PRIVACY POLICY AND INFORMATION – INTERNATIONAL SIVANANDA YOGA VEDANTA CENTRES CANADA
International Sivananda Yoga Vedanta Centre’s code is based on the CSA Model Code for the Protection of Personal Information (CAN/CSA-Q830-96). This code describes International Sivananda Yoga Vedanta Centre’s commitment and methods of subscribing to the principles of the CSA Model Code.
PURPOSE
International Sivananda Yoga Vedanta Centre recognizes the right of an individual to the protection of personal information and the need for information management practices that adhere to national standards. International Sivananda Yoga Vedanta Centre will ensure that its policies and operational guidelines, directed by the principles of the CSA Code, govern the management of personal information of its members, donors, staff and volunteers.
SCOPE
This policy will be applied to all personal information collected, used or disclosed, whether factual or subjective, about an identifiable individual during the course of commercial activities. It is the responsibility of International Sivananda Yoga Vedanta Centre Canadian Section (English Speaking) to ensure that those individuals, groups/organizations and/or businesses that have been approved, designated or contracted to act for or on its behalf are aware of and in compliance with the principles set forth in the Privacy Policy of International Sivananda Yoga Vedanta Centre Canadian Section (ES) [AICS (ES)].
DEFINITIONS
PERSONAL INFORMATION
Factual or subjective information, recorded or not. This can include, but is not limited to, age, name, addresses, e-mail addresses, giving history, financial information, identification numbers, income, ethnic origin, sexual orientation, opinions, evaluations, comments, disciplinary actions, employee files, loan records, medical files or documentation of a dispute.
COMMERCIAL ACTIVITY
Any particular transaction, act or conduct or any regular course of conduct that is of a commercial character, including the selling, bartering or leasing of donor, membership or other fundraising lists.
CONSENT
Voluntary agreement with what is being done or proposed. Consent can be either express or implied. Express consent is given explicitly, either orally or in writing. Express consent is unequivocal and does not require any inference on the part of the organization seeking consent. Implied consent arises where consent may reasonably be inferred from the action or inaction of the individual.
PRIVACY CODE
Taken from “Your Privacy Responsibilities” Canada’s Personal Information Protection and Electronic Documents Act”, December 2000.
ACCOUNTABILITY
International Sivananda Yoga Vedanta Centre recognizes that it is responsible for all personal information under its control. This includes, but is not limited to, information in any form be it verbal, print or electronic document, such as age, name, address, telephone numbers, e- mail addresses, identification numbers, income, ethnic origin, opinions, evaluations, social status, credit records, and recordings of disputes between the organization and a donor/member.
International Sivananda Yoga Vedanta Centre will ensure that a privacy protection clause be included in contracts with individuals/organizations both inside and outside the scope of the organization. The organization will be guided by the principles outlined in its Privacy Code in the daily development, administration, management and evaluation of personal information under its care.
In order to ensure compliance of this Privacy Code, International Sivananda Yoga Vedanta Centre shall designate an individual or individuals to be responsible for the implementation of and adherence to the following principles. The requirements for this candidate shall be outlined in the “Operational Guidelines” of International Sivananda Yoga Vedanta Centre’s Privacy Policy.
IDENTIFYING PURPOSES
International Sivananda Yoga Vedanta Centre and those designated or contracted to act for or on its behalf, shall identify the purposes for which personal information is collected at or before the time the information is collected. International Sivananda Yoga Vedanta Centre will attempt to document and clearly define the purpose or purposes intended for personal data before it is collected and will always ensure that it is present at the time of its collection. International Sivananda Yoga Vedanta Centre will only collect information that it views as a necessity in order to fulfill the identified purpose. Any secondary or optional uses of information by the organization will be identified and individuals will be provided with an opportunity to reject or accept such uses.
International Sivananda Yoga Vedanta Centre will make every attempt to ensure that the purposes and uses of information it collects will be presented in easy and straightforward language. It will clearly identify why this information is needed and how it will be used. All materials used by International Sivananda Yoga Vedanta Centre or those designated to work for it on its behalf, to collect information will present the purpose, need and use in a manner that is understandable to whomever it is intended.
Methods and procedures to ensure that all relevant materials used to collect personal information adhere to the “Identifying Purposes Principle” will be outlined in Operational Guidelines. These guidelines will assist individuals within the organization in directing inquiries or complaints regarding purposes of collection to the appropriate individual or individuals. International Sivananda Yoga Vedanta Centre recognizes the diversity of its members and donors’ needs and will apply this to its operational guidelines.
CONSENT
International Sivananda Yoga Vedanta Centre and those designated or contracted to act for it or on its behalf will ensure that the knowledge and consent of the individual are obtained for the collection, use, or disclosure of personal information, except where inappropriate. International Sivananda Yoga Vedanta Centre has a responsibility to provide explanation in clear, simple and understandable language of the intended uses and impacts and to obtain consent before the information is used. The organization will provide this explanation on all appropriate forms, contracts and publicly available forms. Specific adherences to this principle will be outlined in the Operational Guidelines.
Consent may be express or implied dependent upon the particular situation. However, International Sivananda Yoga Vedanta Centre will attempt to obtain express consent, where possible.
International Sivananda Yoga Vedanta Centre recognizes the right of individuals to prevent their personal information from being provided to other organizations on a reciprocal basis for the purpose of fundraising. International Sivananda Yoga Vedanta Centre will present its members and donors an opportunity to opt-out of such exchanges annually through its direct mail program. International Sivananda Yoga Vedanta Centre will not disclose any personal information without providing an opportunity for individuals to opt-out.
International Sivananda Yoga Vedanta Centre recognizes that individuals have the right to withdraw consent to personal information use at any time. International Sivananda Yoga Vedanta Centre will provide its members/donors with an opportunity to opt-out of name exchanges annually and an opt-out option from receiving mail every three years. However this principle is subject to legal and contractual restrictions and reasonable notice.
In addition this principle is exempt in particular circumstances where criminal investigations, legal or security situations, medical emergencies or mental or physical incapacities arise. However, International Sivananda Yoga Vedanta Centre will approach these situations with great caution and care.
LIMITING COLLECTION
International Sivananda Yoga Vedanta Centre shall ensure that the collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means. International Sivananda Yoga Vedanta Centre will collect information in a straightforward and honest manner and with the individual’s consent. It will not collect information in an indiscriminate manner. Information will not be collected from other individuals associated with the person such as family members or friends without the consent and knowledge of the individual and only in situations that are deemed to be most compelling.
LIMITING USE, DISCLOSURE AND RETENTION
International Sivananda Yoga Vedanta Centre shall ensure that personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes. International Sivananda Yoga Vedanta Centre will ensure that consent for personal information use is applied only to purposes agreed to initially by the individual. The use of the information will be presented clearly to the individual. In circumstances where potential purposes of use of information may appear as complex, all potential options of future use should be presented and an option to have one’s information either included or removed should be clearly presented. International Sivananda Yoga Vedanta Centre will ensure that any inquiries regarding the organization’s purposes of use and practices of disclosure are responded to in an open and honest fashion.
International Sivananda Yoga Vedanta Centre’s practices and procedures regarding the retention of personal information will be clearly outlined in its Operational Guidelines, including minimum and maximum retention periods.
ACCURACY
International Sivananda Yoga Vedanta Centre shall ensure that personal information under its care be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. Opportunities for individuals to inquire about and review their personal information, which they have consented to provide to International Sivananda Yoga Vedanta Centre, will be made readily available following appropriate notice. Individuals will be provided an opportunity to update or correct personal information which is outdated or inaccurate.
SAFEGUARDS
International Sivananda Yoga Vedanta Centre shall ensure that personal information shall be protected by security safeguards appropriate to the sensitivity of information. International Sivananda Yoga Vedanta Centre shall take all reasonable means necessary to ensure that all personal information under its care is protected against loss or theft, unauthorized access, disclosure, copying, use or modification. This includes but is not limited to physical, organizational and technological means. Specific measures and procedures will be outlined in the Operational Guidelines.
OPENNESS
International Sivananda Yoga Vedanta Centre shall make readily available to individuals specific information about its policies and practices relating to the management of personal information. International Sivananda Yoga Vedanta Centre will ensure that its policies and procedures regarding personal information are simple, clear and easily accessible in a variety of forms including electronically and in print. In addition, it will also make available a copy of the CSA Guidelines within its Policy Manual.
Access to these materials, along with access to the individual or individuals responsible for compliance with the Privacy Policy, should remain readily available to those who inquire.
INDIVIDUAL ACCESS
International Sivananda Yoga Vedanta Centre agrees to ensure that upon request an individual shall be informed of the existence, use, and disclosure of their personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate. Requests by individuals regarding the type of information International Sivananda Yoga Vedanta Centre maintains, its uses and to whom it has been disclosed, will be responded to in an honest and timely fashion.
If, in certain circumstances, International Sivananda Yoga Vedanta Centre is not able to provide certain information, an explanation outlining the reasons must be provided to the individual in writing. Exceptions to providing this information should be limited and specific. These may include but are not limited to cost, references to other individuals or for reasons of legal, security or litigation privilege.
PROVIDE RECOURSE
International Sivananda Yoga Vedanta Centre agrees to ensure that an individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization’s compliance.
International Sivananda Yoga Vedanta Centre will make every effort to respond openly to inquiries or complaints regarding its management, collection and disclosure of personal information.
It will make readily available the name, title and access information for the individual responsible for the organization’s compliance with the Privacy Policy. In the case of public documents such as membership forms/pamphlets, the title and contact information will be provided.
International Sivananda Yoga Vedanta Centre will ensure that every complaint is investigated and that the appropriate actions required to rectify the situation will be taken.