DOES THIS POLICY APPLY TO ME?
It is STARS’ policy to comply with the privacy legislation within each jurisdiction in which we operate. Sometimes the privacy legislation and an individual’s right to privacy are different from one jurisdiction to another. For example, we may provide you with health related services or with services on behalf of a public body. As a result, your personal information may be protected by various health information or public sector privacy laws or by various private sector privacy laws.
This privacy statement has been created to address the specific privacy concerns of individuals (other than our employees and volunteers) to whom we provide services directly or with whom we interact as we undertake our commercial activities. Questions concerning information that is related to the health related services that we provide or the services that we provide on behalf of various public bodies should be directed to our Privacy Officer.
This Policy has a limited scope and application and the rights and obligations contained in this Policy may not be available to all individuals or in all jurisdictions. This Privacy Statement covers only those activities that are subject to the provisions of Canada’s federal and provincial private sector privacy laws, as applicable.
WHO IS STARS?
In this Policy, STARS refers to the Shock Trauma Air Rescue Serviceand the Shock Trauma Air Rescue Service Foundation (“STARS Foundation”) (each of which are non-profit and registered charitable organizations).
WHAT IS PERSONAL INFORMATION?
WHAT PERSONAL INFORMATION DOES STARS COLLECT?
We collect and maintain different types of personal information in respect of the individuals with whom we interact. This includes:
- contact and identification information, such as your name, address, telephone number and e-mail address;
- product and service related information concerning the products and services that we provide to, or receive from, you;
- donation and support information such as the nature of the support provided;
- payment information such as your method of payment; and
- information that you freely provide to us, such as your feedback and comments.
Sometimes we collect information (e.g., surveys, focus groups or comment cards) concerning market trends impacting our activities so that we can better understand and serve our stakeholders’ and community needs and develop our strategic plans. We may also collect information related to our donor campaign, media and public relations activities.
As a general rule, STARS collects personal information directly from you. In most circumstances where the personal information that STARS collects about you is held by a third party, we will endeavour to obtain your permission before we seek out this information from such sources. Such permission may be given directly by you, or implied from your actions.
From time to time, we may utilize the services of third parties in carrying out our activities and may also receive personal information collected by those third parties in the course of the performance of their services for us or otherwise. Where this is the case, we will take reasonable steps to ensure that such third parties have represented to us that they have the right to disclose your personal information to us.
Where permitted or required by applicable law or regulatory requirements, we may collect information about you without your knowledge or consent.
WHY DOES STARS COLLECT PERSONAL INFORMATION?
STARS collects personal information to enable us to manage, maintain, and develop our operations and delivery of services, including:
- to establish, maintain and manage our relationship with you so that we may provide you with, or receive from you, the programs, products and services that have been requested, such as health information if you are carried on a mission; name, address and contact information if you wish to volunteer for STARS, etc.;
- to enable us to undertake our fund-raising and charitable activities (for example, we may send you our newsletters, information concerning upcoming campaigns, provide tax receipts and/or thank you letters for your donations and respond to any special requests, such as specific memorials, that you may have);
- to be able to comply with your requests (for example, if you prefer to be contacted at a business or residential telephone number and advise us of your preference, we will use this information to contact you at that number);
- to, as we noted above, enable us to understand market trends and community needs so that we may better serve our stakeholders and community and develop our strategic plans;
- to protect us against error, fraud, theft and damage to our goods and property;
- to enable us to comply with applicable law or regulatory requirements; and
- any other reasonable purpose to which you consent.
SITE SECURITY & MONITORING
In the course of conducting our operations, we may monitor the activities of individuals in respect of our operations and our property. For example, some of our site locations are equipped with surveillance cameras. These cameras are generally in high risk areas or entrances to our facilities. Where in use, surveillance cameras are there for the protection of employees, volunteers and third parties, and to protect against theft, vandalism and damage to our goods and property. Generally, recorded images are routinely destroyed and not shared with third parties unless there is suspicion of a crime, in which case they may be turned over to the police or other appropriate government agency or authority.
This is not meant to suggest that all individuals will in fact be monitored or their actions subject to surveillance. It is meant to bring to your attention that such monitoring may occur and may result in the collection of personal information from you.
HOW DO WE USE AND DISCLOSE YOUR PERSONAL INFORMATION?
We may use or disclose your personal information:
- for the purposes described in this Policy; or
- for any additional purposes that STARS advises you of and where, if your consent is required by law, we have obtained your consent in respect of the use or disclosure of your personal information.
We may use your personal information without your knowledge or consent where we are permitted or required by applicable law or regulatory requirements to do so.
WHEN AND TO WHOM DOES STARS DISCLOSE YOUR PERSONAL INFORMATION?
We may share your personal information with those of our employees, volunteers, contractors, consultants and other parties who require such information to assist us with managing our relationship with you, including: third parties that provide services to us or on our behalf; third parties that collaborate with STARS in the provision of services to you; and, third parties whose services we use to perform our services. For example, your information may be disclosed to a direct mail processing company to mail to you the latest STARS newsletter. Further, your personal information may be disclosed:
- as permitted or required by applicable law or regulatory requirements;
- to comply with valid legal processes such as search warrants, subpoenas or court orders;
- as part of STARS’ regular reporting activities;
- to protect the rights and property of STARS;
- during emergency situations or where necessary to protect the safety of a person or group of persons;
- where the personal information is publicly available; or
- with your consent where such consent is required by law.
Rest assured, we are not in the business of selling, renting or giving away your personal information to third parties for the purpose of allowing others to market their wares or services to you.
OUR COMMITMENT TO PRIVACY
At STARS, we take your privacy seriously. As a non-profit organization, we believe it is important to point out that Canada’s private sector privacy legislation generally only applies to our commercial activities, such as selling STARS merchandise, and not to our other activities such as the services that we provide on behalf of certain public bodies or our fundraising activities. That being said, we believe it is important to confirm to you that we endeavour to undertake our activities in a manner that respects your privacy.
Typically, where your consent is required by law, we will seek your consent at the time that we collect your personal information. In certain circumstances, your consent may be obtained after collection but prior to our use or disclosure of your personal information. If we plan to use or disclose your personal information for a purpose not previously identified (either in this privacy statement or separately), we will endeavor to advise you of that purpose before such use or disclosure.
To the extent that your consent is required, we will assume, unless you advise us otherwise, that you have consented to STARS collecting, using and disclosing your personal information for the purposes stated above (including any other purposes stated or reasonably implied at the time such personal information was provided to us).
Where your consent was required for our collection, use or disclosure of your personal information, you may, at any time, subject to legal or contractual restrictions and reasonable notice, withdraw your consent. All communications with respect to such withdrawal or variation of consent should be in writing and addressed to our Privacy Officer.
In certain circumstances, we may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law or regulatory requirements.
HOW IS YOUR PERSONAL INFORMATION PROTECTED?
STARS endeavors to maintain physical, technical and procedural safeguards that are appropriate to the sensitivity of the personal information in question. These safeguards are designed to prevent your personal information from loss and unauthorized access, copying, use, modification or disclosure.
HOW LONG IS YOUR PERSONAL INFORMATION RETAINED?
Except as otherwise permitted or required by applicable law or regulatory requirements, STARS endeavors to retain your personal information only for as long as it believes is necessary to fulfill the purposes for which the personal information was collected (including, for the purpose of meeting any legal, accounting or other reporting or record retention requirements or obligations). We may, instead of destroying or erasing your personal information, make it anonymous such that it cannot be associated with or tracked back to you.
UPDATING YOUR PERSONAL INFORMATION
It is important that the information contained in our records is both accurate and current. If your personal information happens to change during the course of your relationship with STARS, please keep us informed of such changes.
In some circumstances, we may not agree with your request to change your personal information and may instead append an alternative text to the record in question.
ACCESS TO YOUR PERSONAL INFORMATION
You can ask to see the personal information that we hold about you. If you want to review, verify or correct your personal information, please contact our Privacy Officer using the contact information set out below. Please note that any such communication must be in writing.
When requesting access to your personal information, please note that we may request specific information from you to enable us to confirm your identity and right to access, as well as to search for and provide you with the personal information that we hold about you. We may charge you a fee to access your personal information; however, we will advise you of any fee in advance. Note, we may require a deposit before your access request is processed. If you require assistance in preparing your request, please contact the office of our Privacy Officer.
Your right to access the personal information that we hold about you is not absolute. There are instances where applicable law or regulatory requirements allow or require us to refuse to provide some or all of the personal information that we hold about you. In addition, the personal information may have been destroyed, erased or made anonymous in accordance with our record retention obligations and practices.
In the event that we cannot provide you with access to your personal information, we will endeavour to inform you of the reasons why, subject to any legal or regulatory restrictions.
INQUIRIES OR CONCERNS?
We will endeavor to answer your questions and advise you of any steps taken to address the issues raised by you. If you are unsatisfied with our response, you may be entitled to make a written submission to the Privacy Commissioner applicable for your jurisdiction.