This policy provides information about how personal information is collected, used, disclosed and protected. This policy also includes procedures for asking questions or changing personal information held by Kids Help Phone.
The terms “Kids Help Phone”, “we” and “our” refer to the national and regional offices of Kids Help Phone.
Safeguards are in place to ensure that the information is not disclosed or shared more widely than is necessary. Measures are taken to ensure the integrity of information is maintained and to prevent it being exposed, lost or destroyed. Kids Help Phone has implemented a protocol to guide the organization in responding to any incidents of data security breaches resulting in the exposure of private information to unauthorized parties. The protocol includes provisions to notify parties whose private information may have been exposed and to minimize the harm caused by data security breaches.
Specific information about Kids Help Phone’s website information-handling practices is provided in the Website Practices section.
This policy is subject to change due to changes in organizational practices or legal and regulatory requirements. We regularly review our privacy practices for our various activities, and update our policy. We encourage you to periodically check our website KidsHelpPhone.ca or JeunesseJecoute.ca on a regular basis for information on our most up‐to‐date information.
Donors and members of the public — privacy
Kids Help Phone values the trust of the public. Maintaining trust requires transparency and accountability in managing information.
Kids Help Phone gathers and uses personal information in the course of projects and activities. This information will be carefully protected and any use of this information with outside parties is subject to consent.
- Personal information will not be sold or rented but may be traded under specific, highly confidential circumstances subject to a mechanism to opt
- Personal information provided to, or collected by, Kids Help Phone in the course of providing counselling, information and referral, and other support services for clients may be reviewed for quality assurance, training and evaluation. In specific cases where research ethics has been approved and consent is obtained from service users, client information may be used as part of research studies.
In our effort to maintain appropriate standards of care in managing personal information, we commit to the following ten principles:
- Identifying Purposes
- Limiting Collection
- Limiting Use, Disclosure and Retention
- Individual Access
- Challenging Compliance
Defining personal information
Personal information is any information recorded in any form that identifies or can identify an individual, other than an individual’s business contact information. Thus, personal information includes your name, gender, address, phone number, date of birth, credit card details or other financial information, health information, donation amounts and dates, volunteer information such as availability and areas of interest, history of involvement with Kids Help Phone, and information required to maintain an employment relationship with Kids Help Phone.
Exceptions: 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. Where an individual uses their home contact information as business contact information as well, the contact information provided is business contact information, and is not therefore subject to protection as personal information.
Principle 1: Accountability
Kids Help Phone accepts responsibility for protecting personal information under its control. Kids Help Phone’s Senior Vice President, Operations & CFO is accountable for the organization’s compliance with this policy as Privacy Officer.
The Privacy Officer:
- ensures all staff/volunteers are trained on the appropriate collection, use and disclosure of personal information and can answer public and donor inquiries;
- develops and, on a regular basis, reviews Kids Help Phone policies and practices to ensure consistent implementation and compliance;
- ensures all third parties to whom Kids Help Phone provides access to personal information also adhere to appropriate standards of care in managing that information; and
- handles all inquiries and complaints relating to privacy.
Principle 2: Identifying Purposes
Kids Help Phone identifies the purposes for which it collects personal information prior to the time the information is collected, and only collects information necessary for the identified purposes.
Personal information is collected for purposes such as:
- providing support services;
- managing Kids Help Phone events;
- responding to any concerns or inquiries about Kids Help Phone’s activities;
- fundraising and promoting Kids Help Phone events and services;
- communicating with the community, including communications with donors, funders, partners and individuals that participate in Kids Help Phone events or use Kids Help Phone services;
- determining an individual’s suitability to be in a position of trust, including the handling of cash or working with vulnerable persons;
- accounting and other financial purposes such as issuing tax receipts;
- maintaining a volunteer relationship with volunteers; and
- maintaining an employment relationship with employees of Kids Help Phone.
Each time an individual accesses Kids Help Phone’s website, we automatically receive and store certain types of non-personally identifiable information. Please refer to the Website Practices section for more information.
Principle 3: Consent
Requirements for consent to the collection, use or disclosure of personal information vary depending on circumstances and on the type of personal information. Consent can be obtained in person, by phone, by mail or via the Internet.
In determining whether implied or explicit consent is required and, if so, which form of consent is appropriate, Kids Help Phone will take into account the sensitivity of the personal information at issue, the purposes for which Kids Help Phone will use the information and any legal requirements. Consent may be implied based upon the reasonable expectations of the individual. For example, if you provide personal information in response to a fundraising communication, consent may be implied for the purposes of using the information for fundraising. In determining the appropriate form of consent, Kids Help Phone will take into account the sensitivity of the personal information. Implied consent will generally be appropriate where the personal information is non-sensitive in nature and context. Express consent will always be sought should the primary purpose of collection be to promote a corporate partner products or should we wish to disclose your personal information to a third party, such as another charity.
Kids Help Phone will usually obtain your informed consent at the time that we collect your personal information. If your personal information will be used or disclosed for any additional purposes that are not outlined in this policy, Kids Help Phone will advise you of these new purposes before such use or disclosure, unless otherwise required by law.
Kids Help Phone obtains consent at the time of collecting personal information. Kids Help Phone only discloses personal information to outside agencies/organizations or individuals if consent has been obtained or the disclosure is permitted or required by law.
Consent may be time-limited and may be revoked by the individual who gave it, subject to legal restrictions, limited exceptions and reasonable notice. Withdrawal of consent will not exclude an individual from service delivery, unless the information requested is required to fulfill an explicitly specified and legitimate purpose.
Principle 4: Limiting Collection
Kids Help Phone limits the collection of personal information to that which is required for the identified purposes.
Every Kids Help Phone department or business unit is responsible for ensuring that all information collected is limited, both in amount and type, to what is needed to fulfill the identified purposes.
Kids Help Phone usually collects personal information directly from the individual who the information is about, but may also collect personal information from other sources, with the consent of the individual or where permitted or required by law, including but not limited to personal references and family members.
Principle 5: Limiting Use, Disclosure and Retention
- Use and Disclosure: Personal information should be used and disclosed only for the purposes for which it was originally collected unless a specific consent from the individual has been obtained or where the law specifically provides otherwise. There are circumstances where a disclosure without consent is permitted, for example in the context of a legal investigation or a request from law enforcement authorities.Also, note that in working with various service providers, all of whom commit to safeguarding personal information, personal information may be accessible in, or transferred to, a foreign jurisdiction. Such information may be provided to law enforcement or national security authorities of that jurisdiction upon request in order to comply with foreign laws.
- Retention: Personal information should be retained only as long as it is necessary for the fulfillment of the identified purposes and as required by law. Kids Help Phone has established retention timelines for staff to follow and also periodically reviews the Organization’s retention needs.
Principle 6: Accuracy
Kids Help Phone makes reasonable efforts to keep personal information as accurate, complete and up-to-date as is necessary to fulfill the purposes for which the information is to be used.
We rely on our donors, volunteers, event participants and employees to provide us with accurate information and to notify us if their information needs to be updated.
In addition, Kids Help Phone has checks in place to ensure information received is accurately entered into our systems.
Principle 7: Safeguards
Kids Help Phone takes reasonable measures to ensure that personal information is kept safe from loss or theft, unauthorized access, use, copying, disclosure or modification. Safeguards include physical, organizational and technical measures, including but not limited to:
- Security card access to premises;
- Restriction of employee access to files on a “need to know” basis;
- Confidentiality undertakings by all employees;
- Locking up personal information and never leaving it unattended and in plain view;
- Firewalls, anti-virus, strong passwords and software solutions for technical security; and
- Regular reviews of privacy compliance initiatives.
Kids Help Phone protects personal information disclosed to third parties through contractual agreements stipulating the protection of personal information and the limited purposes for which the information may be used.
Kids Help Phone trains all staff on privacy best practices and ensures that employees are aware of the importance of safeguarding any personal information that they are privy to.
Principle 8: Openness
Kids Help Phone takes steps to ensure that all staff/volunteers can answer inquiries about the organization’s information-handling practices and can appropriately refer unanswered questions or complaints regarding compliance.
Principle 9: Individual Access
An individual may direct a request for access to their personal information to the Privacy Officer (contact information is set out at the end of this policy). Upon request, Kids Help Phone will:
- inform individuals of personal information held by the organization or its partners about them;
- explain how this information has been used;
- provide a list of any organizations to which their personal information has been disclosed; and
- give individuals access to their information.
An individual may challenge the accuracy and completeness of the information and have it amended as appropriate.
In order to safeguard personal information, an individual may be required to provide sufficient identification information in order for Kids Help Phone to authenticate the individual as an event participant, donor or volunteer and to authorize access to the individual’s file.
Kids Help Phone shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file. Where appropriate, Kids Help Phone shall transmit to third parties having access to the personal information in question, any amended information or information regarding the existence of any unresolved differences.
Individuals will be provided with any help needed to access their personal information, including clarifying exactly what they are looking for. Requested information will be provided in a form that is generally understandable — any acronyms, abbreviations or codes in the record will be explained.
The individual’s request for access to his or her personal information will be responded to as quickly as possible, and no later than 30 days after receipt of the request. Depending on the amount of information requested, there may be a nominal fee charged to cover the cost of photocopying.
Where permitted or required by law, Kids Help Phone may decline to provide an individual with access to the personal information. Under such circumstances, Kids Help Phone will explain the reasons for the refusal.
Principle 10: Challenging Compliance
The organization has procedures in place to receive, respond to and track concerns or complaints about its management of personal information. The expectation is that by following these procedures, a remedy or corrective action may occur to resolve the issue, including if necessary amending the organization’s policies and procedures. In addition, tracking complaints and resolutions will ensure that complaints are handled in a timely and effective manner.
How donor personal information is collected and protected
Kids Help Phone takes commercially reasonable steps to protect personal information against unauthorized access and to maintain the accuracy and proper use of the information by means of appropriate physical, technical and organizational measures.
Kids Help Phone will not, as a condition of interaction, require service users or donors to consent to the collection, use or disclosure of information beyond that required to fulfill the explicitly specified and legitimate purposes for which the information was provided.
Kids Help Phone collects personal information that is voluntarily provided during the process of receiving services, a donation, pledge, request for materials, event registration or use of some web services. Consent for use or disclosure of personal information is obtained at the time of collection. In certain circumstances, Kids Help Phone may wish to use personal information previously collected for a new purpose that was not stated at the time the information was collected. In this situation, donors will be given the opportunity to opt‐out of such new use through email or mail.
Kids Help Phone may trade names for its fundraising efforts to list brokers. These list brokers are required to ensure that the appropriate consents have been obtained by the list owners.
Contact information may be used to inform donors about Kids Help Phone developments or activities, upcoming fundraising events or sponsorship opportunities occurring at the national or regional level.
Website practices and electronic commerce
All sessions, online transactions and contributions on the Kids Help Phone website occur through a safe, private and secure system that protects individual personal information. Security measures, including encryption of data in transit and at rest, are used to protect personal and other information received during all website sessions and donation transactions.
Our websites may automatically record some general information about your visit in order for Kids Help Phone to engage in web statistical analysis using Google Analytics. We want to make sure our sites are useful to visitors and make the most efficient use of donor dollars in our marketing efforts through targeted advertising. This information may include the:
- internet domain for your internet service provider, such as “company.com” or “service.ca” and the IP address of the device you are using to access Kids Help Phone’s website; type of browser you are using, such as Safari, Internet Explorer, Firefox or Chrome;
- type of operating system of your device such as iOS, Android, Windows or macOS;
- date and time of the visit to our site, the pages of our site that were visited, and the address of the previous website you were visiting if you linked to us from another website;
- age category, gender, and affinity interests as determined by demographic and interest reports available through Google Analytics.
We make no effort to personally identify you based on your visit to our site. Non‐personally identifying IP address information may be gathered during visits to the website at KidsHelpPhone.ca or JeunesseJecoute.ca. IP address information is not linked to personally identifiable information.
Data collected for web analytics purposes may be processed in any country where Google operates servers, and thus may be subject to the governing legislation of that country.
We also use “cookies” that identify you as a return visitor and which can help us tailor information to suit your individual preferences. A cookie is a small text file that a website can send to your browser, which may then store the cookie on your hard drive. The goal is to save you time next time you visit, provide you with a more meaningful visit, and measure website activity. Cookies in and of themselves cannot be used to reveal your identity. Many browsers, however, allow you to disable cookie collection if you wish, or inform you when a cookie is being stored on your hard drive.
When you are not on Kids Help Phone sites
Kids Help Phone also provides links to other websites which we believe may be of interest to you. Kids Help Phone is not responsible for the privacy practices of these other sites. We encourage you to read the privacy statements of each and every website that requests personal information from you.
Third party social media
Kids Help Phone’s use of social media serves as an extension of its presence on the Internet. Social media account(s) are public and are not hosted on Kids Help Phone’s servers. Users who choose to interact with Kids Help Phone via social media should read the terms of service and privacy policies of these third-party service providers and those of any applications used to access them.
How to opt out, request access to, or update personal information or contact preferences
To access, update or correct personal contact information or request removal from mailing lists, donors may request a change that will be implemented within 30 days by:
- Written request sent to 300‐439 University Ave. Toronto, ON M5G
- Telephone Kids Help Phone toll free at 1‐800‐268‐3062
- Email at firstname.lastname@example.org or email@example.com or firstname.lastname@example.org
Kids Help Phone makes commercially reasonable efforts to keep files complete, up‐to‐date, and accurate. Upon presentation of satisfactory identification, individuals can check their information on record to verify, update and correct it. Additionally, donors can also request to not have their name listed in publications.
Employee – privacy
Privacy Concerns and Privacy Officer contact information
Susan Morris, Privacy Officer
Kids Help Phone, National Office
300‐439 University Avenue Toronto, ON M5G 1Y8
Toll Free Number 1-800-268-3062
Please note that when personal donor file information is requested, suitable identification will be required. Files may include confidential information relating to other individuals or information confidential to Kids Help Phone. In compliance with the Kids Help Phone Privacy Policies, these files can not be copied or released; however, any factual information regarding an individual requesting their own file will be made available. Under normal circumstances, all requests and updates will be processed within 30 (thirty) days of receipt of the request. The privacy officer is the Senior Vice President, Operations & CFO and should the privacy officer not be available, the designate is the Associate Vice President, People and Culture.
Further information on privacy and your rights in regard to your personal information may be found on the website of the Privacy Commissioner of Canada at https://www.priv.gc.ca/.