At the Evangelical Free Church of Canada (EFCC) we understand that privacy is a vital issue for our constituents. This privacy policy outlines our principles and procedures regarding the confidentiality and security of constituent personal information. Some of our services require the collection, use and disclosure of some personal information about our constituents, protecting their personal information is one of our highest legal and ethical priorities.

EFCC Accountability
We have strengthened our commitment to protecting personal information as a result of British Columbia’s Personal Information Protection Act (PIPA).  PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. businesses and not-for-profit organizations may collect, use and disclose personal information.

Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our constituents’ personal information and allowing our constituents to request access to, and correction of, their sensitive personal information. In all communications, EFCC advises constituents that complete confidentiality and security are not assured. EFCC is not accountable for any damages suffered when information is communicated to the constituent or at the request of the constituent.

Information is available to our constituents as to why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that is described hereafter.

Definitions
Collection – the act of gathering, acquiring, or obtaining personal information.
Consent – involves voluntary agreement with what is being done or proposed. Consent may be expressed or implied either orally or in writing. Implied consent exists when EFCC can reasonably infer consent based upon the action or inaction of the constituent.
Constituent – is any individual who works, contributes, applies, attends, submits and commits to participate in any way with EFCC (may be donor, employee, missionary, pastor, supplier, affiliate organization, etc.)
Contact information –information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number.  Contact information is not covered by this policy or PIPA.
Disclosure – the act of making personal information available to third parties who may or may not be associated with EFCC.
EFCC – Evangelical Free Church of Canada
Personal Information – information about an identifiable individual, such as: name, age, home address, home phone number, social insurance number, marital status, religion, income, credit history, medical information, education, employment information.  Personal information does not include contact information (described above).
Privacy Officer –the individual responsible for ensuring that Evangelical Free Church of Canada complies with this policy and PIPA.
Use – the treatment and handling of personal information by and within EFCC.
We – refers to Evangelical Free Church of Canada.

Policy 1 – Purposes for Collecting Personal Information
1.1  Unless the purposes for collecting personal information are obvious and the constituent voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.

1.2  We will collect constituent information that is necessary to fulfill the following purposes:
– To enter into a contract with a constituent;
– To develop and manage a high standard of services to meet the needs of our constituents;
– To verify a constituent’s identity;
– To ascertain constituent preferences;
– To open and manage an account;
– To guarantee a travel or hotel reservation;
– To process a magazine subscription;
– To provide medical, dental, and counselling services;
– To send out information and correspondence;
– To contact our constituents for fundraising;
– To meet regulatory requirements.

Policy 2 – Constituent Consent
2.1  We will obtain constituent consent, when consent is not implied, to collect, use or disclose personal information (except where, as noted in this policy, we are authorized to do so without consent).

2.2 Consent can be provided orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting, using or disclosing the personal information would be considered obvious and the constituent voluntarily provides personal information for that purpose.

2.3 Consent may also be implied where a constituent is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs, e-links, and fundraising and the constituent does not opt-out.

2.4 Subject to contractual or legal arrangements and reasonable notice, constituents can withhold or withdraw their consent for Evangelical Free Church of Canada to use their personal information.  A donor’s, employee’s, missionary’s and pastor’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product.  If so, we will promptly explain the implications of the withdrawal.

2.5 We may collect, use or disclose personal information without the donor’s, employee’s, missionary’s and pastor’s knowledge or consent in the following limited circumstances:
– When the collection, use or disclosure of personal information is permitted or required by law;
– In an emergency that threatens an individual’s life, health, or personal security;
– When the personal information is available from a public source (e.g., a telephone directory);
– When we require legal advice from a lawyer;
– For the purposes of collecting a debt;
– To protect ourselves from fraud;
– To investigate an anticipated breach of an agreement or a contravention of law.

Policy 3 – Using and Disclosing Personal Information
3.1  We will use or disclose constituent personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
–  To conduct constituent surveys in order to enhance the provision of our services;
– To contact our constituents directly about meetings, opportunities, products and services that may be of interest.

3.2  We will not use or disclose constituent personal information for any additional purpose unless we obtain consent to do so.

3.3  We will not sell constituent lists or personal information to other parties.

Policy 4 – Retaining Personal Information
4.1   If we use constituent personal information to make a decision that directly affects the constituent, we will retain that personal information for at least one year so that the constituent has a reasonable opportunity to request access to it.

4.2  Subject to policy 4.1, we will retain constituent personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.

Policy 5 – Ensuring Accuracy of Personal Information
5.1 We will make reasonable efforts to ensure that constituent personal information is accurate and complete where it may be used to make a decision about the constituent or disclosed to another organization.

5.2 EFCC will not routinely update information unless it is necessary to fulfill the purposes for which it was collected or if it is required to maintain active constituent information.

5.3 Constituents may request correction to their personal information in order to ensure its accuracy and completeness.  A request to correct personal information must be made by letter or electronic message and provide sufficient detail to identify the personal information and the correction being sought.

5.4 A request to correct personal information should be forwarded to the Privacy Officer or designated individual.

5.5 If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required.  If the desired amendment to information remains in dispute, EFCC will note the constituents’ opinion in the file.

Policy 6 – Securing Personal Information
6.1 We are committed to ensuring the security of constituent personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, loss, theft, modification or disposal or similar risks.

6.2 The following security measures will be followed to ensure that constituent personal information is appropriately protected: the use of locked filing cabinets; physically securing offices where personal information is held; the use of user IDs, passwords, encryption, firewalls, possession by lawyer; restricting employee access to personal information as appropriate (i.e., only those that need to know will have access); contractually requiring any service providers to provide comparable security measures.

6.3 We will use appropriate security measures when disposing of a constituent’s personal information such as shredding documents and deleting electronically stored information.

6.4 We will continually review our security policies and controls to ensure ongoing personal information security.

Policy 7 – Providing Constituents Access to Personal Information
7.1 Constituents have a right to access their personal information, subject to limited exceptions, such as solicitor-client privilege, or if disclosure would reveal personal information about another individual. The Officer will ensure that, upon request, EFCC will inform an individual whether EFCC holds personal information about him/her. If possible, the information’s source will also be given. EFCC may, however, choose to make sensitive medical information about its constituents available through a medical practitioner.  EFCC will also account for the use that has been made or is being made of this information.  (Note: if the Officer believes for valid reasons that access to personal information should be denied, he/she shall consult legal counsel before making such a decision.)

7.2  A request to access personal information must be made in writing, by letter of electronic message and provide sufficient detail to identify the personal information being sought.  A request to access personal information should be forwarded to the Privacy Officer or designated individual.

7.3 Upon request, we will also tell constituents how we use their personal information. If the organization has supplied personal information about an individual to third parties, the Officer will ensure that an attempt is made to be as specific as possible.  When EFCC is unable to give a list of the organizations to which it has disclosed information about an individual, EFCC will provide a list of organizations to which it might have disclosed information about the individual.

7.4 We will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.

7.5 A minimal fee may be charged for providing access to personal information.  Where a fee may apply, we will inform the constituent of the cost and request further direction from the constituent on whether or not we should proceed with the request.

7.6 If a request is refused in full or in part, we will notify the constituent in writing, providing the reasons for refusal and the recourse available to the constituent.

Policy 8 – Questions and Complaints:  The Role of the Privacy Officer or designated individual
8.1 The Privacy Officer or designated individual is responsible for ensuring EFCC’s compliance with this policy and the Personal Information Protection Act.

8.2 Constituents should direct any complaints, concerns or questions regarding EFCC’s compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the constituent may also write to the Information and Privacy Commissioner of British Columbia.

Contact information
Evangelical Free Church of Canada
info@efcc.ca