Privacy and
Confidentiality Policy

1 – Introduction, definition and scope

2 – Situations in which we collect personal information

3 – Information Retention

4 – Use of personal information

5 – Disclosure of information to third parties

6 – Obtaining consent

7 – Right of access to personal information

8 – Right to correction of information or right to withdrawal

9 – Data protection

10 – Questions or requests relating to the confidentiality of personal information

1 – Introduction, definition and scope

In pursuit of its mission, Mission inclusion (the Foundation) regularly collects, uses, communicates and retains information relating to individuals who interact with it.

Personal information means any non-public information about a natural person that allows that person to be identified, directly or indirectly.

The Policy also contains important information regarding the rights available to the individuals concerned and how they can exercise them. Aware of the importance of protecting personal information, the Foundation intends to comply with the applicable legislative framework, particularly the Act respecting the protection of personal information in the private sector (the Act) and to meet high ethical standards.

Mission inclusion’s information protection policy (the Policy) describes how we process and protect the personal information we collect. We follow these rules to protect privacy and meet our legal obligations.

You must read the Policy in conjunction with the Cookie Policy. By the Act, personal information concerning the exercise by a person of a function within a company, such as his or her name, title and function, as well as the address, email address and telephone number of his or her place of work, are not covered by the Policy.

The Policy does not apply to third-party websites, including social media, even if you can access them by clicking on links shared by the Foundation. In these cases, it is recommended that you refer to the personal information protection and confidentiality policies of these sites.

2 – Situations in which we collect personal information

The Foundation only collects the personal information necessary for its mission and philanthropic activities. Primarily, the Foundation collects information directly from a person aged 14 or older when they communicate or interact with them or when they update their preferences and account settings.

Collection can be carried out through personal communication (telephone, mail, email, SMS, in person), forms, or publicly accessible sources (media, public registers).

We ensure that personal information is accurate, complete, and used only for the purposes for which it was collected, used or disclosed.

The Foundation may also collect information indirectly and from other sources, obtaining consent where required, including for the following purposes:

► Process donations and prepare official receipts to the CRA’s requirements for donations’ processing;

► Recognize the contribution of sure allies in our publications or on physical recognition media;

► Communicate with allies periodically in writing, verbally or electronically to keep them informed of the Foundation’s funding needs;

► Establish and maintain our relationship with our allies, understand their needs and adapt our approach to better serve them;

► Comply with regulatory and legal requirements;

3 – Information Retention

We keep personal information for as long as necessary for the purposes for which it was collected. We must destroy this information by law and our records retention policy. When we destroy personal information, we take the necessary measures to ensure its confidentiality and that no unauthorized person can access it during the destruction process.

Mission inclusion has offices that may operate outside Quebec and Canada. Therefore, the information may be used and stored securely in other provinces and countries. In some instances, the information may be subject to the laws and access rights of the authorities of foreign countries, including the United States.

4 – Use of Personal Information

We use personal information to:

Identify, update information and verify the accuracy of the information provided;

► Assess eligibility for a mandate of incapacity service;

► Establish the philanthropist profile, philanthropic needs, strategies and objectives;

► Establish and maintain a relationship;

► Conduct studies and data analyses to generate statistics and improve our products and services;

► Personalize the donor experience, in particular through analyses of profiles, transactions, frequencies and amounts of donations;

► Promote new donation formulas;

► Allow due diligence checks of our operations in anticipation of the conclusion of a commercial transaction;

► Manage risks, including credit and business risks, and comply with
laws and regulations;

► Communicate using the contact information provided (by mail, email,
text messages, calls, and social media).

We ensure the integrity, security and confidentiality of information. Under no circumstances do we sell or provide customer lists to third parties for marketing purposes.

5 – Disclosure of information to third parties

Mission inclusion may share personal information with a third party to which it has outsourced specific tasks. According to Mission inclusion standards, the third party must destroy the personal information entrusted to it as soon as the required task is completed.

6 – Obtaining Consent

Mission inclusion will not collect, use or disclose your personal information without consent. Consent to collecting personal information may be expressed, presumed or implied.

Expressed consent is unequivocal and may be given verbally, electronically or in writing.

Presumed consent occurs when the purpose for the collection, use or disclosure of personal information would be apparent to a reasonable person and information is provided voluntarily (e.g., you provide your email address to receive an official receipt by email).

Individuals can reasonably consent by choosing to take or not take a specific action. (e.g., an individual does not notify us to stop sending them event invitations by email).

Donors’ and volunteers’ personal information will not be used or disclosed for purposes other than those for which it was collected unless our donors and volunteers have consented to do so or as required by law. The Foundation shares personal information only with third parties who have signed an agreement that includes the obligation to implement Mission inclusion’s privacy policy.

Mission inclusion’s website contains online forms allowing visitors to donate. The Foundation uses online credit card information only to process donations. The Foundation processes online donations through a third-party provider.

Our website contains hyperlinks to other sites. When an individual leaves our website using one of these links to access other websites, they will be subject to these sites’ security and privacy policies.

If an individual withdraws their consent, their decision will be respected and recorded in our records.

7 – Right of access to personal information

You may request to consult the information that Mission inclusion holds at any time unless the law provides limits to this request.

Any request for modification must be made in writing by letter or email to the person responsible for protecting personal information at Mission inclusion.

We will process the request as soon as possible.

8 – Right to correct information or right to withdraw

Anyone may correct inaccurate information about them. To provide quality service, all our information must be accurate and complete. To this end, any request for modification must be made in writing by letter or email to the person responsible for protecting personal information at Mission inclusion. We will process the request as soon as possible.

9 – Data Protection

Mission inclusion staff can access this personal information only when needed and for the purposes for which it was collected. All employees and volunteers must sign an agreement attesting that maintaining confidentiality is a prerequisite to maintaining their employment or volunteer status with the Foundation. Employees and volunteers are aware of the importance of preserving the confidentiality of personal information, and particular care is taken in disposing of and destroying this information to prevent any unauthorized party from having access to it.

Several security measures are in place, including physical, organizational and technological.

Thus, information on non-electronic media is protected by keys and procedures informing staff how it must be managed. Password-protected protocols, restricted access, and firewalls are used to protect personal information provided when a donation or another transaction is made online or by email.

We store all personal data relating to identifiable individuals using Secure Socket Layer (SSL) encryption to protect information entered on our site. SSL is the industry standard for protecting information transmitted over the Internet. All offline information is stored securely and can only be accessed by authorized Foundation personnel.

The security measures implemented by Mission inclusion protect personal information against loss, theft, or destruction, as well as against unauthorized consultation, disclosure, copying, use, or modification, regardless of its form.

When services are outsourced that require access to personal information by a third party, selecting the service provider, implies the capacity and contractual commitment to respect the conditions of this Policy.

10 – Questions or requests regarding the confidentiality of personal information

Questions, comments, or complaints regarding this Policy may be sent to the person responsible for protecting personal information. If the complaint relates to non-compliance with confidentiality, appropriate measures will be taken to remedy the situation. The Foundation will communicate responses to complaints in writing.

Richard Veenstra, protection@missioninclusion.ca
130, de l’Épée Avenue, Montreal (Quebec) H2V 3T2, Canada