In accordance with applicable laws, UGM is committed to protecting the privacy of its corporation members (includes board members), staff, donors, volunteers, and any other persons about or from whom UGM collects personal information. UGM embraces the principles of the Canadian Standards Association Model Code for the Protection of Personal Information to ensure that all personal information is properly collected, used only for the purposes for which it is collected and is disposed of in a safe and timely manner when no longer required.
UGM is responsible for maintaining and protecting the personal information under its control. UGM has appointed a Privacy Officer who is responsible to ensure that UGM complies with its privacy obligations in accordance with applicable privacy laws.
UGM collects and uses personal information for a variety of purposes including, but not limited to:
- providing services to individuals ministered to by UGM
- establishing and maintaining corporation member, volunteer, and donor lists
- managing payroll and benefits
- conducting missionary performance evaluations
UGM shall identify and explain the purposes for which it collects personal information, to the person from whom the personal information is being collected, before or at the time the information is collected.
Consent will be obtained from the person whose personal information is collected, used and disclosed, unless obtaining the consent would be inappropriate or not required by law. Sometimes the person’s consent may be implied by virtue of their role with UGM. When it is appropriate, written consent will be obtained.
Written consents will be kept on file for as long as the information is reasonably necessary. A person may withdraw his or her consent at any time, subject to legal or contractual restrictions and reasonable notice. The person will be informed of reasonably foreseeable implications of the withdrawal.
Information collected will be limited to that required for the purpose or purposes identified by UGM. UGM is committed to collecting personal information in a fair, open and lawful manner.
Limiting Use, Disclosure and Retention
Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the person or as required by law. All collected personal information shall be destroyed, erased or made anonymous as soon as the purpose for which it was collected is no longer relevant, or as permitted by the law.
All personal records and files maintained by UGM are confidential and remain the property of UGM. Records and files are not to be disclosed to any outside party without the express permission of a manager. Confidential information includes, but is in no way limited to: personnel, regarding current and former missionaries; the identity of, contact information for, and any other account information on students, techniques, and processes; and any other documentation regarding UGM’s operations, procedures, or practices. Confidential information may not be removed from UGM premises without express authorization.
No information given by a client to UGM, or information about a client from any source is to be disclosed, other than the following exceptions:
- there is a court order requiring the disclosure of information (this would include a search warrant, subpoena, etc.)
- a client has given their written consent to disclose information
- conditions and circumstances exist that would lead a reasonable person exercising reasonable care and concern to believe that failure to disclose information would constitute a danger to the community and/or the client
- there is a contractual obligation at a program level to release information to a specified authority
Nothing should ever be discussed in a public place. At all times missionaries must remain conscious and sensitive of their surroundings when having workplace discussions, whether in or outside of the building.
All telephone calls regarding a current or former missionary’s position with UGM must be forwarded to a manager.
Personal information shall be maintained in as accurate, complete and up-to-date a form as necessary in order to fulfill the purposes for which it was collected.
Personal information will be protected by security safeguards that are appropriate to the sensitivity of the personal information. This safeguarding could include physical measures such as locked filing cabinets and/or premises security. Organizational
measures such as restricted access to files with personal information or technological measures such as security software will also help safeguard personal information.
- name and contact information of the Privacy Officer
- means of gaining access to personal information held by UGM
- copy of any brochures or other information that explains UGM’s policies, standards or codes
Access to Personal Information
Access to personal information will be granted, where UGM is legally required to release the information, provided that the disclosure does not violate any applicable statutes or contracts, to the person to whom the information pertains where there is an appropriate written request. The existence, use and disclosure of the personal information will be granted within a reasonable period of time. Any inaccuracy or incompleteness of personal information will be amended as required.
Complaints or inquiries about the collection, use, disclosure or retention of personal information and UGM’s compliance with these ten principles should be directed to the Privacy Officer. The Privacy Officer will investigate complaints and ensure that appropriate measures are taken.