POLICY INTRODUCTION:
The University Hospital Foundation (the “Foundation”) values its reputation for honesty, integrity, and the faithful discharge of the public trust and confidence. Foundation board members (“Trustees”), employees and volunteers are expected to conduct themselves and the work they perform on behalf of the Foundation in a manner that honors that reputation and does not detract from the public’s trust and confidence.
POLICY STATEMENT
The University Hospital Foundation respects and protects the privacy and confidentiality of our donors and is committed to protecting private information under our control. The Foundation will take all reasonable precautions to ensure that information provided to us will be secure and protected from loss, misuse, unauthorized access, disclosure, alterations, and destruction.
The Foundation collects a limited amount of personal information about its donors and potential supporters, including name, title, address, email address, telephone number, past donations and other relevant contact information. This personal information is collected for the following purposes:
• to comply with Canada Revenue Agency requirements,
• to provide donors with periodic stewardship information,
• to provide donors with appropriate recognition by the Foundation,
• to provide donors and potential supporters with information about the University of Alberta Hospital’s, the University of Alberta’s, and the University Hospital Foundation’s activities, and
• to promote opportunities where donors and potential supporters may support the Foundation.
SCOPE
The University Hospital Foundation (the “Foundation) is committed to protecting the privacy of the personal information of its constituents (donors, volunteers, visitors and staff) and is committed to respecting and protecting their personal information. The Foundation strives to ensure that information in any format (paper or electronic) is protected so that the relationship of trust between the constituent and the Foundation is upheld. Accordingly, the Foundation facilitates actions and processes to meet or exceed all provincial and federal legislative requirements with respect to privacy and embraces ethical guidelines established by the Association of Fundraising Professionals, the Association of Healthcare Philanthropy and the Canadian Association of Gift Planners. Our privacy policy adheres to the ten internationally recognized privacy principles that address the way the Foundation collects, uses, discloses, and protects personal information; and the right of the individuals to have access to personal information about themselves, and, if required, to have the information corrected.
ROLES AND RESPONSIBILITIES
Personal information collected by the Foundation is kept in confidence and is only disclosed where necessary to meet the above purposes. For example, the Foundation may disclose limited personal information to Alberta Health Services or the University of Alberta so that they may directly recognize a particular donation.Our employees are only authorized to access personal information if they need to use that personal information for the reason(s) for which it was collected. Safeguards are also in place to ensure that the personal information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was collected and to prevent its being lost or destroyed. The Foundation also takes measures to ensure that the integrity of this information is maintained.The University Hospital Foundation does not rent or sell mailing lists. It does, however, exchange donor names from time to time with carefully selected charities as a cost-effective way to reach new potential donors. Individuals also have the opportunity to opt out altogether of having their personal information used except as required by law. If an individual wishes to change, limit, or withdraw consent to the use of personal information with regards to its collection, use or disclosure, they should contact our offices directly.
PROCEDURE
Principle 1 – Accountability for Personal Information
The Foundation has a Privacy Officer who is accountable for the Foundation’s overall compliance with its Privacy Policy and acts as the primary contact person on information privacy and security matters. The Privacy Officer can be contacted at 825-901-1513 or by email at [email protected].
The Foundation is responsible for all personal information in our possession, including information that has been transferred to a third party for processing. In cases where such transfers take place, we ensure that the third party has comparable privacy safeguards in place and is required to sign a confidentiality agreement.
Although the Foundation is responsible for all personal information in our possession that has been transferred to a third party with comparable privacy safeguards, the Foundation is not responsible for any privacy breach that is the result of circumvention of any privacy settings or security measures of such a third party.
Principle 2 – Identifying Purposes for Collection of Personal Information
When the Foundation collects personal information directly from its constituents, the Foundation will identify the purposes, orally or in writing, for which personal information is collected at orbefore the time of collection. These purposes include: donor recruitment and recognition, that which is necessary for the administration of a donor’s interests and compliance with legal and regulatory requirements.
The Foundation will not use or disclose personal information for any new purpose beyond that for which it was originally collected without first identifying and documenting the new purpose and getting the user’s consent
Principle 3 – Obtaining Consent
The knowledge and consent of a person is required for the direct collection, use or disclosure of personal information except where mandated by law. Individuals may withdraw consent at any time, by any means, with reasonable notice to the Foundation. The Foundation may collect, use and disclose personal information without consent if that information is considered by law to be in the public domain. Sources of public information include telephone and professional directories, newspapers, periodicals and public registries.
Principle 4 – Limiting Collection of Personal Information
The Foundation will limit the collection of personal information to that which is necessary for the purposes identified. Information will be collected by fair and lawful means. The Foundation does not collect any personal health information, other than that which is volunteered directly by the constituent.
Principle 5 – Limiting Use, Disclosure and Retention
Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the person or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes. The Foundation does not rent or sell any personal information to third parties. Personal information is only disclosed to third parties who have signed an agreement binding them to the Foundation’s privacy policies. The Foundation will also disclose names for donor recognition and honorary acknowledgements unless the supporter indicates they wish to remain anonymous.
Principle 6 – Accuracy
The Foundation will use its best efforts to ensure personal information is accurate, complete and as up-to-date as necessary for the purposes for which it is to be used. To change or modify any personal information previously provided to the Foundation, contact the Foundation Office at 833-GIVE-UHF or [email protected].
Principle 7 – Safeguards
Personal information is protected with security safeguards appropriate to the sensitivity of the information. Although the Foundation uses commercially reasonable efforts to protect your personal data and information in accordance with applicable professional, provincial, and federal guidelines, transmission and storage of information by digital means is difficult to completely secure. The Foundation is not responsible for any privacy breach that is the result of the circumvention by another party of any privacy settings or security measures deployed by the Foundation.
Principle 8 – Openness
The Foundation’s Privacy Policy is available on our web site at www.GiveToUHF.ca. A print version of the Foundation’s Privacy Policy can be requested from the Foundation office at 833-GIVE-UHF or [email protected].
Principle 9 – Access to Personal Information
Upon request, a person will be informed of the existence, use, and disclosure of personal information of the person and shall be given access to that information. A person can challenge the accuracy and completeness of the information and have it amended as appropriate. The Foundation will respond to a person’s request within a reasonable length of time, but no longer than 30 daysfrom date of receipt of the request. Upon request, the Foundation will provide specific information about third parties to whom personal information has been disclosed.
Principle 10 – Handling Users’ Complaints and Questions
The Foundation can be asked at any time to receive, investigate and respond to users’ complaints and questions. The Foundation will respond to all complaints and questions in a timely manner under the circumstances and within legal time frames. A challenge concerning compliance with the above principles should be made to the Privacy Officer. Should the Foundation become aware of any data breaches where there exists a real risk of significant harm to the individual whose information has been compromised, the Foundation will, as required by law, notify the Information and Privacy Commissioner under the Freedom of Information and Protection of Privacy Act, together with any impacted individuals, as soon as feasible after the breach, so that steps may be taken to reduce any potential harm.
Privacy Officer Contact Information:
Board Liaison
University Hospital Foundation
9-124 Clinical Sciences Building
8440 – 112 Street NW
Edmonton, AB T6G 2B7
Phone: 825-901-1513
Email: [email protected]
Related Policies and Procedures
Code of Business Conduct and Ethics Policy (GOV-001)
Complaints Policy (in development)
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