International Justice Mission Canada (IJM Canada) is committed to protecting the personal information that it collects, uses and discloses in accordance with the federal Personal Information Protection and Electronic Documents Act (“PIPEDA”) and applicable provincial privacy legislation.
1. What is personal information?
Personal information means information about an identifiable individual in any form and excludes business contact information and work product information, as these terms are defined in applicable legislation.
2. What personal information we collect
IJM Canada may collect personal information such as:
• Name and personal contact information
• Donor related information
• Financial information, such as financial institution accounts or credit card numbers
• Volunteer or employee information
• Client/victim casework information
IJM Canada collects such information through communications directly with you, except in unusual circumstances.
3. How we use your personal information
We use your personal information to inform you of our activities, service your financial and other support of IJM Canada, comply with requirements of funding bodies and applicable laws, and to operate the work of IJM Canada. We may also use your personal information to understand your preferences and to tell you about specific IJM Canada initiatives that may be of particular interest to you.
4. How we disclose your personal information
We may disclose your personal information to other IJM entities to inform you of their activities as they relate to IJM Canada, comply with legal and regulatory obligations, and to operate the work of IJM Canada.
5. Your consent
We request your consent in writing, through electronic means or orally to collect, use or disclose your personal information, except as permitted by law. Your consent may also be implied through an action that you take after we have notified you of a change to this policy.
If you prefer not to provide consent or withdraw your consent, we may not be able to inform you of our activities, service your financial and other support of IJM Canada, comply with our legal obligations, or operate aspects of the work of IJM Canada.
If we use or disclose your personal information for any new purpose not mentioned in this policy, we will ask for your consent. We may not seek your consent if the use or disclosure is required or permitted by law.
6. What is personal employee information?
Personal employee information is personal information about an employee or volunteer which is collected, used or disclosed solely for the purposes of establishing, managing or terminating an employment relationship or a volunteer work relationship. We only collect, use and disclose personal employee information for the purposes described in the section “Why we collect personal employee information” below. The personal employee information includes:
• Contact information such as your name, home address, telephone number, e-mail address
• Criminal background checks
• Employment or volunteer information such as your resume, reference information and interview notes, correspondence relating to offer/acceptance of employment, policy acknowledgement forms, background verification information, workplace performance evaluations, emergency contacts, etc.
• Benefits information, as applicable
• Financial information, such as pay cheque deposit information and tax-related information, as applicable
• Other personal information required for the purposes of our employment or volunteer relationship
7. Why we collect personal employee information
We are permitted to collect, use and disclose your personal employee information without your consent only for the purposes of establishing, managing or ending the employment or volunteer relationship. The purposes for which we collect, use and disclose personal employee information include:
• Determining eligibility for employment or volunteer work
• Establishing training and development requirements
• Assessing performance and managing performance issues
• Administering pay and benefits, and work-related claims, as applicable
• Complying with requirements of funding bodies and applicable laws
We provide current employees and volunteers with prior notice about what information we collect, use or disclose and our purpose for doing so. We will obtain your consent to collect, use and disclose your personal information for purposes unrelated to our employment or volunteer relationship.
8. How long is personal information retained?
Personal information is retained only for as long as it is used for the purpose for which it was obtained or for legal purposes. We use appropriate measures to retain and destroy personal information.
9. Requests for access to personal information, inquiries and complaints
Any individual may request access to their personal information held by IJM Canada or inquire or complain about IJM Canada’s compliance with its own policy and the relevant legislation. Written requests, inquiries or complaints are forwarded promptly to IJM Canada’s Privacy Officer and will receive a response within 30 days from IJM Canada’s Privacy Officer. Compliance with this policy is monitored and will be managed by the Privacy Officer.
Requests, inquiries and/or complaints may be submitted to:
Vice-President of Operations, Privacy Officer
PO Box 336 STN B
London, ON N6A 4W1
The timeframe for responding to requests, inquiries and complaints will be based on the date on which IJM Canada is able to confirm the identity of the individual making the request, inquiry or complaint.
In response to an individual’s request, inquiry and/or complaint regarding personal information held by IJM Canada, the Privacy Officer will search out and record personal information pertaining to that individual held by IJM Canada. The Privacy Officer will document this information and make it available to the individual who made the request.
Where an individual is inquiring about IJM Canada’s compliance with its own policy or legislation, the Privacy Officer will investigate the inquiry.
If we refuse a request, inquiry or complaint, we will provide reasons for the refusal.
10. Privacy Officer
The Vice-President of Operations of IJM Canada is the Privacy Officer for IJM Canada and will be held responsible for the compliance of the organization with applicable privacy legislation and this policy. The Privacy Officer’s duties are to:
• Review the policies and practices of IJM Canada with regard to personal information, and make appropriate amendments
• Communicate the manner in which IJM Canada treats personal information
• Handle complaints concerning personal information
11. Keeping Personal Information Safe
IJM Canada takes seriously the responsibility to protect your personal information. We protect personal information in a manner appropriate for the sensitivity of the information. We make reasonable efforts to prevent any loss, misuse, disclosure or modification of personal information, as well as unauthorized access to personal information. We also rely on you to notify us when there is a change in your personal information that may affect your relationship with us. Please let us know if there is a change or error in your personal information and we will correct it, following the process described in “Requests for access to personal information, inquiries and complaints”.
Access to the personal information held by IJM Canada is limited to authorized personnel. Authorized personnel are those individuals who must be able use and manage the personal information held by IJM Canada in order to properly fulfill their function within the organization. Processes for the entering, removal, editing, selection, viewing and/or use of personal information are communicated and monitored by the Privacy Officer.
The personal information held by IJM Canada is not sold, rented or traded with other organizations but is available to our auditors, tax authorities and other government agencies, as required by law.
In instances where IJM Canada engages third-party vendors when using personal information (for example, for printing and mailing IJM Canada’s newsletter or obtaining IT support) reasonable steps are taken to ensure the personal information is protected and confidentiality is maintained.
In very limited circumstances, we may store or process personal information (excluding financial information) outside of Canada. In this case, personal information may be subject to the laws of the other jurisdiction.
Approved by the Board of Directors of IJM Canada on October 21, 2011; title of Privacy Officer updated May 5, 2015.