Privacy Policy

Principle 1 – Accountability

Strategic Communications is responsible for personal information under its control and shall designate one or more persons who are accountable for Strategic Communications compliance with the following principles.

Responsibility for compliance with the provisions of the Strategic Communications Privacy Policy rests with the Strategic Communications Privacy Officer who can be reached by e-mail at privacy@stratcom.ca or by mail at 1090 Homer Street, Suite 300, Vancouver BC V6B 2W9. Other individuals within Strategic Communications may be delegated to act on behalf of the Privacy Officer or to take responsibility for the day-to-day collection and/or processing of personal information.

Strategic Communications is responsible for personal information in its possession or control and shall use contractual or other means to provide a comparable level of protection while information is being processed or used by a third party.

Principle 2 – Identifying Purposes for Collection of Personal Information

Strategic Communications shall identify the purposes for which personal information is collected at or before the time the information is collected.

Strategic Communications collects personal information from the public only for the following purposes:

Further reference to “identified purposes” mean the purposes identified in this principle.

Strategic Communications shall specify orally, electronically or in writing the identified purposes to the individual being contacted at or before the time personal information is collected. Upon request,
persons collecting personal information shall explain these identified purposes or refer the individual to a designated person within Strategic Communications who can explain the purposes.

When personal information that has been collected is to be used or disclosed for a purpose not previously identified, the new purpose shall be identified prior to use. Unless the new purpose is permitted or required by law, the consent of the individual will be acquired before the information will be used or disclosed for the new purpose.

Strategic Communications may provide clients or other third parties with information from any survey, in aggregate form. In aggregate form it is impossible to identify an individual’s personal information.

Principle 3 – Obtaining Consent for Collection, Use or Disclosure of Personal Information

The knowledge and consent of an individual are required for the collection, use, or disclosure of personal information, except where inappropriate.

Participation by individuals in survey research, focus groups, fundraising or communications campaigns is always voluntary. When an individual agrees to donate money, buy a product or service or participate in a survey or advocacy campaign, he/she gives consent to the collection of personal information by participating (through making a donation, participating in an interview, or signing a petition or action card).

Personal information collected is not disclosed to third parties except where it is appropriate for the project, for example the disclosure of member donation information to a client. Occasionally, a client sponsoring a research project may want to contact respondents directly. In these cases, Strategic Communications always explains the reason for the disclosure to the respondent and obtains express permission from the respondent before making any such disclosure.

Individuals are always free to choose whether or not to participate in fundraising calls, surveys etc. They are also free to choose not to answer any specific questions and free to discontinue participation at any time.

In obtaining consent, Strategic Communications shall use reasonable efforts to ensure that individuals are advised of the identified purposes for which personal information will be used or disclosed. The identified purposes shall be stated in a manner that can be reasonably understood by the individual.

Generally, Strategic Communications shall seek consent to use and disclose personal information at the same time it collects the information. However, Strategic Communications may seek consent to use and/ or disclose personal information after it has been collected, but before it is used and/or disclosed for a new purpose.

In determining the appropriate form of consent, Strategic Communications shall take into account the sensitivity of the personal information and the reasonable expectations of its respondents.

The participation of a respondent in a quantitative or qualitative marketing or social research study, or a fundraising or advocacy campaign, may constitute implied consent for Strategic Communications to collect, use and disclose personal information for the identified purposes.

Strategic Communications acknowledges and agrees that all fundraising, sales, advocacy and research data are the property of the client commissioning the research project, and are confidential and shall be used for no other purpose without the explicit permission of the client.

All survey respondents and focus group participants are guaranteed anonymity by Strategic Communications. Survey results are provided to the client in aggregate, or in a format that does not identify full names or contact information of individual respondents.

Principle 4 – Limiting Collection of Personal Information

Strategic Communications shall limit the collection of personal information to that which is necessary for the purposes identified by Strategic Communications. Strategic Communications shall collect personal information by fair and lawful means.

In conducting its business, Strategic Communications limits the amount and type of personal information it collects. We collect only the amount and type of information needed for the purposes identified to individuals.

Strategic Communications collects personal information about an individual primarily from that individual or a member of that individual’s household. Except as permitted by law, Strategic Communications will only collect personal information from external sources, such as client organizations, if individuals have consented to such collection.

Principle 5 – Limiting Use, Disclosure, and Retention of Personal Information

Strategic Communications shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

Strategic Communications may disclose an individual’s personal information to:

Only Strategic Communications’ employees with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about respondents, supporters or members.

Strategic Communications shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law. Depending on the circumstances, where a respondent, supporter or member may have to be re-contacted for purposes of clarifying responses to a survey, or to seek additional responses, Strategic Communications shall retain the personal information for a period of time that is reasonably sufficient to allow this re-contact.

Strategic Communications shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is
no longer necessary or relevant for the identified purposes or required by law to be retained. Such information shall be destroyed, erased or made anonymous.

Principle 6 – Accuracy of Personal Information

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Personal information used by Strategic Communications shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about an individual.

Strategic Communications shall update personal information about respondents, members, supporters and employees as necessary to fulfill the identified purposes or upon notification by the individual.

Principle 7 – Security Safeguards

Strategic Communications shall protect personal information by security safeguards appropriate to the sensitivity of the information.

Strategic Communications shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held.

Strategic Communications shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

All of Strategic Communications’ employees with access to personal information shall be required to respect the confidentiality of that information.

Principle 8 – Openness Concerning Policies and Procedures

Strategic Communications shall make readily available to individuals specific information about its policies and procedures relating to the management of personal information.

Strategic Communications shall make information about its policies and procedures easy to understand, including:

Principle 9 – Individual Access to Personal Information

Upon request, Strategic Communications shall inform an individual of the existence, use, and disclosure of his or her personal information and shall give the individual access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Upon written request to the Privacy Officer, Strategic Communications will inform an individual of the existence, use and disclosure of his/her personal information and shall be given access to that information.

In certain situations, Strategic Communications may not be able to provide access to all the personal information that it holds about a respondent, supporter or member. For example, Strategic

Communications may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual. Also, Strategic Communications may not provide access to information if disclosure would reveal confidential commercial information.

In order to safeguard personal information, a respondent, supporter or member may be required to provide sufficient identification information to permit Strategic Communications to account for the existence, use and disclosure of personal information and to authorize access to the individual’s file. Any such information shall be used only for this purpose.

Strategic Communications shall promptly correct or complete any personal information found to be inaccurate or incomplete. Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file. Where appropriate, Strategic Communications shall transmit to third parties
having access to the personal information in question any amended information or the existence of any unresolved differences.

Respondents supporters, members and employees can obtain information or seek access to their individual files by contacting the Strategic Communications Privacy Officer.

Principle 10 – Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for Strategic Communications’ compliance with the Strategic Communications Privacy Policy.

Strategic Communications shall maintain procedures for addressing and responding to all inquiries or complaints from its respondents regarding Strategic Communications’ handling of personal information.

Strategic Communications shall, on written request, inform its respondents about the existence of these procedures as well as the availability of complaint procedures.

The person or persons accountable for compliance with the Strategic Communications Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

Strategic Communications shall investigate all complaints concerning compliance with its Privacy Policy. If a complaint is found to be justified, Strategic Communications shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures. The complainant shall be informed of the outcome of the investigation regarding his or her complaint.