through a secure third-party provided SSL verified connection to adhere to industry standard privacy and security standards.
Our donor database (Raiser’s Edge NXT) does not retain credit card information for one-time donations. For recurring monthly donations, credit card information is stored until donation cancellation but is not visible to HBSPCA staff outside of card type, last 4 digits of card on file and card expiry date. Card Security Code (CSC) is not retained. For monthly direct debit donations, donor banking information is stored until donation cancellation.
9. Accuracy and Safeguarding your Information
HBSPCA will keep personal information as accurate, complete and current as is necessary for the purposes for which it is to be used. We will protect personal information with security safeguards appropriate to the sensitivity of the information.
10. Individual Access and Openness
Upon written request, and subject to exemptions stipulated by law, HBSPCA will inform an individual of the existence, use and disclosure of their personal information and will provide access to that information. An individual may challenge the accuracy and completeness of the information and have it amended as appropriate.
11. Inquiries, Concerns and Requests for Access or Removal from Mailing List
If you have any questions about this Privacy Policy or wish to review, verify, obtain a copy, update or correct your personal information or if you wish to deposit a written comment in your file or a request to delete such information, please contact the office of the Privacy Officer for the region in which you live. Please note that all requests to access personal information must be in writing or by e-mail.
Hamilton/Burlington SPCA
245 Dartnall Road
Hamilton, Ontario
L8W 3V9
Requests to be removed from our mailing list can be made by email to development@hbspca.com or by phone at 905-574-7722.
Please check back for updates to our Privacy Protection Policy. We may change the terms of this policy from time to time in order to reflect new practices. Any changes will be clearly displayed online. Any information collected by us will be dealt with in accordance with the provisions of our policy that were in effect at the time of collection.
