BC Social Venture Partners Privacy Policy

Our Commitment
It is BC Social Venture Partners’ (“BC SVP”) commitment to maintain the principles of integrity and trust with respect to the protection of personal information. As part of our commitment, BC SVP will protect the privacy of personal information of donors, employees, grant recipients and other individuals whose personal information comes into our possession or control.

BC SVP is committed to complying with British Columbia’s Personal Information Protection Act (the “Act”) and all other applicable privacy laws.

Definitions
“Personal information” is information about an identifiable individual, but does not include business contact information or work product information.

Personal information includes:

• “employee personal information” means personal information about an employee that is collected used or disclosed solely for the purposes reasonably required to establish, manage or terminate an employment relationship, but does not include other personal information about the employee.

but does not include:

• “business contact information”, which means information that enables an individual to be contacted at work, including his/her name, title, business address, business telephone number, fax number and e-mail address; or
• ”work product information”, which means information prepared or collected by an individual or group of individuals as part of their employment or business responsibilities or activities related to their employment or business.

Responsibility
BC SVP is responsible for all personal information under its control, even if it is not in its possession. BC SVP has developed policies and procedures to deal with the proper collection, use and disclosure of personal information.

BC SVP has appointed the following person to act as its Personal Information Officer to ensure we meet our personal information handling commitments:

Cindy Pandini
cpandini@bctsvp.com
604-568-9420

We reserve the right to make changes to this Policy that will become effective 30 days following notice thereof.

Purposes
Names, addresses, or other personal information collected by BC Social Venture Partners will only be used in accordance with our Privacy Policy, and will not be disclosed to any third party.

We collect personal information for the following purposes:

• To mail charitable income tax receipts and notices of BC SVP meetings and events to donors, Partners and others;
• To e-mail newsletters, to contact Partners and others about changes in schedules or upcoming events, and to notify Partners and others of special opportunities on behalf of BC SVP;
• To determine the nature and extent of a Partner’s interest in the causes SVP supports;
• To determine how, where and to what extent a Partner wishes to engage in working with BC SVP Grantees;
• To track & quantify the time & expertise contribution of Partners as a whole, to BC SVP Grantees;
• To gauge the overall satisfaction of Partners with BC SVP;
• To solicit interest to become a Partner in BC SVP;
• To manage the employment relationship with our employees;
• To meet legal and regulatory requirements; and
• For purposes identified to individuals or purposes obvious to individuals, in respect of particular collection s of personal information.

We will communicate with you or send you information that we believe to be of interest to you, unless you request no communications. We are committed to ensuring that donors, fund advisors, board members, friends and volunteers do not receive an unreasonable number of letters, emails or phone calls.

We also collect & track information to help manage for Donor Advised Funds as follows:

• To assist donors in making a gift to BC SVP or creating a fund at BC SVP;
• To appropriately receipt, acknowledge and steward the gifts of donors and the grants from donors’ funds;
• To determine a donor’s motivation in creating a fund and to assist BC SVP in approving the donor’s suggested distributions from the fund;
• To determine the nature and extent of a donor’s interest in the causes they wish to support; and
• To determine the donor’s particular wishes with respect to the administration and management of the fund.

Consent
BC SVP requires the appropriate form of consent of individuals to collect, use or disclose personal information. Where the personal information is sensitive in nature, BC SVP will provide the individual in question with a clear written description of our reason for collecting, using, or disclosing the information. BC SVP will not collect, use, or disclose the information until BC SVP has obtained written consent to do so from that individual. Where the personal information is not sensitive in nature and the purpose for our collection, use, or disclosure would be clear to a reasonable person, an individual will be deemed to consent to our collection, use, or disclosure of the information when the individual provides that information to BC SVP freely.

Unless required by law or otherwise authorized by the Act, BC SVP will not use or disclose personal information already collected for other purposes unless it obtains the consent of the individual to whom it belongs. Generally, BC SVP will seek consent to use and disclose personal information at the same time as it collects the information.

You have the right to request that your name and other information not be used for any internal BCT SVP marketing purposes.

Collection
BC SVP will only collect personal information for the purposes it has identified and that are reasonable in the circumstances. BC SVP will try to collect personal information directly from the individual concerned unless authorized by that individual to collect it from a third party or otherwise as permitted by the Act.

Use, Disclosure and Retention
BC SVP will only use or disclose personal information for the purpose(s) for which it was collected.

BC SVP may disclose the personal information to:

• a person who in BC SVP’s reasonable judgment is seeking the information as an agent of the individual;
• a company, association, organization, or individual engaged by BC SVP to perform functions on our behalf, such as research or data processing, and in particular to Salesforce.com, incorporated in the Unites States, for the purposes of database management;
• a public authority or agent of a public authority, if in BC SVP’s reasonable judgement of, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or
• where the individual concerned consents to such disclosure or as required or authorized by law.

BC SVP may use and disclose employee personal information for a variety of purposes related to commencing, managing or terminating the employment relationship.

BC SVP will retain personal information only as long as necessary to fulfil the purposes stated above, as required for legal or business purposes or as required by law. Subsequently, BC SVP will destroy, erase, or make anonymous such information. However, BC SVP will retain for at least one year personal information that has been used to make a decision about an individual, including an employee.

Accuracy of Personal Information
BC SVP will make reasonable efforts to ensure that personal information in its control is accurate and complete. Individuals may request corrections to their personal information. If BC SVP rejects an individual’s request for a correction, BC SVP will make a notation of such request and rejection on the individual’s file or personal information.

Safeguarding Personal Information
BC SVP will protect personal information in its control against loss, destruction or theft and against unauthorized access, disclosure, copy, use or modification by security safeguards that are appropriate to the sensitivity and format of the information.

Access
Upon reasonable notice from an individual, BC SVP will, within 30 days or such longer period in the event BC SVP obtains an extension, provide the individual access to all his/her personal information in BC SVP’s possession and tell the individual what the information is being used for and to whom it has been disclosed.

BC SVP reserves the right to charge a reasonable fee (except to employees) for providing access to personal information.

In certain situations, BC SVP may not be able to provide access to all personal information about an individual under BC SVP’s control. For example, BC SVP may not provide access to information if doing so would likely reveal personal information about a third party or could reasonable be expected to threaten the life or security of an individual. Also, BC SVP may not provide access to information if disclosure would reveal confidential commercial information, if the information is protected by solicitor-client privilege, if the information was generated in the course of a formal dispute resolution process, or if the information was collected in relation to the investigation of a breach of an agreement or a contravention of a law.

If BC SVP refuses an individual’s request for access, BC SVP will notify the individual in writing and will document the reasons for refusal, the relevant provision of the Act on which BC SVP relies and the remedies available to the individual.

Complaints
An individual who has complaints about how his/her personal information is being handled by BC SVP may file a complaint with BC SVP’s designated representative at the contact address listed above. Such complaint must clearly state the nature of the dispute and contain all necessary contact information for the complainant.

BC SVP will acknowledge receipt of a complaint, investigate such complaint and notify the complainant of the outcome of the complaint, including any relevant steps taken.

If a complaint has not been resolved to the satisfaction of an individual, he/she may seek redress from the Office of the Information and Privacy Commissioner.