What is 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 (e.g. name, title, business address). This Policy does not cover aggregated data from which the identity of an individual cannot be determined. RIN retains the right to use aggregated data in any way that it determines appropriate.
Why RIN May Collect Personal Information
RIN may use the Personal Information provided, verbally or in writing (including via electronic media), by volunteers and other stakeholders in order to:
- Administer the RIN program;
- Maintain the volunteer databases;
- Provide information to volunteers, partner organizations and the community at large about RIN programs and services;
- Manage our relationships and communicate with, among others, volunteers, partner organizations and the community at large;
- Register volunteers;
- Solicit, receive, process and recognize donations;
- Publish and distribute a RIN newsletter;
- Respond to information requests;
- Meet legal and regulatory requirements; and
- Such other purposes consistent with these purposes.
How RIN Collects and Uses Personal Information
RIN only collects, uses and discloses Personal Information for purposes that would be considered reasonable in the circumstances and only such information as is required for the purposes of providing services or information to our volunteers, members, partner organizations, the community at large and others. We use only fair and lawful methods to collect Personal Information.
Our use of Personal Information is limited to the purposes described in this Policy and RIN does not otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information it has obtained.
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When RIN May Disclose Your Personal Information
RIN may disclose your Personal Information to:
- Individuals or organizations who are our advisors or service providers; and
- Individuals or organizations involved in maintaining, reviewing and developing our business systems, procedure and infrastructure including testing or upgrading our computer systems; or a reorganization of RIN.
In the event sensitive Personal Information is provided to RIN, we will not disclose such Personal Information unless it is required in order to fulfill our mandate.
Where RIN discloses Personal Information to organizations that perform services on its behalf, we will require those service providers to use such information solely for the purposes for which it was provided. Where Personal Information may be subject to transfer to another organization in contemplation of a merger or reorganization of all or part of RIN, we will do this only if the parties have entered into an agreement under which the collection, use and disclosure of the information (including any Personal Information) is restricted to those purposes that relate to the transfer, and is to be used by the parties to carry out and complete the transfer.
Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where RIN is obliged to disclose information without consent. Such circumstances may include:
- Where required by law or by order or requirement of a court, administrative agency or governmental tribunal;
- Where RIN believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group; or
- Where the information is public.
Where obliged or permitted to disclose information without consent, RIN will not disclose more information than is required.
Unless permitted by law, no Personal Information is collected, without first obtaining the consent of the individual concerned to the collection, use and dissemination of that information. However, we may seek consent to use and disclose Personal Information after it has been collected in those cases where we wish to use the information for a new or different purpose where the individual concerned has not already consented to such a use of their personal information.
By providing Personal Information to RIN you agree and consent that we may collect, use and disclose your Personal Information in accordance with this Policy. In addition, where appropriate, specific authorizations or consents may be obtained from time to time.
In most cases and subject to legal and contractual restrictions, you are free to refuse or withdraw your consent at any time upon reasonable, advance notice. It should be noted that in certain circumstances, certain services or information can only be offered if you provide Personal Information to RIN. Consequently, if you choose not to provide us with any required Personal Information, we may not be able to offer you the services or information requested. We will inform you of the consequences of the withdrawal of consent.
The Accuracy and Retention of Personal Information
RIN endeavours to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary for the purposes for which we use that information. If we become aware that Personal Information is inaccurate, incomplete or out of date, RIN will revise the Personal Information and, if necessary, use its best efforts to inform third parties that were provided with inaccurate information so that those third parties may also correct their records.
We keep your Personal Information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the service and the nature of the information. This period may extend beyond the end of a person’s relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date.
When your Personal Information is no longer required for RIN’s purposes, we have procedures to destroy, delete, erase or convert it into an anonymous form.
Currently, the principal place in which RIN holds Personal Information is in the City of Ottawa.
Protection of Personal Information
RIN endeavours to maintain appropriate physical, procedural and technical security with respect to its information storage to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This also applies to our disposal or destruction of Personal Information.
RIN further protects Personal Information by restricting access to it to those employees, volunteers, and members that the management of RIN has determined need to know that information in order that we may provide our services or information.
If any employee, volunteer or member of RIN misuses Personal Information, this will be considered a serious offence for which disciplinary action may be taken, up to and including termination of the employment or other relationship.
While no method of transmission over the Internet, or method of electronic storage, is 100% secure, if we learn of a security systems breach, we will inform you and the authorities of the occurrence of the breach in accordance with applicable law.
Access to Your Personal Information
RIN permits the reasonable right of access and review of Personal Information held by us about an individual and will endeavour to provide the information in question within a reasonable time, generally no later than 30 days following the request.
We will provide information from our records in a form that is easy to understand. RIN reserves the right not to change any Personal Information but will append any alternative text the individual concerned believes to be appropriate.
RIN reserves the right to decline to provide access to Personal Information where the information requested:
- Would disclose (i) Personal Information, including opinions, about another individual or about a deceased individual; or (ii) confidential information that may harm RIN or other third party;
- Would interfere with contractual or other negotiations of RIN, or a third party;
- Is subject to solicitor-client, litigation or other legal privilege;
- Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information;
- Does not exist, is not held, or cannot be found by RIN;
- Could reasonably result in (i) serious harm to the treatment or recovery of the individual concerned, (ii) serious emotional harm to the individual concerned or another individual, or (iii) serious bodily harm to another individual;
- May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by law to perform such functions; or
- May be withheld or is requested to be withheld under applicable legislation.
Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure.
In the event of questions about: (i) access to your Personal Information; (ii) our collection, use, management or disclosure of Personal Information; or (iii) this Policy; please contact RIN at email@example.com. We have procedures in place to receive and respond to complaints or inquiries about our handling of Personal Information. We will describe the complaint procedures to anyone who makes inquiries or lodges complaints. If you are not satisfied with our response after making a complaint, you may have recourse to additional remedies under applicable privacy legislation. For further information, please contact the federal Privacy Commissioner or your provincial or regional Privacy Commissioner, as applicable.