Privacy Policy

Our Commitment to Privacy and Digital Education:

Foundation for a Path Forward  is committed to respecting the privacy of its Donors, Clients, Beneficiaries, Volunteers and Employees. As part of this commitment, we want everyone to know our principles and practices for the collection, use, processing, transfer, storage or disclosure of Personal Information.

This Privacy Notice outlines our policy and practices on the collection, use, transfer, storage and disclosure of Personal Information about Donors, Clients, and any other individuals with whom we work. It also applies to employees, volunteers, and contractors when they are working on behalf of Foundation for a Path Forward . It requires them to uphold the principles and practices described in this Privacy Notice. The application of this Privacy Notice is subject to applicable laws including legislation, regulations, and the orders or lawful requests of any courts or other lawful authorities.

Definitions

“Client(s)” means an individual(s) who a) is a Foundation for a Path Forward  Donor; b) has requested or used Foundation for a Path Forward  services; c) has given his or her information to Foundation for a Path Forward  for processing; d) has received training by Foundation for a Path Forward  as a volunteer.

“Collection” means the act of gathering, acquiring, noting or obtaining by any other means Personal Information about an individual.

“Consent” means giving permission for the collection, use, and disclosure of Personal Information for certain purposes. Consent can be either express or implied and can be given orally, electronically or in writing. Implied consent is consent that can be reasonably inferred from an action or inaction.

“Disclosure” means making Personal Information available to someone else.

“Donor(s)” means an individual(s) who makes a donation of money to Foundation for a Path Forward  or has indicated to Foundation for a Path Forward  or to its agents an intention to make a donation to Foundation for a Path Forward .

“Personal Information” means any information, recorded in any form, about an identified individual, or an individual whose identity may be inferred or determined from such information, but does not include information that is publicly available, such as business contact information or information found in a telephone directory.

“Use” means the treatment, handling and management of Personal Information

Foundation for a Path Forward Accountability and Safeguards

Foundation for a Path Forward  takes very seriously its responsibility to protect the personal information in our possession. We are accountable to our Clients, Donors, Employees and Volunteers to adopt and regularly review our practices to ensure they align with reasonable business practices appropriate to the level of sensitivity to safeguard personal information against loss or theft, unauthorized access, alteration or disclosure.

How Personal Information is used by Foundation for a Path Forward

Foundation for a Path Forward  collects, safeguards and uses the Personal Information provided by Clients, Donors and others to facilitate assistance and training, activities, and outreach with the goal of assisting those in need in Canada and abroad. Our initiatives include providing and assisting in the provision of:

• Anti-Racism programs;
• Mental Health and wellness and programs;
• Emergency relief and preparedness services and programs;
• Environmental programs;
• Public Safety programs;
• Education programs;
• Professional Development programs;
• Technology programs;
• Training and awareness courses or programs in connection with any of the above

As well as:

• conducting and facilitating fundraising and appeals;
• managing our relationship with Clients and Donors;
• meeting any legal or regulatory requirement of Foundation for a Path Forward ;
• other purposes consistent with the above

Foundation for a Path Forward  collects and uses the Personal Information provided by employees or volunteers to facilitate the employment or engagement relationship as appropriate. Information and personnel records are kept in order to meet legal requirements and maintain relevant information. Information is stored in a secure location, safeguarded and held in strict confidence. Employees may request access to their personnel file and schedule a time to review the file with their reporting Manager. Personnel files are retained for seven years following an employee’s termination of employment.

Contents of a personnel file may include, but are not limited to:

• Job description
• Application and resume
• Contact information
• Signed Employee Handbook Acknowledgement and/or confidentiality statement(s)
• Emergency contacts
• Performance evaluations
• Change of status/address/job transfers
• Letters of commendation/progressive discipline

How Foundation for a Path Forward  uses Donor Personal Information

The Personal Information of Foundation for a Path Forward  is never sold, rented or traded to other organizations

Electronic Donations: The Personal Information of a Donor who donates electronically to Foundation for a Path Forward  via our website is not shared with other organizations.

Mail Solicitation: The Personal Information of a Donor who responds to donation solicitations through the mail will not be shared with other organizations or individuals.

Face-to-Face and Telemarketing: The Personal Information of Donors who donate through face-to-face canvassers is never shared with other organizations.

Text-to-Donate: Foundation for a Path Forward  never receives the Personal Information of individuals who donate to us via a text message sent from their cell phone. The management of these donations is handled via a regulated telecommunications body and Foundation for a Path Forward  only receives the donation itself.

Donations made Directly to a Foundation for a Path Forward  Office: Donors making donations at a Foundation for a Path Forward  branch or zone office are assured their information will not be shared.

Personal Information on Foundation for a Path Forward Website

Foundation for a Path Forward  is the sole owner of the information collected on the www.pennyappeal.ca website (“our website”). Foundation for a Path Forward  collects information from users at several different points on its website. We will not sell, trade, or rent information gathered from our website to others. We use IP addresses to analyze trends, administer the site, track users’ movements, and gather broad demographic information for aggregate use. IP addresses are not linked to personally identifiable information.

Cookies and Web Beacons: For both anonymous visitors and known visitors to our website, we collect information such as the server your computer is logged onto, the domain name of your internet service provider, your browser type and version (for example, Netscape or Internet Explorer) and your IP address. An IP address is a number that is assigned to your computer automatically and required for using the Internet. We may also derive the general geographic area associated with an IP address. We use “cookies”, sometimes in combination with “web beacons” or similar technology to collect information about how this website is used such as average time spent on this website, pages viewed, and information searched for, access times, response rates to online or e-mail advertising and other relevant information about your online experience. If you are an anonymous visitor, the information in this paragraph does not personally identify you but rather numerically identifies your site and we share this cookie’s information with a third party marketing provider that will use it to deliver marketing about us to you while you visit other sites on the internet. Our third-party provider is located in the United States. If you do not want to receive cookies on your computer, you must select the appropriate settings in your browser’s options; however, doing so may limit some of the interactivity our site offers you.

We use AdRoll’s smart pixel. AdRoll may serve you with targeted Ad’s by occasionally placing a cookie on your browser. No information about the visitor will be stored by the Adroll smart pixel. The data that is collected includes:

• Website Activity – what pages you visited while on the website. This helps us understand what pages you were interested in during your visit.
• Device and Browser – This includes browser or device you used to access the website, e.g. device type and IP address.
• Ad Data – This is data about the online adverts AdRoll served (or attempted to serve) you. It includes information such as what page an advert appeared on, the number of times the advert was served to you and if you engaged with the advert.

Please note, none of your personal data will be shared with Adroll.

Links to Other Websites: This website contains links to other sites. Please be aware that Foundation for a Path Forward  is not responsible for the privacy practices of other such sites. We encourage our users to be aware when they leave our site and to read the privacy policy of every website that collects personally identifiable information. This Privacy Notice applies solely to information collected by this website.

Security and Confidentiality on our website: All online transactions and contributions on this site occur through a safe, private, and secure system that protects the on-line Donor’s personal information.

Communication with Donors via email: From time to time we may communicate with a Donor via email. If a Donor does not wish further communication via email, he or she will be given an opportunity to opt out. Members and donors can opt out of receiving any type of emails from us at any time by clicking on the unsubscribe link in the email or by contacting us at info@foundationforapathforward.org

Consent

When an individual chooses to become an Employee, Volunteer, Donor or a Client of Foundation for a Path Forward , he or she is consenting to our collection, use and disclosure of his or her Personal Information in accordance with this Privacy Notice. We may seek additional consent where required by law or in situations where we consider further consent to be necessary or appropriate.

An individual is free to refuse or withdraw his or her consent to the collection, use or disclosure of his or her Personal Information at any time upon reasonable notice in writing to Foundation for a Path Forward . An Employee, Volunteer, Client or Donor may decline to give Foundation for a Path Forward  his or her Personal Information but, in some circumstances, this decision may hinder the Foundation for a Path Forward ’s ability to provide services to the Client or process the donation of the Donor.

Limiting Collection, Use, Disclosure, and Retention

Limitations on Collection and Use: Foundation for a Path Forward  strives to identify the purpose for which it is collecting Personal Information at the time it is collected through oral, electronic, or written means, although in extreme circumstances such as emergency response, it may not be possible to do so immediately. Personal Information will be collected, to the extent possible, directly from the individual concerned. An individual with questions about how Foundation for a Path Forward  collects Personal Information may contact us for more information at the Privacy Contacts listed in Section 9 of this Privacy Notice.

Disclosure: Foundation for a Path Forward  does not disclose the Personal Information of its Employees, Volunteers, Donors or Clients without the stakeholder’s knowledge and consent. In certain rare circumstances, Foundation for a Path Forward  may be permitted or obliged to disclose Personal Information without express consent. These circumstances include but are not limited to:

• where required by law or by order or requirement of a court, administrative agency or other governmental tribunal;
• where we believe, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
• where it is necessary to permit us to pursue available remedies or limit any damages that we may sustain; or
• where the information being disclosed or used is in the public domain.
• where Foundation for a Path Forward is obliged or permitted to disclose information without consent, we will not disclose more information than is minimally required in the applicable circumstances.

Retention: Foundation for a Path Forward  retains personal information as long as necessary for the fulfillment of the identified purposes for its collection or as otherwise necessary to comply with applicable laws. When personal information is no longer necessary or relevant for the identified purposes, or is required to be retained by applicable laws, Foundation for a Path Forward  will take steps to have it deleted, destroyed, erased, aggregated or made anonymous. Foundation for a Path Forward  uses reasonable business practices to ensure we have adequate controls, schedules and practices for information and records retention and destruction which apply to your personal information.

Accuracy and Individual Access

Foundation for a Path Forward  endeavours to ensure that any Personal Information provided to it by Employees, Volunteers, Clients or Donors is as accurate, current, and complete as necessary in order to meet the reason for which it was obtained.

Access: An individual may request access to and review of personal information about themselves that is in the possession of Foundation for a Path Forward . Access will be provided within a reasonable business timeframe unless access is declined for one of the reasons described herein. We reserve the right to decline access to Personal Information where:

• The identity of the person requesting access cannot be confirmed.
• The Personal Information is not readily retrievable and the burden or cost of providing it would be disproportionate to the nature or value of the information;
• The requested Personal Information does not exist, is not held, or cannot be found;
• Disclosure of the Personal Information would compromise the confidentiality of another individual or threaten the safety of another person.
• Non-disclosure of the Personal Information is required or permitted by law.

Requests to Change or Delete Information: An individual may request that Foundation for a Path Forward  change or delete Personal Information about themselves that is in the possession of Foundation for a Path Forward . We reserve the right not to change any Personal Information but will append any alternative text the individual concerned believes appropriate. We will make reasonable business efforts to comply with a request to delete an individual’s Personal Information as long as technological restraints or legal constraints do not limit our ability to fulfill the deletion request.

Where a request for access, alteration, or deletion of Personal Information is declined, the individual making the request will be provided with the reasons for declining the request.

Foundation for a Path Forward Privacy Contacts for concerns or questions

In the event of questions about: (i) access to Personal Information; (ii) the collection, use, management or disclosure of Personal Information by or on behalf of Foundation for a Path Forward ; or (iii) this Privacy Notice, there are several options depending on who you are:

• Employees or Volunteers: Your reporting Manager, Chief Executive Officer or via the Complaints Policy
• Donors: email info@foundationforapathforward.org
• Clients: contact your Fundraising Coordinator/Manager of the region you are in.
• Donors, Clients, or other third parties: email info@foundationforapathforward.org