Yarrow Alliance Church of
The Christian and Missionary Alliance in Canada
Privacy Policy
Yarrow Alliance Church is committed to respecting the privacy of individuals (together “Individuals” or each an “Individual”) comprising its members, attendees, and those who are served by its programs.
In demonstration of our commitment to this privacy goal and in compliance with the Personal Information Protection Act (“PIPA”) Yarrow Alliance has created the following Privacy Policy (the “Privacy Policy”).
The Privacy Policy has been designed to reflect a commitment to the principles outlined in PIPA that are as follows:
1. Accountability
2. Identifying purposes
3. Consent
4. Limiting collection
5. Limiting use, disclosure, and retention
6. Accuracy
7. Safeguards
8. Openness
9. Individual access
10. Challenging compliance
All directors, officers, employees and volunteers of Yarrow Alliance Church are required to comply with the Privacy Policy and may be given restricted access to personal information solely to fulfill the purposes as set out in this Privacy Policy.
All other persons or agents who act on behalf of Yarrow Alliance Church are also required to comply with the principles set out in the Privacy Policy and may be given restricted access to personal information solely to fulfill the purposes as set out in this Privacy Policy.
Privacy Officer
The Yarrow Alliance Church has currently appointed Rev. Dwayne Toews, Assistant Pastor, as its Privacy Officer, who will be responsible for overseeing implementation of the Privacy Policy as well as any inquiries, requests or concerns relating to privacy matters. You may contact the Privacy Officer at the
following address:
Privacy Officer
Yarrow Alliance Church
42479 Yarrow Central Rd.
Chilliwack, B.C.
V2R 5C8
E-mail: info@gffyac.org
Overview
This Privacy Policy covers our treatment of the personal information our personnel collects from our individuals, and any personal information collected by our individuals through our church.
In this Privacy Policy we will outline the purposes behind our collection and use of personal information.
In addition we will outline our policies concerning the collection, use, distribution and retention of this information. Finally we will also set out our policies for addressing any concerns or complaints.
Requests to Add, Change or Delete
If at any time, you wish to add, change or delete your personal information that is retained by Yarrow Alliance Church, please contact our Privacy Officer at:
Telephone: 604 823 6767
e-mail: info@gffyac.org
PRINCIPLE 1 - ACCOUNTABILITY
Yarrow Alliance Church is responsible for personal information which we collect, use or distribute on behalf of Yarrow Alliance and any such personal information in their custody or under their control. In order to fulfill our responsibility and comply with current legislation:
1.1 We have designated a privacy officer who is responsible to oversee our Privacy Policy and ensure
routine compliance with it.
1.2 We shall make known the name or names of the Privacy Officer(s) and contact information upon request.
1.3 We have developed procedures in accordance with this Privacy Policy to govern the handling of personal information and respond to complaints.
1.4 Our Personnel are trained in accordance with this Privacy Policy and committed to taking all
required measures to protect privacy.
1.5 Our Privacy Policy is made available to our Individuals through our website. ()
1.6 If Yarrow Alliance Church makes personal information available to a contracted third party, we will hold that party responsible to maintain comparable levels of protection of privacy while the information is in their control.
PRINCIPLE 2 - IDENTIFYING PURPOSES
2.1 Yarrow Alliance Church is committed to ensuring that the purposes for which personal
information is used are identified.
2.2 Yarrow Alliance Church will only collect personal information from Individuals that is
necessary to fulfill the following purposes:
To verify identity;
To identify individual preferences;
To understand the (financial, banking, insurance) needs of our Individuals;
To deliver requested products and services
To provide counseling services;
To send out membership information;
To contact our individuals for fundraising;
To ensure a high standard of service to our individuals;
To meet regulatory requirements;
2.3 Yarrow Alliance Church will make these purposes known to Individuals at the time that personal information is being collected orally, electronically or in writing.
2.4 Unless required by law, Yarrow Alliance Church will notify and obtain the consent of an Individual before using previously collected information for a new purpose.
PRINCIPLE 3 - CONSENT
3.1 Yarrow Alliance Church will obtain reasonably informed consent of Individuals to collect, use or disclose personal information except where we are authorized to do so without consent.
3.2 Consent can be provided orally, in writing, electronically or through an authorized representative. We will take reasonable steps to ensure that consent given is clearly understood.
3.3 Consent can be implied where the purpose for collecting using or disclosing the personal
information would be considered obvious and any affected person voluntarily provides personal
information for that purpose.
3.4 In general, the acceptance of employment or benefits by an employee, constitutes implied consent for Yarrow Alliance Church to collect, use and disclose personal information for all identified purposes
3.5 Consent may also be implied where Individuals are given notice and a reasonable opportunity to opt-out of his or her personal information being used for Yarrow Alliance Church or other Directory and the person does not opt-out.
3.6 Subject to certain exceptions, Individuals can withhold or withdraw their consent for Yarrow Alliance to use their personal information in certain ways.
3.7 Individuals may not be able to withhold consent when withdrawal of consent would frustrate the performance of a legal obligation.
3.8 Yarrow Alliance Church will not require consent to the collection and use of information in order to access goods or services unless that information is necessary to fulfill the purpose identified. In a situation where a Individual’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 we will explain the consequences of withdrawing consent to assist the Individual in making the decision.
3.9 The following are examples of when we may collect, use or disclose the personal information of an Individual without their consent:
• When the collection, use or disclosure of personal information is permitted or required by law;
• When collection is clearly in his or her best interests and we are unable to obtain his or her consent in a timely way;
• In an emergency that threatens an person’s life, health, or personal security;
• When disclosure is required to comply with a court order;
• When disclosure is required for archival purposes;
• When the personal information is available from a public source (e.g., a telephone directory);
• When the personal information is available through observation at a public event to which you attended voluntarily;
• When the collection, use or distribution is necessary to determine your suitability to receive an honour, award or similar benefit or to be selected for an athletic or artistic purpose;
• When collection is required for an investigation into alleged moral failure;
• 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.
PRINCIPLE 4 - LIMITING COLLECTION
4.1 Yarrow Alliance Church shall limit the collection of personal information to the purposes set out in this Privacy Policy in compliance with our legal obligations.
4.2 Yarrow Alliance Church will not collect personal information indiscriminately.
4.3 The purposes for collecting personal information shall be reasonably clear at the time of collection and we will not deceive or mislead our Personnel as to why information is being collected.
PRINCIPLE 5 - LIMITING USE, DISCLOSURE AND RETENTION
5.1 Yarrow Alliance Church will only use and disclose personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes except where we are authorized to do so (see Principle 3 – Consent).
5.2 Yarrow Alliance Church will not use or disclose personal information for any additional purpose unless, directly or indirectly we obtain consent to do so.
5.3 Yarrow Alliance Church will not sell Individuals’ names lists or personal information to other parties without consent.
5.4 Yarrow Alliance Church will only retain personal information as long as it is needed for the purposes for which it was collected or consented to. Yarrow Alliance Church will maintain reasonable schedules to ensure that personal information is reviewed on an ongoing basis to determine relevance and if retention is required.
5.5 When personal information collected is no longer relevant to its purpose or when it is permitted by law, Yarrow Alliance Church will ensure that it is deleted, destroyed or made anonymous. In general, all personal information shall be deleted, destroyed or made anonymous no later than seven years after the purpose for which it was collected has been completed unless the law requires otherwise.
5.6 If Yarrow Alliance Church uses personal information to make a decision that directly affects an Individual we will retain that personal information for at least one year to give that Individual a reasonable opportunity to request access to it.
PRINCIPLE 6 - ACCURACY
6.1 Yarrow Alliance Church is committed to ensuring the accuracy of its information and will take reasonable efforts to ensure that personal information is accurate and complete where it is necessary.
6.2 Yarrow Alliance Church will update information when it is necessary or when an Individual notifies us. Personnel may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought. This request should be directed to the Privacy Officer.
PRINCIPLE 7 - SAFEGUARDS
7.1 Yarrow Alliance Church is concerned about the safety of personal information. In order to address security concerns, we have developed the following safeguards:
• Physical security measures including locked cabinets, restricted access to areas where sensitive personal information is kept, security alarm systems, and other similar measures instituted from time to time;
• Yarrow Alliance Church security measures including employee confidentiality agreements, sensitive information restricted to those involved, and other similar measures instituted from time to time; and
• Technological security measures including use of passwords, firewalls and security encryptions.
7.2 Yarrow Alliance Church shall protect personal information disclosed to third parties by contractual agreement that stipulates the confidentiality and safeguard requirements that are comparable to our own.
7.3 We will use appropriate security measures when destroying personal information such as
• Shredding any documents containing personal information;
• Deleting any electronic records containing personal information;
7.4 Yarrow Alliance Church will routinely review and update our security measures.
7.5 Yarrow Alliance Church will stress to all Personnel the importance of safeguarding the
confidential nature of personal information.
PRINCIPLE 8 - OPENNESS
8.1 Yarrow Alliance Church is committed to making its privacy policies and procedures available and clear to all interested parties.
8.2 We will demonstrate our commitment to this openness by making the Privacy Policy easy to
access and by making the name and contact information of our Privacy Officer readily available.
8.3 Any questions or concerns regarding our policy or procedure may be directed in writing to our Privacy Officer.
PRINCIPLE 9 - INDIVIDUAL ACCESS
9.1 Individuals have a right to access their own personal information, subject to limited exceptions including, but not limited to:
• Situations of solicitor-client privilege;
• Situations where disclosure may reveal the personal information of another person;
• Situations where the health or safety of a person may be jeopardized.
9.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought and should be forwarded to the attention of the Privacy Officer. We will make the requested information available within 30 days, or provide written notice of an extension where additional time is required to fulfill the request. A reasonable fee may be charged for providing access to personal information, in which case we will inform the Individual prior to proceeding.
9.3 We will endeavour to make all information provided easy to understand and explain any acronyms, abbreviations, etc. used.
9.4 We reserve the right to confirm the identity of the Individual seeking access to personal information before complying with any access requests. In this event, information related to the Individual’s identity would be used exclusively for the purposes of confirming access.
9.5 In certain situations, it may not be possible to provide access to all the personal information that is held and a request may be refused in whole or in part. For example, information may not be provided if to do so would reveal personal information about a third party or jeopardize the security of another.
9.6 If a request is refused in full or in part or if the information requested is not available, we will
notify the Individual in writing, providing the reasons for refusal and the recourse available to the
Individual. This notification will be kept on file.
9.7 If personal information provided is shown to be incomplete or inaccurate, we will amend the Individual’s personal information appropriately. When appropriate, we will transmit this correction to third parties with access to this information. When a challenge is not resolved to the Individual’s satisfaction, we will either correct the personal information in issue or destroy all personal information under our care and control, at the option of the District Office.
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PRINCIPLE 10 - CHALLENGING COMPLIANCE
10.1 Complaints made regarding the Privacy Policy or the use of personal information must be made to the Privacy Officer in writing.
10.2 The Privacy Officer will receive and respond to all personal information requests including
challenges or complaints.
10.3 It is Yarrow Alliance Church’s policy that all complaints will be investigated.
10.4 If a complaint is found to be justified, the Privacy Officer will take appropriate measures,
including, if necessary, amending this Privacy Policy.
10.5 The Privacy Officer may seek advice from professionals or others where appropriate before
providing a final response to individual complaints.
10.6 If the Privacy Officer is the subject of the complaint, then Yarrow Alliance Church will address any complaints or concerns. If the Privacy Officer (or, in the case of a complaint against the Privacy Officer, the Chairman) is unable to resolve the concern, the affected individual of the Personnel may also write to the Information and Privacy Commissioner of British Columbia.
10.7 Yarrow Alliance Church's procedure for dealing with complaints involving personal
information is as follows:
• Record the date and nature of a complaint when it is received;
• Acknowledge receipt of the complaint promptly;
• Review the matter fairly and impartially, providing to the Individual where possible, access to all relevant records;
• Notify the Individual of the outcome of the investigation promptly and clearly; and
• Correct any inaccurate or incomplete information when possible.
10.8 The contact information for the Privacy Officer is as follows:
Privacy Officer
Yarrow Alliance Church
42479 Yarrow Central Rd.
Chilliwack, B.C.
V2R 5C8
Telephone: 604 823 6767
E-mail: info@gffyac.org
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