
Privacy and Personal Data Management Policy
I) Privacy Statement
In the context of Canada’s Privacy Act and the Government of Quebec’s Bill 25, CPA Without Borders (CPAWB) is committed to maintaining the confidentiality of the personal information it collects in the accomplishment of its mission. The following policy describes how CPAWB collects, uses, retains, and protects personal information.
CPAWB collects personal and other information in the course of its outreach, education, fundraising, partnership building, contracting, and other mission-related activities. “Personal information” is understood to include any information about a physical person that can be used to identify the individual.
In addition, CPAWB collects information that cannot be used to personally identify anyone. Examples of such information would include a person’s preferred browser, the type of software in use by the computer’s operating system, the devices involved, and the domain name of the site accessing CPAWB’s site. These data allow CPAWB to operate and improve its own website.
This policy applies to all CPAWB website pages and to all information contained therein. However, it does not apply to the linked pages of other organizations whose privacy policies may vary from CPAWB’s. When visiting the www.cpasansfrontieres.ca website, visitors are understood to have agreed to this policy’s terms and conditions.
Responsibility
CPAWB is responsible for any personal information it collects, maintains, and manages, including any information entrusted to a third party for processing. Mr. Mario Roy, a member of the Board of Directors of CPAWB, is responsible for managing any personal information collected by the organization. As the person officially responsible for managing personal data, Mr. Roy may delegate the day-to-day application of this policy to other employees.
Who is Concerned
CPAWB is committed to protecting the confidentiality of personal information in its possession and understands and appreciates that individuals are concerned about the management of their personal information.
In the course of its normal operations, CPAWB collects personal information from:
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Members
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Volunteers
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Partners
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Volunteer cooperants
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Project participants
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Donors
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Supporters
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Internet users
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Staff
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Any other person related to the organization
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Any other individuals accessing the organization’s services
Consent
The policy on the collection, use, and or disclosure of personal information is premised upon the “knowledge and consent” of the individual involved.
To this end, CPAWB extends every reasonable effort to ensure that the individual is informed and understands the purposes for which information is being collected, used, or disclosed.
Subject to legal or contractual restrictions, an individual may, with reasonable notice, withdraw his or her consent by contacting the Privacy Officer. CPAWB will inform those withdrawing of the implications of any such withdrawal.
Personal Information Collected
CPAWB collects the personal information it needs in the conduct of its activities. This information will vary depending on the means of communication used and the person’s relationship with the organization, and can include:
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First and last name
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Birthday (Birth, Death, Marriage, Other Anniversaries)
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Email address
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Street and mailing address
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Phone, cell phone, and fax numbers
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Language of correspondence
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Country of residence
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Banking, billing, or payment information (including credit cards)
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Information required to register for a project, an activity, or to receive a service (e.g., food allergies)
In the case of volunteer cooperants or partners:
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Curriculum vitae
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Professional information
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Documents related to their particular mission
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Information necessary to ensure their eligibility or safety
Accuracy
In an effort to minimize the possibility of inappropriate information being used in the course of its activities, CPAWB strives to keep the information in its possession current, accurate, and complete.
Use of Personal Information
CPAWB collects and uses personal information with the consent of the individuals involved in order to:
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Solicit and raise funds as well as personalize communication with its donors
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Process donations and issue tax receipts
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Launch and manage its Web and social network campaigns
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Inform donors, members and supporters of activities, events, and other opportunities to get involved with CPAWB
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Enter participating individuals’ names at information sessions, fundraisers, training sessions, or advocacy activities
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Respond to individuals’ requests
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Manage suppliers’ service agreements
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Ensure the safety of its staff, members, volunteers, and other individuals contacting CPAWB.
Limiting Use, Disclosure, and Retention
Personal information will not be used or disclosed for purposes other than those for which it was collected, except as required by law, or with the consent of the individuals involved.
Personal information will be securely stored for the purposes for which it was collected and for as long as legally required.
Personal information that is no longer required will be destroyed, erased, or rendered anonymous unless otherwise required by law.
Safeguards
Personal information will be securely protected utilizing safeguards appropriate to the sensitivity of the information involved. Such measures are intended to prevent the loss, theft, unauthorized access to, disclosure, copying, modification, or use of such information. Protection measures include:
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Physical measures, e.g., locking filing cabinets and restricting access to data
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Organizational measures, e.g., limiting access on a “need-to-know” basis, imposing security clearances, etc.
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Technological measures, e.g., encryption, password protection, staff training, etc.
Access to Personal Information
CPAWB ensures that its information management policies and practices are readily accessible and easily understood. CPAWB welcomes any requests for information or clarification.
With reasonable notice, individuals can request information on their personal files and on the use of their information, including use by third parties, at any time. Respondents can challenge the accuracy and completeness of their information and request appropriate corrections.
Concerned individuals have the right to:
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Be informed of their inclusion in a CPAWB personal information data bank, to access such information, and to be informed of any third party with which this information has been shared.
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Have their information corrected and/or completed.
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Be informed of any breach of confidentiality that might cause harm,
II) Cookies
CPA Without Borders website uses cookies and similar tracking technologies to improve its website performance and the users’ experience. While users can disable cookies at any time, doing so will impact the user’s experience.
Definitions
Cookies are small text files that a website can place on your electronic device when you visit a site or webpage for the first time. The term “cookie” refers to all files that collect information in this way. The information collected allows sites to recognize a user’s device on subsequent visits.
CPAWB employs “session” or “persistent” cookies:
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Session cookies are only active during the user’s visit and are deleted when the user closes his or her browser.
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Persistent cookies remain on a user’s device for an indefinite period unless the user elects to delete them.
Use of Cookies
CPAWB employs cookies to enable its website to function properly, to monitor the site’s performance, and for security and marketing purposes. Cookies can also help in identifying site bugs or errors. Most cookies collect general information like how users access and navigate a site, and do not collect information that identifies the individual user.
Necessary Cookies
While they can be disabled, cookies are not intended to be disabled as they are essential to the site’s proper functioning and to the security of the user’s browsing experience. Cookies enable the user to access the site’s options and features, like filling forms and setting privacy preferences. If you choose to disable cookies in your browser settings, you might not be able to access all the site’s many features.
Performance and Analytics Cookies
Cookies are employed to monitor visitors’ use of a website and its performance. They collect information (e.g., number of visits, traffic sources, most and least viewed pages) and generate reports and statistics without identifying individual users.
Other Technologies
CPAWB’s websites and emails may also employ scripts and tags, two other technologies that convert information into programming code.
Tags can be used to track users’ activity, for example, to record how people use the site and to track the number of visitors, the number of emails opened and to collect specific personal information, including IP addresses.
CPAWB may also employ embedded scripts to collect information about users’ use of its website (e.g., the number of clicks on a link). Scripts are temporarily downloaded to a user’s device during a visit and are subsequently disabled or deleted.
Use of Cookies by Third Parties
CPAWB allows third parties to use cookies that fall into these same categories. Like many other organizations, CPAWB employs third-party analytical tools, like Google Analytics, to monitor traffic on its site and to improve site functionality.
Accepting or Refusing Cookies
With respect to privacy issues, CPAWB offers users the ability to accept or refuse certain types of cookies. When opening the CPAWB website, you may be presented with a consent form. All users need to do to get more information is to select from among the available options and to modify their default settings accordingly. You can also manage your cookie preferences via your browser, by deleting and/or blocking specific cookies. As has already been mentioned, blocking certain types of cookies may impact on your browsing experience.
Browsers
The CPAWB website is optimized for the Google Chrome, Mozilla Firefox, and Safari browsers. Nevertheless, users are encouraged to update their browsers frequently to ensure that they are free from security vulnerabilities.
While CPAWB’s website is available to users with older or less compliant browsers, the website’s visual presentation may be corrupted, and/or access to certain features lost.
Users having problems in navigating CPAWB website, are encouraged to update their browser, or to download one of the free browsers listed above.
Cookies and Browsers
Users can change the settings on their browser or mobile device. Once again, this may impact the operation of the site. Visit your browser’s website to learn more:
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Google Chrome
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Mozilla
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Firefox
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Safari
If your browser is not listed, please refer to the browser’s webpage for more information.
III) Payment Security
Donations and payments made on our website are processed via PayPal and/or Zeffy (i.e., secure third-party payment platforms that do not transmit your banking or credit card information). Overall security and the management of your financial data are entirely within the scope of PayPal (www.paypal.com) and Zeffy’s (www.zeffy.com) security policies and systems. You are encouraged to review their privacy and security policies before making a transaction.
IV) Responsible
Those concerned can obtain information on CPAWB’s data management policies and practices and on the personal information in its possession by mail or e-mail to:
Mr. Mario Roy
Privacy Officer
CPAWB
1431 Fullum Street, Suite 202
Montreal, Quebec, H2K 0B5
Canada
mario.roy@arihq.com or +1 514-238-4169
Should CPAWB’s response prove unsatisfactory, those concerned can file a complaint with the Quebec Government’s access to information website at http://www.cai.gouv.qc.ca
V) Relevant Legislation
This policy is governed by and shall be interpreted in the context of relevant Provincial and Federal regulations. In the event of any dispute, the complainant and CPAWB agree that the Province of Quebec courts have exclusive jurisdiction to receive and adjudicate any such claims.


