NAPO Privacy and Confidentiality Policy

The National Anti-Poverty Organization acknowledges the importance of philanthropy and the role it plays in NAPO’s mission to elimate poverty in Canada. NAPO recognizes the good will of its supporters and pledges to maintain a high level of integrity and accountability. To achieve this, NAPO adheres to the Ethical Fundraising and Financial Accountability Code developed by the Canadian Center for Philanthropy and the Canadian Marketing Association’s Code of Ethics & Standards of Practice.

NAPO strongly believes in the donor’s right to truthful information and privacy. The following outlines NAPO’s principles regarding personal privacy:

Accountability

NAPO is responsible for protecting personal information under its control.

• It has designated a staff manager to be responsible for NAPO’s adherence to the Federal Personal Informational Protection and Electronic Documents Act.

Identifying Purposes

NAPO will clearly identify the primary use of the personal information and ask permission before any secondary use of the personal information.

• NAPO collects personal information primarily to communicate with its members and build relationships with its supporters.
• Should personal information be collected during volunteer participatory activities, permission must be granted before any fundraising appeal use.

Consent

NAPO recognizes that donors have control over the use of their information.

• All new donors are given the opportunity to decline to have their name or other information used for any further marketing purposes by a third party.
• Current donors have the opportunity to decline to have their names or other information used for marketing purposes by a third party at least every two years.
• NAPO removes a donor’s name from its exiting housefies or trade list promptly upon request.
• NAPO uses the Do Not Mail/Do Not Call service of the Canadian Marketing Association when conducting a campaign in order to delete the name of any person, other than a current donor, who has requested that he or she be removed from mail or telemarketing lists.

Limiting Use

NAPO will control the use of information by third parties.

• NAPO does not rent its trade list.
• NAPO does exchange its trade list with other like-minded organization from time to time.
• NAPO will only exchange lists with other privacy compliant organizations.
• NAPO maintains a summary of trade lists exchanges over the last 12 months and will provide the information when queried about the potential use of personal information to third party.

Limiting Collection, Disclosure and Duration of Retention

NAPO shall limit collection of information to that which is necessary for the activities noted below.

• NAPO collects the contact information, donation history and special interests of its donors in order to build on its existing relationship with its supporters.
• NAPO is obligated to retain donor information for 7 years as per Revenue Canada tax receipting guidelines.
• NAPO may collect survey information as part of its volunteer participatory activities.
• Any personal banking information is deleted from donor records upon their cancellation from the pre-authorized payment program.

Accuracy

NAPO will ensure that information is accurate, complete and up-to date as is necessary for the purpose of continuing its contact with its support base.

• NAPO will endeavor to keep donor contact records up-to- date.
• NAPO will ensure that any requests regarding donor giving preferences. i.e. limiting the number of solicitations, no further requests, do not solicit by telephone or other technology will be added to the personal record promptly.
• NAPO will not update records with contact information that is deemed not in the public domain i.e. unlisted telephone numbers etc.

Safeguards

NAPO assures the security and confidentiality of private information.

• the NAPO donor database has electronic security passwords. Access to the database is limited to select NAPO staff during office hours and locked up when the office is closed.
• The NAPO computer system also has appropriate security systems in place.
• Any paper files with confidential financial information are stored in locked filing cabinets.
• NAPO staff has signed a Code of Ethics.
• If NAPO outsources data processing or enters into contracts that require handling of personal information, NAPO will have written assurances that the firm abides by the law.
• Confidential personal information is disposed of properly to prevent unauthorized use.

Access

NAPO recognizes that donors have the right to access their information.

• All NAPO donors have the right to see their own donor record and to challenge its accuracy.
• NAPO will provide information about the potential use of personal information upon request.
• All potential donors have the right to know the source of obtaining their name.

Openness & Proper Handling of Donor Complaints

NAPO pledges to respond immediately to any queries about personal information or complaints regarding the use of personal information. NAPO will also make readily available our privacy policies and practices relating to the management of personal information upon request. Information request must be fulfilled within 30 days.

Anonymous Information

We routinely collect anonymous information, which is information that cannot be directly traced back to specific individuals. For example our web servers may electronically collect information from Web site visitors. This type of anonymous information might typically include:

• Specific web sites pages visited and the number of visitors.
• Survey data collected from donors, members or subscribers.

At no time is personal information collected from our web site unless you choose to provide it i.e. signed up for e-newsletter or provide internet donation.

Disclosure of Information to Outside Parties

We strive to keep your personal information private at all times. Occasionally, we many need to undergo analysis on our database systems by a third party in which case we required and obtain written assurances that the firms abides by safeguard regulations set out in the privacy law.

There are occasions when we are required by law to allow access to donor records. For example, our external auditing firm or Revenue Canada’s auditors may request to look at a sample of representative donor records or receipts during the course of their review of our accounting procedures.

Adopted at the NAPO Board of Directors Meeting, November 19 - 21, 2004