Background

The Lighthouse is committed to safeguarding the personal information entrusted to us by our participants, volunteers, contractors, donors and staff. While not subject to privacy legislation, the Lighthouse will manage its handling of personal information in the spirit of such legislative schemes.

Principals

Information Collection

• Information will be collected by fair and lawful means and will be as accurate, and as current as necessary for the purpose for which it is used.
• Information collected will take into account the interests of the individual and the needs of the organization. It will also be limited to that which is necessary, has a defined reason and can be explained.
• The Executive Director will implement procedures to ensure that information collected is accurate and is updated as necessary. Individuals will not be contacted for information unless such a process is needed to fulfill an ethical, organizational need, or other valid purpose.

Description of Information Collected

• Information relating to program participants (e.g., name, address, age, gender,intake interviews) to determine the appropriate program to meet their individual needs.
• Information relating to engaging volunteers (e.g., applications, references, police background checks) to determine their suitability as a volunteer.
• Information relating to the hiring and employment of employees (e.g., resumes, references, police background checks) to determine their suitability as an employee.
• Information relating to the engaging of contractors (e.g., resumes, references) to determine their suitability as a contractor.
• Donor information (e.g., names, mailing addresses, phone numbers, email addresses) to issues receipts and maintain future contact.
• Contact information from individuals necessary to receive regular communication from the Lighthouse (e.g., names, mailing addresses, email addresses.)

Information Disclosure

• Information collected will generally not be used or disclosed for purposes other than those for which it has been collected.
• If the Lighthouse wishes to use or disclose personal information for any new business purpose or purpose other than what the original collection was for, consent will be requested.
• There may be specific circumstances where collection, use or disclosure without consent is authorized or required by law.

Safeguarding Information

• Security safeguards will be in place to protect personal information against loss, theft, or unauthorized access. The nature of the safeguards will vary, depending on the sensitivity of the information. Methods of protection will include:
  • ✓Locked filing cabinets, and secure storage of files not in use.
  • ✓Password protected sign-in software programs.
  • ✓If confidential information is stored electronically or in databases, safeguards will be in place to ensure that only those authorized may have access to information.
  • ✓Virus software updated routinely, and back up of information routinely.
  • ✓Computer firewalls in place.
  • ✓All printed information disposed of securely by shredding and electronic records by permanently deleting.
  • ✓Locking unattended vehicles when transporting personal information.
• When faxing or emailing information, steps will be taken to ensure that the recipient is authorized to receive the personal information, and the scope of the information transmitted will be limited to that which is necessary for its purpose.

Retention and Disposal of Information

• Information will be retained as long as necessary to fulfill the intended purpose of the information, generally according to the following guidelines:
  • ✓Participant records – Once the participant has reached the age of 25 years
  • ✓Staff and Contractor files – 7 years after the employee has left the organization
  • ✓Service Delivery (Facilitator) volunteer files – 50 years after the person has left the organization
  • ✓Other volunteer files – 7 years after the person has left the organization
  • ✓Donor Financial information – 7 years
• Personal information will be retained in a secure and locked location when not in use. When in use, files or personal information documents will be treated in a confidential manner, not open for viewing by unauthorized personnel. If confidential information is stored electronically or in databases, safeguards will be in place to ensure that only those authorized may have access to information.

Privacy Complaints

• The Lighthouse Complaint Policy applies for any complaints arising from this Policy.

Responsibility

• The Lighthouse is responsible for protecting personal information and designates the Executive Director to be accountable for controlling records and compliance with privacy policies.
• The Executive Director will ensure that procedures are implemented to protect personal information and respond to complaints and inquiries.
• A copy of this policy is provided to anyone on request and is found on The Lighthouse website.

Date of Approval by Board of Directors: August 2020