The Canadian Hard of Hearing Association (CHHA) and its entities are committed to protecting the privacy of our clients, members, employees, donors, volunteers, members and other stakeholders. We value your trust and recognize that maintaining this trust requires us to be transparent and accountable in how we treat the personal information shared with us.
During the course of our various activities, we frequently gather and use personal information. This information may be obtained directly from you or collected from third parties that have the right to disclose this information to us. Our policy regarding how personal information entrusted to us is collected, used, disclosed or retained reflects the principles set forth in the Personal Information Protection and Electronic Documents Act (Canada).
What is personal information?
Personal information is any information that contributes to the identification of an individual and includes details that can be used to distinguish, identify or contact a specific individual.
Business contact information and certain publicly available information, such as names, addresses and telephone numbers as published in telephone directories, are not considered personal information in this context.
Personal information collected by CHHA
CHHA collects personal information to support program and service delivery, to establish, maintain and manage our relationship with our clients, members, employees, donors, volunteers and members, and for research, fundraising, public education and advocacy purposes.
CHHA collects personal information when an individual:
- Registers to access CHHA services
- Registers for an event
- Participates in any interactive feature of our websites
- Makes a donation online
- Purchases a product online
- Becomes an employee or volunteer
- Contacts us with an enquiry, comment or suggestion
- Subscribes to a mailing list or newsletter
Personal information collected may include:
- Contact information such as home address, telephone number, e-mail address (when e-mail message was sent to CHHA through the website, the time the message was sent and the IP address from which it was sent is automatically collected)
- Demographic information such as age and gender
- Hearing health information
- Credit card or bank account information
- Language and communications preferences
- Service or event-specific information such as name and phone number of an emergency contact individual, dietary restrictions and accommodation preferences.
Use of personal information
Clients, Members and Customers
Registering for a service or event
When a client, member or customer registers for a CHHA service or event, or purchases a product, they may be asked for personal information such as name, email address, mailing address, phone number emergency contact information, special dietary requirements and accommodation preferences.
We collect this information to facilitate participation in the event and to provide the services requested. We will use the emergency contact information only as required in the event of an emergency.
When an individual registers with CHHA for services, or is referred by their doctor for same, information about their hearing health is collected.
This information is collected to identify the individual, recommend/deliver specific services or technical aids, or for research purposes. Personal information may be used to contact the individual or the individual’s parent(s) and/or legal guardian(s) when necessary. With the individual’s permission, CHHA may also send them information about other products or services of interest. An individual may opt out of receiving such communications at any time by contacting us as set out in the “Contact us” section below.
When registering online, the individual may choose to provide CHHA with information about their personal interests. We use this information in order to send the individual information geared to their interests. An individual may change their personal interests at any time by updating their profile.
CHHA may sometimes use e-mail addresses and phone numbers to investigate activity that may violate the terms of acceptable use associated with a particular CHHA service offering.
Employees and Volunteers
Access by employee and volunteer to their personal information
Access to personal information is restricted to authorized employees who have a legitimate reason to access it. An employee or volunteer may access and verify his/her personal information subject to some exceptions, for example, the law requires that we refuse access to information that would reveal personal information about another individual. If access is refused, the reason for refusal will be provided.
Employees’ personal information
CHHA uses personal information about employees in order to establish, manage and terminate the employment relationship. This includes:
- Personal information collected in the hiring process, including information on resumes and application forms (contact information, personal and professional history, qualifications, emergency contact information, results of criminal records checks, information collected from references)
- Payroll information including, social insurance number, rate of pay, hours of work, deductions, bank account information, any court orders
- Benefit information including premiums or contributions, coverage information, date of birth, marital status, dependent information, medical information
- Performance information including work history, performance reviews, discipline and related notes, documentation on job qualifications, internal competition information
- For other purposes identified when the information is collected.
Volunteers’ personal information
CHHA uses personal information about volunteers for the purposes of recruiting volunteers, establishing and managing an effective volunteer program, and for other purposes identified when the information is collected. This includes:
- Personal information collected in the recruiting process including information on application forms (contact information, personal and professional history, qualifications) and information collected from references
- Information related to the volunteer’s services including availability, schedule, duties, and notes related to volunteer qualifications
Donors and other stakeholders
When a donation is made, CHHA collects the donor’s name, address, and credit card or bank information for the purpose of processing the donation and issuing a tax receipt. As a form of appreciation, and to remind others of the ongoing need for support, CHHA may publicly recognize the donor’s name, unless the donor indicates their preference not to be recognized in any way. The donor’s name may be published in association with the range of the dollar amount of the donation.
Donations may also be made in honour or in memory of someone, or to sponsor a participant in one of our events. CHHA collects personal information about the recipient of the donation, or the family of the recipient in the case of a donation in memory, such as their name, addresses and contact information. We collect this personal information in order to notify the recipient of the donation. We do not use or disclose the recipient’s personal information for any other purpose unless they give us permission to do so. The donor has the option to decide whether they would like to be identified as the sender of the donation. We do not publish the amount of any donation made in honour or in memory. As the sponsor of a participant in one of our events, the donor has the option to decide whether or not the amount of the donation may be publicly available.
Opportunity to provide CHHA financial support
CHHA may occasionally provide its clients, members, employees, volunteers and other stakeholders with the opportunity to donate to CHHA through our direct mail, telemarketing or other fundraising programs. We collect and keep only as much personal information about donors and prospective donors as we need in order to raise funds efficiently. To ensure we offer opportunities of interest to the individual, our philanthropy staff will know you are a client, the year you became a client, and which services you use.
You may opt out of receiving donation opportunities by contacting us as set out in the “Contact us” section below.
Mailing lists and newsletters
If an individual signs up for a newsletter, CHHA uses their email and/or home address, as applicable, to send the newsletter and other information requested. CHHA provides regular communications to its clients, members, employees, donors, volunteers and other stakeholders through both regular postal mail and electronic mail. Any personally identifiable information provided by you will be used for the purpose of delivering the mailing item, research and/or marketing.
An individual may opt out of receiving such communications at any time by contacting us as set out in the “Contact us” section below.
The “help” portion of the toolbar on most browsers shows how to prevent the browser from accepting new cookies, how to have the browser notify when a new cookie is received, or how to disable cookies altogether.
Disclosure of personal information
We will disclose an individual’s personal information internally only to employees and volunteers who need to know in order to provide and support the services the individual has requested.
From time to time CHHA conducts research through surveys, interviews with clients/members or by using CHHA member information. In all cases clients/members are informed that the information they are providing is being used for research purposes only and that all information will be kept confidential. Participants are given a unique study ID number that is anonymous and not identifiable. All data and recordings of interviews are restricted to members of the research team. There is no disclosure of participant information to outside people or researcher organizations outside CHHA and no names are used in any discussion within the research team. Clients’/members names are not included in any printed material that is part of the research study, or in any publications concerning the research. All information acquired during the research is saved in a locked folder on a CHHA internal database. Only members of the research department have access. Audio files are deleted once they have been transcribed to the secure database.
Client/members lists are not provided to outside organizations for the purpose of research. On occasion, CHHA will contact members on behalf of an external organization or agency and ask if they are willing to participate in research conducted by an outside agency. They are fully informed that their participation is entirely voluntary, is confidential and is in no way linked to their rehabilitation therapy at CHHA.
Employee and volunteer personal information
CHHA may disclose personal information of an employee or volunteer to others solely in connection with the purpose for which the information was collected, as consented to by the individual, or as required or permitted by law.
If an employee or volunteer wishes to limit the sharing of their personal information as permitted by law, the individual may submit a request to the Privacy Officer specifying which items of personal information are to be limited and to whom these items are to be restricted. The Privacy Officer will advise the individual whether the requested information can be restricted as requested.
Outside service providers
The term ‘outside service provider’ includes vendors, consultants and service delivery partners or agencies.
CHHA may contract with outside service providers to perform certain services on its behalf. These organizations are given only the information necessary to perform those services, and we take steps to ensure that such information is securely transferred and stored and is used only for the purposes intended.
Service providers with whom we share personal information may perform activities in the United States or another country in which case personal information is subject to laws in the United States or that other country. For example, personal information may be shared in response to valid demands from government authorities, courts and law enforcement officials in the country where the data resides.
CHHA agreements with service providers set out our expectations regarding privacy and protection of personal information; specifically, they require that the service provider:
- Maintain the confidentiality and security of personal information provided by CHHA and use it only in compliance with applicable privacy laws.
- Prohibit access, use or disclosure of personal information for any purpose other than providing the services covered by the agreement.
- Report immediately to CHHA any access, use or disclosure of personal information provided by CHHA other than for the provision of the services covered by the agreement.
- Provide access controls and safeguards for the secure management, retention and destruction of personal information provided, as applicable.
- Consistent with CHHA’s legal obligations to protect the privacy of personal information in its care, the service provider affords CHHA the right to audit its compliance with our privacy requirements or provide a copy of its most recent independent information security and/or privacy audit.
CHHA will not provide personal information to an outside service provider if de-identified or aggregate information will serve the purpose.
CHHA and our service providers may provide personal information in response to a legal requirement to do so, or in the case of a breach of agreement or infringement of law to a fact-finding entity, or as otherwise required or permitted by law.
From time to time CHHA exchanges the names and addresses of its donors with other like-minded charities to further our fundraising efforts. As a matter of course, CHHA routinely provides its donors the opportunity to decline the use of their name and address for such purposes. A donor can also opt out of the program by contacting us as set out in the “Contact us” section below.
Social Media / Forums
If you voluntarily submit or post any information, photographs or other content to any CHHA forums, Twitter pages, Facebook pages or other social networking pages/sites, certain elements of your personal information may be automatically included in the posting, including your user name and email address, and this information may be collected and used by others. CHHA has no control over and is not liable for the collection, use or disclosure of any posted user content by users of such forums and social media networking pages. Any personal information posted, used or disclosed via such sites is not subject to this Policy.
CHHA may disclose your personal information to a government institution that has asserted its lawful authority to
obtain the information or where we have reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the disclosure of information, or to comply with court rules regarding the disclosure of records and information, or to protect the rights and property of CHHA or otherwise as permitted or required by law.
Security – Safeguarding personal information
CHHA takes reasonable measures to ensure that our systems keep personal information safe from loss or theft, unauthorized access, use, copying, disclosure or modification. Safeguards include but not limited to:
- Designated systems security officer accountable for information security controls and ongoing oversight to strengthen CHHA information security
- Firewalls, intrusion-detection, anti-virus, strong passwords, inactivity based screen lock, mandatory PDA access control and other software solutions for technical security
- Confidentiality sign-off by all employees
Retention and disposal of personal information
The length of time CHHA keeps personal information varies depending on the service and the type of information. Personal information is kept for as long as it may be reasonably needed for service, research, legal or business purposes. When personal information is no longer required for these purposes, it is securely destroyed or deleted.
Access to and correction of personal information
Individuals have the right to access and correct inaccuracies in the personal information CHHA has about them in our records. To do so, they should contact CHHA as described in the “Contact us” section below. To protect individual privacy, CHHA will take reasonable steps to help verify the individual’s identity before granting access or making corrections to personal information.
Linking to outside websites
Links to third-party websites from CHHA website are provided for the convenience of our users. CHHA has no control over, and therefore has no responsibility or liability for, the manner in which the organizations that operate such linked websites may collect, use, disclose or otherwise treat your personal information. The inclusion of any link does not imply CHHA’s endorsement of any other organization, its websites, or its products and/or services.
To review or update one’s personal information in CHHA’s possession, or withdraw consent for the collection, use and/or disclosure of one’s personal information or name from an email or other mail list, please contact us at:
Canadian Hard of Hearing Association
901-75 Albert Street
Ottawa, ON K1P 5N7
Further information on privacy in general and on individual rights in regard to personal information is available on the website of the Privacy Commissioner of Canada.