Privacy Policy
Last update: May 5, 2009
At the Jewish Russian Community Centre of Ontario ("JRCC"), we are committed to protecting the privacy and confidentiality of the personal information of our members and Community. In order to comply with applicable privacy legislation and to instill confidence in our community that the Personal Information they entrust to us is safe, we have developed this Privacy Policy. We want our members to know why we ask for their personal information, how we use it, what safeguards we employ, and how to contact us with privacy-related questions.
In this Privacy Policy, "Personal Information" means information that specifically identifies a community member as an individual and is provided to, or collected by, JRCC and its staff. We may collect Personal Information directly from a community member upon applying at the JRCC for the first time, or over time as we enhance our programs. We may on occasion obtain information about a community member from other sources, such as other family or community members. Personal Information does not include the name, title, business address or telephone number of any employee of any organization.
I IDENTIFYING THE PURPOSES AND USE OF PERSONAL INFORMATION
JRCC collects and uses a community member's Personal Information for the following purposes:
· Exodus Magazine, JRCC Calendar and other general notices and mailings;
· General announcements, including life cycle events, Shiva notices, Etc;
· program announcements;
· Collection of pledges;
· Membership status determination;
· Fundraising;
· Aliyas and yortzeits;
· Birthday & anniversary greetings to the whole family;
· affiliated organizations' programs and activities;
· To generally communicate with our community members and their spouses and family members;
· To provide necessary information to enable us to officiate and run Jewish life cycle events;
· To understand and assess the needs and requirements of our community members; and potential members to unable us to offer services, programming and events to meet those needs;
JRCC is a vibrant and caring "Community Centre" which is dedicated to our community and supportive of its members. As such, certain information or news about our members and their life cycle events will be shared with the community unless we are notified otherwise.
II CONSENT
JRCC will not collect, use or disclose a community member's Personal Information without the member's requisite consent, except in certain extraordinary circumstances. Such extraordinary circumstances shall include without limitation, when legal, medical or security reasons make it impossible or impractical to obtain consent or where it is otherwise in the best interests of the community member.
Consent for the collection, use and/or disclosure of Personal Information may be obtained orally or in writing and may be expressly given or implied. We may occasionally ask a community member to give written consent to the use and disclosure of specific Personal Information. In determining how we obtain consent, we will take into account the sensitivity of the Personal Information that we are collecting, using and/or disclosing. We will use and disclose Personal Information only in accordance with this Privacy Policy.
By becoming a member giving a Donation or updating your information at the JRCC, a community member consents to the terms of this Privacy Policy, including the disclosure of Personal Information to a third party in the circumstances or for the purposes set out in this Privacy Policy. Unless stated otherwise in writing.
Our community members may withdraw their consent by written notice to us at any time, subject to any legal or contractual restrictions and reasonable notice. A community member's refusal to provide, or subsequent withdrawal of, his or her consent may affect our ability to provide the community member with our services. We will inform the community member of the implications of such withdrawal. To withdraw consent, a community member should contact JRCC's Chief Privacy Officer, who is JRCC's Administrator from time to time, in writing at:
Jewish Russian Community centre of Ontario
5987 Bathurst St. Unit 3
North York, Ontario, M2R 1Z3
Attn: Chief Privacy Officer
Email: [email protected]
III LIMITING COLLECTION
JRCC limits the collection of a community member's Personal Information to that which is necessary for the purposes identified in this Privacy Policy, or for any additional purpose identified to the community member before collection of the Personal Information.
IV LIMITING USE, DISCLOSURE AND RETENTION
Personal Information is not used or disclosed for purposes other than those for which it was originally collected, except with the consent of the community member, or as permitted by law. Personal Information is only retained as long as may be necessary for the fulfillment of these purposes, or to meet government requirements, whichever is longer, following which it is destroyed, erased, or rendered anonymous. JRCC is guided by and adheres to the standards of Halacha, and, as such, selected items of Personal Information may be retained indefinitely.
Under certain circumstances JRCC may disclose a community member's Personal Information:
- when we in good faith believe the law requires or authorizes us to do so, including reporting to Canada Revenue Agency of donations received;
- when the services we are providing require us to give a community member's information to third parties (for example, to a funeral parlour or caterer), in which case a community member's consent will be implied, unless a community member tells us otherwise;
- where it is necessary to establish or collect dues or contributions;
- when Personal Information is provided to third party service providers (such as accountants, computer back-up services mailing company or archival file storage) with whom we have contractual arrangements that ensure comparable levels of protection to the internal protection which we maintain for Personal Information;
- when we engage in joint activities or programs with other organizations of a similar religious or communal nature;
- if the information is already publicly known.
We never make our community list available to third parties in any form, except as set out in this section or unless we have consent from our members. Our Membership list may be made available to members upon request. If a member does not wish to be included on this list, please contact the Chief Privacy Officer.
V ACCURACY
JRCC strives to ensure that a community member's Personal Information is as accurate, complete and up to date as necessary for the purposes for which it is used. If a community member's Personal Information changes or if a community member becomes aware that the Personal Information which we have is incorrect, please inform us so that we can make the necessary changes.
VI SAFEGUARDS
JRCC endeavors to maintain adequate safeguards to protect against loss, theft, unauthorized access, disclosure, copying, use or modification of community Personal Information in the care of the JRCC, including restricted access to Personal Information, locked cabinets and offices and computer passwords.
As JRCC is responsible for any Personal Information under its control, including Personal Information that JRCC may transfer to a third party for processing; we will use contractual or other means to ensure that the third party will have a level of privacy protection comparable to the internal privacy protection maintained at JRCC.
VII ACCOUNTABILITY, OPENNESS AND MEMBER ACCESS
JRCC is responsible for the Personal Information under its control and has appointed a Chief Privacy Officer to oversee our efforts to comply in all material respects with applicable privacy legislation and the terms of this Privacy Policy. The Chief Privacy Officer and those designated by the Chief Privacy Officer (the "Privacy Team") address and investigate questions or concerns regarding a member's Personal Information.
To reach the Chief Privacy Officer or a member the Privacy Team, please call 416-222-7105 x227 or email: [email protected]. A copy of this Privacy Policy and any future updates or amendments is available at www.jrcc.org.
JRCC will provide a member access to their Personal Information upon written request. Detailed requests that require archive, retrieval or copying costs may be subject to reasonable reimbursement for our actual costs. The member may correct or amend any inaccuracies in the member's Personal Information. JRCC has the right to refuse a request for access to Personal Information if:
· The information is protected by legal privilege;
· Granting access would reveal confidential commercial information;
· Doing so would reasonably be expected to threaten the life or security of another individual;
· The information was collected for purposes related to the detection and prevention of fraud;
· The information was generated in the course of a formal dispute resolution process, such as a Beit Din;
· Denial of access is required or authorized by law;
· The information would likely reveal personal information about another individual;
· The request is vexation or frivolous;
· The information would prejudice negotiation with the member; or
· To protect JRCC's rights and property.
If we deny a request for access, or refuse a request to correct information, we will provide a written explanation.
VIII CHALLENGING COMPLIANCE
Community members are encouraged to discuss any privacy issues with the Chief Privacy Officer or a member of the Privacy Team.
IX WEBSITE
Our Web site (www.jrcc.org) may contain links to other sites, which are not governed by this Privacy Policy. On our Web site, like most other commercial Web sites, we may monitor traffic patterns, site usage and related site information in order to optimize our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.
X COMMUNICATING WITH US
Email is not a 100% secure medium and community members should be aware of this when contacting us to send personal or confidential information.
XI CHANGES TO THIS PRIVACY POLICY
JRCC will from time to time review and revisit privacy practices and this Privacy Policy. In the event of any material amendment, an appropriate notice will be posted on JRCC's Web site. All members are encouraged to contact JRCC to establish if any updates have been made to this Privacy Policy, which can be ascertained by the date listed at the top of this Privacy Policy. All updates and amendments to this Privacy Policy can be found at www.jrcc.org.
E-mail: [email protected].