Personal Information Privacy Statement

The Hoeffener International Ministries is committed to protecting the privacy of the people it serves and their immediate family, its donors, volunteers, prayer partners, employees, directors, officers and any other persons about or from whom Hoeffener International Charities collects personal information and complies with all applicable privacy laws. Hoeffener International Charities embraces the principles of the Canadian Standards Association Model Code for the Protection of Personal Information to ensure that all personal information including personal health information as defined by the Personal Health Information Protection Act is properly collected, used and disclosed only for the purposes for which it is collected and that it is properly safeguarded while it is retained by Hoeffener International Charities and is disposed of in a safe and timely manner when no longer required.

As such Hoeffener International Charities has developed a formal Policy which sets out how it will deal with the personal information it collects.

Personal information collected by Hoeffener International Charities may take on a commercial purpose if it is sold, rented, leased or otherwise used to facilitate the transfer of goods or services in exchange for money or other consideration. It is in these areas that personal information is collected, used and disclosed and is protected by privacy legislation.

In accordance with Hoeffener International Charities’ Policy, no personal information collected by it will be used or disclosed to any other person for a commercial purpose without the consent of the individual. Except as otherwise required by the operation of law, every person has the right, in accordance with the policy provisions, at any time, to withdraw his or her consent.

Other persons or organizations that act for, or on behalf of, Hoeffener International Charities are required to undertake compliance with the Policy and will be given restricted access to personal information solely to perform the services they may be retained to perform for Hoeffener International Charities.

Hoeffener International Charities has designated Kristen Inkster to be its Personal Information Compliance Officer. Any inquiry, request or concern related to privacy matters should be made in writing to Kristen Inkster, who may be contacted at:
Personal Information Compliance Officer
Hoeffener International Charities
4278 King Street East
Kitchener, ON N2P 2G5
kinkster@christian-horizons.org

Privacy Procedures

Personal Information – its Collection, Use and Disclosure

Hoeffener International Charities collects personal information, including personal health information, about the people it serves directly from those individuals or from persons acting on behalf of those individuals. The personal health information which Hoeffener International Charities collects may include health histories and records. Hoeffener International Charities will usually collect personal health information directly from those it serves or their families or substitute decision makers, or from health information custodians who are involved in the treatment of the individuals that Hoeffener International Charities serves. Hoeffener International Charities will only collect, use and disclose personal information in accordance with its privacy policy.

Information Request Procedure

To access your personal information on file with Hoeffener International Charities, please send a written request to the Personal Information Compliance Officer at the address above. You may be asked to give sufficient information to permit Hoeffener International Charities to provide an account of your personal information. Hoeffener International Charities will endeavor to provide you with access to the information within 30 days. If an extension is required, the Personal Information Compliance Officer will inform you in writing before the end of the first 30-day period of the need for an extension.

Information Correction Procedure

To correct any personal information on file with Hoeffener International Charities, please send a written update of information to the Personal Information Compliance Officer, at the address noted above. You may be asked to give information that demonstrates the inaccuracy or incompleteness of personal information, and information will be amended as required.

Inquiries and Complaints Procedure

To make an inquiry or issue a complaint regarding the handling of your personal information, please send a written request to the Personal Information Compliance Officer at the above address. This written request should include a consent to use your personal information for an investigation into the complaint. The Personal Information Compliance Officer of Hoeffener International Charities will investigate the complaint or inquiry. If a complaint is found to be justified, appropriate measures will be taken. The Personal Information Compliance Officer will notify you of the findings of the investigation and corrective action taken, if any.

Privacy Policy

Hoeffener International Charities, in accordance with applicable privacy laws, is committed to protecting the privacy of its supported individuals, employees, volunteers, directors and officers and any other persons about or from whom Hoeffener International Charities collects personal information.

Hoeffener International Charities 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.

Personal information in this policy means the information about an identifiable individual except the individual’s name, business address, business telephone number and business title. Personal information also includes personal health information as it is defined in the Personal Health Information Protection Act.

1. Accountability

Hoeffener International Charities is responsible for maintaining and protecting the personal information under its control. Hoeffener International Charities has appointed a Personal Information Compliance Officer who is responsible to ensure that Hoeffener International Charities complies with its privacy obligations in accordance with applicable privacy laws.

2. Identifying Purposes

Hoeffener International Charities collects and uses personal information for a variety of purposes including, but not limited to,

• providing services, including care, to individuals supported by Hoeffener International Charities;
• providing care to immediate family members of individuals supported by Hoeffener International Charities;
• establishing and maintaining the appropriate level of care and interaction with corporate members, members of the religious order, volunteers and prayer partners;
• managing payroll and benefits for staff;
• staff performance evaluations;
• establishing and maintaining an appropriate level of donor care and interaction;
• providing information to other individuals who request to be placed on our mailing list;
• conducting risk management activity; and
• conducting quality improvement activities.

Hoeffener International Charities 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 for any commercial purpose.

3. Consent

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 the person’s conduct and relationship with Hoeffener International Charities. 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. Except as otherwise required by the operation of law, every person has the right, at any time, to withdraw his or her consent, in accordance with the policy provisions. The ability of Hoeffener International Charities to provide services to individuals may be adversely affected by such withdrawal of consent.

4. Limiting Collection

Information collected will be limited to that required for the purpose or purposes identified by Hoeffener International Charities. Hoeffener International Charities is committed to collecting personal information in a fair, open and lawful manner.

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 the consent of the person or as required by law. All collected personal information will be destroyed, erased or made anonymous as soon as the purpose for which it was collected is fulfilled or completed.

Where personal health information is received from a health information custodian, Hoeffener International Charities will use, disclose and retain that personal health information in accordance with any limitations, restrictions that have been imposed on or by the health information custodian who has provided the personal health information to Hoeffener International Charities.

6. Accuracy

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.

7. Safeguards

Personal information will be protected by security safeguards that are appropriate to the sensitivity of the personal information. This safeguarding may include physical measures such as locked filing cabinets and premises security, organizational measures such as restricted access to files with personal information or technological measures such as security software.

8. Openness

Information regarding the personal information policy of Hoeffener International Charities, as well as the personal information management, will be publicly available on its website. The information will include:

• Name and address of Personal Information Compliance Officer
• Means of gaining access to personal information held by the organization
• Copy of any information that explains the organization’s policies, standards or codes

9. Access to Personal Information

The general principle with respect to access to personal information is that each individual has the right to access their own personal information. Hoeffener International Charities will provide access upon written request. The existence, use and disclosure of the personal information will be granted within a reasonable amount of time. Any inaccuracy or incompleteness of personal information will be amended as required.

There may be some instances where access to personal information will not be granted as a result of legal requirements.

Where access to the personal health information is requested, Hoeffener International Charities will advise the health information custodian who provided the information of the request so that the health information custodian can deal directly with the individual requesting access to his/her personal health information.

10. Challenging Compliance

Complaints or inquiries about the collection, use, disclosure or retention of personal information and Hoeffener International Charities’ compliance with these ten principles should be directed to the Personal Information Compliance Officer. The Personal Information Compliance Officer will investigate complaints and ensure appropriate measures are taken.