PRIVACY NOTICE
Effective Date: 2020 March 01
Broad Reach Foundation (“BRF”) is committed to protecting the privacy and security of your personal information. This Privacy Notice describes how BRF collects and uses personal information about you during and after your involvement with BRF. This Privacy Notice applies to current and former volunteers, staff, and board members of BRF located in Canada.
This Privacy Notice describes the categories of personal information that we collect, how we use your personal information, how we secure your personal information, when we may disclose your personal information to third parties, and when we may transfer your personal information outside of Canada. This Privacy Notice also describes your rights regarding the personal information that we hold about you and how you can access, correct, and request erasure of your personal information.
We will only use your personal information in accordance with this Privacy Notice unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.
Collection of Personal Information
For purposes of this Privacy Notice, personal information means any information about an identifiable individual, as may be defined or limited under applicable privacy legislation. Personal information excludes anonymous or de-identified data that is not associated with a particular individual. Personal information also excludes business contact details and job titles. To carry out our activities and obligations as BRF, we may collect, store, and use the following categories of personal information, which are required for us to administer our relationship with you:
Personal contact details such as name, title, addresses, telephone numbers, and personal email addresses.
Date of birth.
Gender.
Emergency contact information.
Government identification numbers such as driver’s license number, health card number, or other
identification card number.
Performance information.
Education and training.
Employment records (including professional memberships, references, work history, and proof of work eligibility).
Photographs.
Results of background checks.
Other personal details included in a resume or cover letter.
Use of Personal Information
We only use your personal information where applicable law permits it, or when the use is necessary to comply with a legal obligation that applies to BRF. We may use your personal information for the following legitimate purposes:
Management and planning.
Processing insurance claims.
Accounting and auditing.
Conducting performance reviews and determining performance requirements.
Assessing qualifications for a particular job or task.
Gathering evidence for disciplinary action.
Complying with applicable law.
Education, training, and development requirements.
Complying with health and safety obligations.
We will only use your personal information for the purposes we collected it. If we need to use your personal information for an unrelated purpose, we will provide notice to you and, if required by law, seek your consent. We may use your personal information without your knowledge or consent where required by applicable law or regulation.
Data Sharing
We will only disclose your personal information to third parties where required by law or to our contractors, designated agents, or third-party service providers who require such information to assist us with administering your relationship with BRF, including third-party service providers who provide services to us or on our behalf. These third-party service providers may be located outside of Canada.
We require all our third-party service providers to implement appropriate security measures to protect your personal information consistent with our policies and any data security obligations applicable to BRF. We do not permit our third-party service providers to use your personal information for their own purposes. We only permit them to use your personal information for specified purposes in accordance with our instructions.
We may also disclose your personal information for the following additional purposes where permitted or required by applicable law:
To comply with legal obligations or valid legal processes such as search warrants, subpoenas, or court orders. When we disclose your personal information to comply with a legal obligation or legal process, we will take reasonable steps to ensure that we only disclose the minimum personal information necessary for the specific purpose and circumstances.
During emergency situations or where necessary to protect the safety of persons.
Where the personal information is publicly available.
For additional purposes with your consent where such consent is required by law.
Cross-Border Data Transfers
Where permitted by applicable law, we may transfer the personal information we collect about you to the United States and other jurisdictions that may not be deemed to provide the same level of privacy
protection as Canada, as necessary to assist us with administering your relationship with BRF, and for the purposes set out in this Privacy Notice.
Data Security
We have implemented appropriate physical, technical, and organizational security measures designed to secure your personal information against accidental loss and unauthorized access, use, alteration, or disclosure. In addition, we limit access to personal information to those agents, contractors, and other third parties that have a legitimate need for such access.
Data Retention
Except as otherwise permitted or required by applicable law or regulation, we will only retain your personal information for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate purpose without further notice to you or your consent.
Rights of Access, Correction, Erasure, and Objection
It is important that the personal information we hold about you is accurate and current. Please keep us informed if your personal information changes during your involvement with BRF. By law you have the right to request access to and to correct the personal information that we hold about you, or withdraw your consent to the use of your personal information under certain circumstances. If you want to review, verify, correct, or withdraw consent to the use of your personal information, please contact “info@sailbroadreach.ca”.
We may request specific information from you to help us confirm your identity and your right to access, and to provide you with the personal information that we hold about you or make your requested changes. Applicable law may allow or require us to refuse to provide you with access to some or all of the personal information that we hold about you, or we may have destroyed, erased, or made your personal information anonymous in accordance with our record retention obligations and practices. If we cannot
provide you with access to your personal information, we will inform you of the reasons why, subject to any legal or regulatory restrictions.
Right to Withdraw Consent
Where you have provided your consent to the collection, use, and transfer of your personal information, you may have the legal right to withdraw your consent under certain circumstances. To withdraw your consent, if applicable, contact “info@sailbroadreach.ca”.
Data Privacy Contact
If you have any questions about this Privacy Notice or how we handle your personal information, or would like to request access to your personal information, please contact “info@sailbroadreach.ca”.
Changes to This Privacy Notice
We reserve the right to update this Privacy Notice at any time, and we will provide you with a new Privacy Notice when we make any updates. If we would like to use your previously collected personal information for different purposes than those we notified you about at the time of collection, we will provide you with notice and, where required by law, seek your consent, before using your personal information for a new or unrelated purpose. We may use your personal information without your knowledge or consent where required by applicable law or regulation.
RECORDED PROGRAMS
We may choose to record activities such as panel discussions, webinars, workshops and other related programs. This might consist of: (1) pre-recorded content (created by instructors or guest speakers) that can be viewed at any time; (2) pre-recorded learning content (created by project participants) including oral presentations, group discussions, or testimonials; and (3) recordings that occur while participants take part in live-streamed activities.
With the exemption of pre-recorded learning content created by instructors or presenters, the above activities may put participants in a position of having their information recorded in a number of ways, either through their direct participation (e.g. video, audio, chat) or through indirect means (i.e. online identifier, such as name or telephone number.) These conditions raise privacy concerns that should be taken into account. Before engaging in any such activity, we have considered the following:
NOTICE FOR RECORDING:
Notice of recording will be prominently displayed on all program registration forms. Additionally, a notice of recording will also be given at the beginning of every activity that is expected to be recorded.
ALTERNATIVES
Participants who do not wish to be recorded, those in significantly different time zones, those who do not have the technological means to participate, or those who would be disadvantaged in any way by video/audio recording, will be offered an alternative method of participation.
STORAGE AND DISPOSAL
Recordings will not be stored long term on presenters or instructors personal devices, even if the device is encrypted or password protected. Overtime, recordings that are stored on personal devices may be forgotten which then can pose a risk for inadvertent access or disclosure of personal information.
Program recordings will be kept in accordance with Broad Reach records classification and retention schedules, then securely disposed of when they are no longer needed.
LIMITATION AND RISK
Recording is not without limitation and risk which may include: (1) limitation to ensuring privacy security of information despite reasonable efforts; (2) unauthorized copying and disclosure, disclosure as required by law; and (3) introduction of malware into computer system, which could potentially damage or disrupt computer, networks and security settings. We are not responsible for connectivity/ technical difficulties or loss of data that is associated with the student’s hardware, software or internet connection.
Broad Reach Canada
20 Lower Spadina
Suite 304
Toronto ON M5V 2Z1
We acknowledge that our office is situated upon traditional territories. The territories include the Wendat, Anishinabek Nation, the Haudenosaunee Confederacy, the Mississaugas of the Credit First Nations, and the Métis Nation.
