Background

The Lighthouse is committed to safeguarding the personal information (which means information about an identifiable individual) entrusted to us by our participants, volunteers, donors and staff.  While not subject to privacy legislation, The Lighthouse will endeavor to manage its collection, use and disclosure of personal information in a manner that is consistent with the objectives of such legislation.

Procedures and Principles for the Protection of Personal Information

Personal Information Collection

• The purpose for which personal information is collected will be identified by The Lighthouse at or before the time of collection.
• The knowledge and consent of the individual are required for the collection of personal information.
• The personal information collected will be as accurate and as current as necessary for the purpose for which it was collected.
• In collecting personal information, The Lighthouse will take into account the reasonable expectations of the individual.
• The collection of personal information will be limited to that which is necessary for the purpose identified by The Lighthouse.
• Individuals will not be contacted for personal information unless such information is required for a valid purpose identified by The Lighthouse.

Description of Personal 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, 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 issue receipts and maintain future contact.
• Contact information from individuals necessary to receive regular communication from The Lighthouse (e.g., names, mailing addresses, email addresses).

Use and Disclosure of Personal Information

• The knowledge and consent of the individual are required for the use and disclosure of personal information.
• Personal information collected by The Lighthouse will not be used for purposes other than those for which it was collected.
• If The Lighthouse wishes to use personal information for any purpose other than that for which it was collected, the new purpose shall be identified prior to use and the consent of the individual is required before personal information can be used for that purpose.

Exception to Principles of Protection of Personal Information

• There may be specific circumstances where the collection, use or disclosure of personal information without the knowledge and consent of the individual may be authorized or required by law.

Safeguarding Personal 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 personal information is stored electronically or in databases, safeguards will be in place to ensure that only authorized personnel may have access to information;
• Virus software updated routinely, and back up of information routinely;
• Computer firewalls in place; and
• Locking unattended vehicles when transporting personal information.
• When transmitting personal information by fax, email, mail or other means, steps will be taken to ensure that the recipient is authorized to receive the personal information, and the scope of the personal information will be limited to that which is necessary for the purpose for which it was collected.

Retention and Disposal of Personal Information

• Personal information will be retained only for as long as necessary to fulfill the purpose for which it was collected.
• The Lighthouse will follow these guidelines in its retention of personal information concerning the following:
• Participants – until the participant has reached the age of 25 years;
• Staff and Contractors – until 7 years after the employee or contractor has left The Lighthouse;
• Service Delivery (Facilitator) Volunteers – until 7 years after the person has left The Lighthouse;
• Other volunteers– until 7 years after the person has left The Lighthouse; and
• Donors – until 7 years after their last donation.
• Hard copies and electronic copies of documents containing personal information shall be disposed of securely by shredding and permanent deletion, respectively.

Privacy Complaints

• This Complaints Policy applies to any complaints arising from The Lighthouse’s Privacy Policy.

Accountability

• The Lighthouse is responsible for protecting the personal information it collects from individuals.
• The Lighthouse designates the Executive Director as the primary officer responsible for (a) ensuring that all reasonable steps, procedures and safeguards are implemented to protect the personal information collected by The Lighthouse and ensure compliance with this Privacy Policy, and (b) respond to inquiries concerning this Privacy Policy.
• A copy of this Privacy Policy will be provided to anyone on request and will be made available on The Lighthouse website.

Date of Approval by Board of Directors: March 2023