Up With Women Privacy Policy

PURPOSE

This Privacy Policy (“Policy“) outlines Up With Women’s commitment to respecting the privacy of Personal Information of individual persons and explains how we collect, use, protect and disclose personal information. This includes the Personal Information of clients, donors, prospective donors, employees, volunteers, Board of Directors members, and individuals who engage with us on community initiatives.

Up With Women is committed to providing our clients with reliable and trustworthy coaches, employees, and volunteers who will keep all Personal Information about clients confidential, unless clients provide explicit consent.

SCOPE

To better protect one’s privacy, Up With Women has developed this Policy to explain our information practices as well as our online identification practices. This document will also make individuals aware of the choices and the rights they have with regards to the way their information is used.

In order to collect Personal Information online, Up With Women needs an individual’s consent. Up with Women will provide a direct link to this Policy to the general public via its website and will direct a person to confirm review of this Policy prior to submitting any personal information to Up with Women. By then choosing to submit personal information to us, an individual signifies their consent to all of the terms of this Privacy Policy. If an individual feels uncomfortable giving us Personal Information via our website, they can still inquire about Up With Women by emailing us directly through our Contact Us page.

As most of Up With Women’s activities would be deemed non-commercial in nature, the federal Personal Information Protection and Electronic Documents Act (“PIPEDA“) would rarely apply. Nonetheless, Up With Women has voluntarily agreed to abide by the principles laid out in PIPEDA and the regulations thereunder as amended from time to time. Where applicable in jurisdictions with their own privacy legislation, Up With Women will comply with that jurisdiction’s privacy legislation.

This Policy Shall

Define Key Terms
Outline confidentiality with coaches
Outline Personal Information collection purposes
Outline use of Personal Information
Outline how Up With Women store, protect, and share Personal Information
Outline how to access and update Personal Information

DEFINITIONS

Personal Information: Is any factual or subjective information, recorded or not, about an identifiable individual, and may include an individual’s name, address, email, telephone number, age, financial information, etc. Personal information does not include most business contact information such as the name, position, title, business address, or business telephone or fax number of an individual.

Confidentiality: The obligation of all Up With Women employees, or those acting on behalf of Up With Women, to keep Personal Information confidential. Confidentiality arises in the course of a relationship in which private information is shared. As the sharing of Personal Information is essential for accurate assessment and services of Up With Women clients, Up With Women has a legal obligation to ensure that any client information obtained in the course of providing services and after is kept secure and confidential.

Informed Consent: Permission granted by an individual after they have been informed about the expected benefits, potential risks, alternative courses of action, and the likely consequences of receiving or not receiving services, and having the opportunity to ask questions.

POLICY AND PROCEDURES

Confidentiality with our Coaches

All our participating coaches adhere to the International Coach Federation’s Code of Ethics and Standards of Conduct. This includes the commitment to keep the content of the coaching conversations confidential. Additional information can be obtained at: https://coachfederation.org/code-of-ethics.

Up With Women’s Program Managers will check in with each coach on each client’s progress during the program. This will only be for information on a client’s progress, strengths, also possibly to see if employees can assist with anything outside of coaching to better assist with a client’s goals and aspirations. The coach will never divulge sensitive information without a client’s consent.

Coaches and employees are bound by law to report to the proper authorities if:

They become aware of neglect or abuse of a child.
They feel in danger.
They feel a client will hurt themselves or others.

Information Collection

Up With Women obtains informed consent prior to collecting Personal Information, and in any case, prior to using or disclosing Personal Information for any purpose. A person may provide consent to us either orally, electronically (by using our website or submitting Personal Information via the website) or in writing.

Up With Women collects Personal Information from individuals and from third party service partners, where we have obtained consent to do so or where we are otherwise permitted by law (for example, when an individual makes an application to participate in one of our programs, or participates in our events, uses our website or speaks to an Up With Women representative).

Up With Women receives and stores certain types of information when an individual interacts with our websites, emails, and online advertising. Our purpose in collecting this information is to allow the websites to work correctly, to evaluate use of the website, and to support website analytics and marketing campaigns. Some examples include:

Collecting technical information such as a person’s internet protocol address, that person’s computer’s operating system and browser type, the address of a referring website, if any, and the path taken through our web pages.
Collecting and using “cookies” to recognize an individual as they use or return to our sites. This may be done so that we can provide a continuous and more seamless online experience. A cookie is a small text file that a website or email may save to an individual’s browser and store on that individual’s hard drive to record which websites an individual has visited.
Collecting and using web beacons. Beacons allow us to know if a certain page was visited, an email was opened, or if ad banners on our website and other sites were effective.

Up With Women’s websites do not knowingly collect Personal Information from children under the age of 13 without prior, parental consent. Please contact us via the “Contact Us” section of this policy if you believe we may have collected information from your child and we will work to delete it.

Use of Personal Information

Up With Women will identify the purposes for which we use Personal Information at the time we collect such information and obtain consent, in any case, prior to such use. In addition to uses permitted or required by law, Up With Women generally uses Personal Information for the following purposes:

to process a submitted application;
to build relationships, facilitate networking opportunities and match clients with coaches, advisors or mentors;
to assist with administrative or technical support;
to gather opinions and feedback through surveys;
to use in solicitations for fundraising;
to include an individual on our mailing list;
to process a submitted application for volunteer, employment or other opportunities, as the case may be, and other consistent uses that individuals might reasonably have expected at the time of collection (e.g. quality control).

Employees, volunteers and contractors should only access personal information if the discharge of their duties reasonably requires it.

Storing, protecting and sharing Personal Information

Up With Women might keep a record of an individual’s Personal Information, correspondence or comments in a file specific to that individual. We will use, disclose or retain Personal Information for as long as necessary to fulfill the purposes for which that Personal Information was collected and as permitted or required by law.

Up With Women will keep the Personal Information that has been collected at our offices in Toronto, Ontario and Up With Women Regional Offices. Our service partners may, from time to time, also hold an individual’s Personal Information in connection with purposes for which that person provided consent.

We have implemented physical, organizational, contractual and technological security measures to protect Personal Information from loss or theft, unauthorized access, disclosure, copying, use or modification. The only employees who are granted access to Personal Information are those with a business ‘need-to-know’ or whose duties reasonably require such information.

Up With Women identify to whom, and for what purposes, we disclose Personal Information, at the time we collect such information from an individual and obtain consent to such disclosure. We will share Personal Information with partners including a client’s referring agency.

Accessing and Updating Personal Information

How can an individual review their Personal Information that we have collected?

If an individual makes a written request to access any Personal Information about them that Up With Women has collected, utilized or disclosed, we will make every attempt to provide that person with any such Personal Information to the extent required by law. Up With Women will make such Personal Information available to that individual in a form that is generally understandable, and will explain any abbreviations or codes.

What if an individual’s Personal Information changes?

Up With Women will ensure that Personal Information is kept as accurate, complete and up-to-date as necessary for the purpose for which it was collected. We expect individuals, from time to time, to supply us with written updates to their Personal Information, when required.

At any time, a person can confirm the accuracy or completeness of their Personal Information in our records. If they successfully demonstrate that their Personal Information in our records is inaccurate or incomplete, we will amend the Personal Information as required. Requests to correct information can be made on the Website’s contact page or by sending an email to privacy@upwithwomen.org. Where appropriate, we will transmit the amended information to third parties (i.e., referral agencies, coaches, advisors, etc.) having access to the Personal Information.

How long does it take to receive Personal Information?

We will attempt to respond to each written request for access to Personal Information not later than thirty (30) days after receipt of such requests. We will advise in writing if we cannot meet a request within this time limit. An individual has the right to make a complaint to the federal Privacy Commissioner in respect of this time limit.

Does it cost anything to receive Personal Information?

We will not charge any costs for a person to access their Personal Information in our records or to access our Privacy Policy or practices without first providing that person with an estimate of the approximate costs, if any. An individual may withdraw their requests for access to information by notifying us within the thirty (30) day notice period disclosed on the estimate. We will attempt to accommodate any individual’s request to access their information to the best of our abilities and at least as much as reasonably possible.

How do we confirm an individual’s identity in that individual’s written request?

We may request that an individual provide sufficient identification (e.g., government-issue or photo identification) to permit access to the existence, use or disclosure of that individual’s Personal Information. Any such identifying information shall be used only for this purpose.

Contacting us about Personal Information

All comments, questions, concerns or complaints regarding Personal Information or our Privacy Policy and practices, should be forwarded to privacy@upwithwomen.org or in writing to:

Director of Operations

Up With Women

111 Queen St. E

South Building, Suite 450 Toronto ON M5C 1S2