PATHWAYS TO EDUCATION CANADA (“Pathways”) is dedicated to protecting the privacy and security of your personal information under our control, and maintaining our trusting relationship with you. In an effort to ensure an appropriate standard of care, Pathways commits to the principles, as outlined in the Canadian Standards Association’s Model Code for the Protection of Personal Information (CAN/CSA-Q830-96) and adopted by provincial and federal legislation:
“Personal information” is any information that can be used to distinguish, identify or contact a specific individual, other than an individual’s business contact information that is used to communicate with the individual in relation to their business, employment or profession.
Personal information does not include anonymous or aggregate information that cannot be tracked back to you personally.
Pathways accepts full responsibility for the personal information under our control and has established internal procedures to comply with the Canadian Standards Association’s Model Code for the Protection of Personal Information.
- Pathways ensures that any third parties with access to Personal Information provide a level of protection comparable to that provided under Pathways’ policy.
- Pathways has established practices to protect personal information.
2. IDENTIFYING PURPOSES
Personal Information is collected for purpose such as the following:
- Financial information, such as banking and credit card information is collected to receive and process donations. In addition, we collect contact information to acknowledge donations and issue tax receipts;
- Information is collected from individuals who make inquiries to Pathways via a variety of support channels in order to provide assistance;
- Contact information is collected to both inform you of, and to request your support, because you have demonstrated an interest in supporting Pathways’ mission;
- Information is collected from stakeholders for administrative or management purposes, such as to establish or manage a volunteer or employment relationship;
- Information is collected on past, current, and prospective donors to establish giving patterns and engagement opportunities;
- Information is collected on current and past Program participants in order to evaluate and improve the effectiveness of the Pathways Program and also to allow us to track and pay the scholarships students have earned, and document student and alumni stories;
- Contact and educational/career information about our alumni is collected in order to contact them about alumni activities, career opportunities and other Pathways news; and
- Any information that is needed to meet legal or regulatory requirements imposed upon Pathways from time to time will be collected as deemed necessary.
- We collect, use or disclose your Personal Information with your permission. Your permission may be expressed orally, in writing or may be implied, and you may give it to us orally, electronically or in writing. You may limit or opt-out of future contact by providing us notification at [email protected]
4. LIMITING COLLECTION
Pathways limits the collection of personal information to that which is necessary for the purposes identified by Pathways (see #2. Identifying Purposes). Personal information is collected by fair and lawful means
5. LIMITING USE DISCLOSURE AND RETENTION
Personal Information will not be used or disclosed for purposes other than those for which it was collected, except with consent or as required by law. Personal Information will be retained only as long as necessary for the fulfillment of those purposes.
Pathways to Education Canada does not trade, rent or sell any Personal Information to third parties.
Pathways makes reasonable efforts to keep personal information as accurate, complete and up-to-date as is necessary to fulfil the purposes for which the information is to be used. Pathways relies upon the individuals who provide us with their personal information to ensure its accuracy and completeness.
Personal Information is protected with security safeguards appropriate to the sensitivity of the information. Safeguards involve physical, organizational and technical measures and include regular reviews of compliance initiatives.
Any questions or concerns may be addressed to Pathways Privacy Officer at [email protected]
9. INDIVIDUAL ACCESS
Pathways informs individuals of the existence, use and disclosure of their personal information upon request, and gives the individual access to that information. Individuals are given the opportunity to challenge the accuracy and completeness of their information and have it amended as appropriate.
10. CHALLENGING COMPLIANCE
An individual can address a challenge concerning Pathways’ compliance with the principles set out in this Privacy Code to the Privacy Officer. Pathways has procedures in place to receive, investigate, respond to and track concerns or complaints about Pathways’ management of personal information.
Our websites may automatically record some general information about your visit in order for Pathways to engage in web statistical analysis using Google Analytics. We want to make sure our sites are useful to visitors, and ensure we engage in targeted advertising responsibly, such that individuals receive information that is relevant to their needs and interests. User information gathered may include the:
• Internet domain for your Internet service provider, such as “company.com” or “service.ca” and the IP address of the computer you are using to access Pathways’ website
Type of device used to access our site;
• Type of browser you are using, such as Internet Explorer, Firefox or Chrome;
• Type of operating system you are using such as Windows or Macintosh;
• Date and time of the visit to our site, the pages of our site that were visited, and the address of the previous website you were visiting if you linked to us from another website
• Age category, gender, and affinity interests as determined by demographic and interest reports available through Google Analytics.
Data collected for web analytics purposes may be processed in any country where Google operates servers, and thus may be subject to the governing legislation of that country.
We also use “cookies” that identify you as a return visitor and which can help us tailor information to suit your individual preferences. A cookie is a small text file that a website can send to your browser, which may then store the cookie on your hard drive. The goal is to save you time next time you visit, provide you with a more meaningful visit, and measure website activity. Cookies in and of themselves cannot be used to reveal your identity. Many browsers, however, allow you to disable cookie collection if you wish, or inform you when a cookie is being stored on your hard drive.
OTHER IMPORTANT NOTES REGARDING OUR WEB PRACTICES
Pathways also provides links to other websites which we believe may be of interest to you. We are not responsible for the privacy practices of these other sites. We encourage you to read the privacy statements of each and every website that requests personal information from you.
THIRD PARTY SOCIAL MEDIA
Pathways’ use of social media serves as an extension of our presence on the Internet. Social media account(s) are public and are not hosted on Pathways’ servers. Users who choose to interact with Pathways via social media should read the terms of service and privacy policies of these third-party services/applications.
We may offer you the opportunity to engage with our content through third party social networking websites and applications. When you engage with our content this way, you may allow us to have access to certain information associated with your social media account (e.g. name, username, e-mail address, picture) to deliver the content or as part of the website or application. We may use this information to confirm your identity and to personalize your experience.
SPECIAL NOTE FOR PARENTS
Pathways’ websites are not directed at children, and we request that children under the age of 13 not provide personal information through our sites.
No method of transmitting or storing data is 100% secure. As a result, although we strive to protect your personal information, we cannot guarantee the security of any information you transmit to us through or in connection with Pathways websites. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), you must immediately notify us of the problem in order for Pathways to resolve the issue in a timely manner. Also keep in mind that e-mail is not a secure form of communication so never send sensitive personal information to us via e-mail. Examples of sensitive information include social insurance numbers or credit card numbers.
REVISIONS TO THIS POLICY
Director, Marketing and Communications (Privacy Officer)
Or in writing at:
Pathways to Education Canada
439 University Ave., Unit 1600
Toronto, Ontario, M5G1Y8
Attn: Colleen Ryan (Privacy Officer)