Privacy Policy

The National 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. 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.
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Please read this document carefully.

a.

THE TEN PRIVACY PRINCIPLES

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:

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.
Identifying Purposes:
The Foundation will identify the purposes for which Personal Information is collected at or before the time the information is collected.
Consent:
The knowledge and consent of the individual are required for the collection, use, or disclosure of Personal Information, except where inappropriate.
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.
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.
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.
Safeguards:
We will take reasonable steps to keep your Personal Information protected by security safeguards appropriate to the sensitivity of the information.
Openness:
The Foundation will make easily available to individuals specific information about its policies and practices relating to the management of Personal Information.
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.
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.
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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.
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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.
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C. WHAT PERSONAL INFORMATION IS COLLECTED BY THE FOUNDATION

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.
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D. INFORMATION COLLECTED THROUGH THE INTERNET AND COOKIES

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:

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 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.

You have choices when it comes to 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.

The 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.
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E. USING YOUR PERSONAL INFORMATION

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 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.

The Foundation does not collect more Personal Information than we need to achieve these purposes. If the Foundation has already collected your Personal Information, we will not use that Personal Information for a new purpose without advising you first in writing and obtaining your consent for the new use, unless we are permitted by law to do so.
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F. WHO WILL YOUR PERSONAL INFORMATION BE SHARED WITH

We may have to share Personal Information with the parties set out below for the following purposes:

Any third party registered charities 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 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. We require all third party service providers 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.

The Foundation is located and operates programs and activities in Canada. Some or all of the Personal Information we collect may be stored or processed in jurisdictions outside of Canada, such as in cloud-based environments or through other technological measures operated by trusted third parties. 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.
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G. 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.
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H. CONSENT FOR COLLECTION, USE AND DISCLOSURE OF PERSONAL INFORMATION

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:

Verbally – such as when you tell us that you consent over the telephone or in a face to face meeting.
In writing – such as when you fill out an application form that tells you how your Personal Information will be collected, used and disclosed and asks for your consent. By completing and signing the form, you are providing your consent.
Through electronic means – such as when you check off a box on a website that says that you agree to the collection, use and disclosure of your Personal Information as described on that website.

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:

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 such as photographs and videos.
Contact information such as your mailing address, telephone number or email address.
Information about 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.

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.
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I. LIMITED 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.
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J. LIMITED USE, DISCLOSURE, AND RETENTION OF PERSONAL INFORMATION

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.
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K. ENSURING ACCURACY OF 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.
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L. PROTECTION OF PERSONAL INFORMATION

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:

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.

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.
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M. OPENNESS, ACCOUNTABILITY AND CHALLENGING COMPLIANCE

We have appointed a Privacy Officer 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:

Policy Officer: Jessica Braude

Contact:
137 Church street
Toronto, Ontario
M5B 1Y4
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Phone: (416) 300-7290
Email: tcarter@carters.ca

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.
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N. 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 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

Contact:
137 Church street
Toronto, Ontario
M5B 1Y4
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Phone: (416) 300-7290
Email: tcarter@carters.ca

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:

We will respond to your request within 30 days. If we cannot do so, we will send you a notice of extension, giving us additional time to respond to your request.
We will tell you how your Personal Information is being used or has been used and will tell you the third parties to which it has been disclosed. When it is not possible to provide a list of the third parties to which it has actually disclosed your personal information, we will provide a list of organizations to which we may have disclosed your Personal Information.
We may need you to provide more information to permit us to verify your identity before we can process your request.
We will respond to your written request at no or minimal cost to you. If there is a cost involved for the copying, transcribing or transmitting your Personal Information, we will inform you of the approximate cost beforehand and will only proceed if you have advised us to go ahead.
We will provide the Personal Information in a form that you can understand. For example, if we use abbreviations or codes to record information, we will provide you with an explanation of such abbreviations or codes.
In certain situations, we may not be able to provide access to all the Personal Information we have about you, or inform you of all disclosures of your Personal Information. For example, if there are references to other people or if there are legal or security reasons. If we can delete the information that cannot be shared with you, we will do so and provide you with access to the remaining information.
Unless prohibited by law, the reasons for denying access and the statutory provision on which the refusal is based, if any, will be provided to you in writing.
If you can demonstrate to our satisfaction that your Personal Information is not correct or complete for its purposes, we will correct the information as required and issue a new copy with the changes. If appropriate, we will add a statement that Personal Information has been deleted. If appropriate, we will send the corrected Personal Information to any third parties who had access to the inaccurate or incomplete Personal Information.
If you have challenged the accuracy or completeness of your Personal Information but we have not resolved the issue, we will keep a record of your challenge in your file and, if appropriate, we will tell third parties who have had access to your Personal Information about the unresolved challenge.
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O. COMPLIANCE WITH CANADA’S ANTI-SPAM LEGISLATION

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.
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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.

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