Whenever we collect, use or disclose your Personal Information, we will comply with the Ten Principles for the Protection of Personal Information, set out in Schedule 1 of Canada’s Personal Information Protection and Electronic Documents Act. The Ten Principles are:
The Personal Information we may collect could include:
When you visit our Website or use Baobab, we may automatically collect information about you using cookies, server log files and other similar mechanisms. We collect the following types of information through the internet and cookies:
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 may have to share Personal Information with the parties set out below for the following purposes:
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.
We only collect, use and disclose Personal Information with the consent of the individual. Your knowledge and consent are required for us to collect, use or disclose your Personal Information, except in certain limited circumstances such as to investigate a crime or to comply with a court order. We are committed to obtaining meaningful consent. We use clear explanations and plain language to make sure that our consent processes are understandable and user friendly.
Consent can be either express or implied.
Express consent means that a person has clearly and explicitly agreed to the collection, use or disclosure of their Personal Information. Express consent may be given in a number of ways:
Implied consent means a situation in which, even though a person has not given express written or verbal consent, we assume that they have consented to the collection, use or disclosure of their Personal Information based on what they do or do not do. For example, if you give someone a document that contains your Personal Information, that person can reasonably conclude that you consent to their collection of this Personal Information.
In determining whether to obtain express consent or implied consent, the Foundation takes into account the sensitivity of the Personal Information and the reasonable expectations of the individual.
The Foundation collects sensitive or potentially sensitive information such as:
The Foundation requests express consent in most circumstances and always when sensitive or potentially sensitive Personal Information is collected.
The Foundation relies on implied consent only in very limited circumstances, such as to complete a process that has already been started.
You do not have to consent. You have the right to withhold your consent. You should be aware that in many cases, our collection, use, or disclosure of Personal Information is a valid condition of service, which means that we need that Personal Information in order to provide a particular service, such as granting you a scholarship. In such cases, if you do not wish to consent to the collection, use or disclosure of your Personal Information, we may not be able to do certain things, such as provide you with services.
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 Privacy Officer at XX. Please be aware that 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 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.
The Foundation will only use or disclose Personal Information for the purposes that it was collected for, unless we have your consent to use it for a different purpose or if we are required by law.
We have safeguards in place to prevent Personal Information from being disclosed or shared more widely than is necessary to achieve the purpose.If we want to use or disclose your Personal Information for a new purpose, we will advise you of this purpose in writing and get your consent.
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.
We may store your Personal Information in cloud-based environments or through other technological measures operated by trusted third parties.
The Foundation does not sell, rent or trade mailing lists or other Personal Information.
The Foundation makes decisions on the basis of Personal Information that is as accurate and complete as possible.
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, so that we can minimize the possibility that inappropriate information is used to make a decision about a person.
We will not routinely update Personal Information, unless such a process is necessary to fulfil the purposes for which the Personal Information was collected.
The Foundation is committed to protecting your Personal Information by security safeguards appropriate to the sensitivity of the information.
We take all reasonable precautions to protect Personal Information in both paper and electronic format against loss, theft, snooping, hacking or people collecting, disclosing, copying, using or changing it without authorization.
We use a higher level of protection to safeguard more sensitive Personal Information. Our methods of protection include:
The Foundation makes all employees, volunteers as well as third party 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 parties to enter into contractual agreements with us 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.
Policy Officer: Jessica Braude
137 Church street
Phone: (416) 300-7290
If you make a request to the Privacy Officer, we will inform you of the existence, use, and disclosure of your Personal Information and you will be given access to that Personal Information.
You can challenge the accuracy and completeness of the Personal Information and have it changed or corrected as appropriate if there is an error or omission.
These requests may be made by contacting the Privacy Officer at:
Policy Officer: Jessica Braude
137 Church street
Phone: (416) 300-7290
If you need assistance in preparing your request, we will assist you.
The procedures and time frame we will follow in processing these requests is as follows:
The Foundation complies with the requirements of Canada’s Anti-Spam Legislation, 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.