Privacy Policy

Last modified: March 28, 2023

Privacy Policy

Iranian Women’s Organization of Ontario (IWOO) (“we” or “the organization”) is committed to protecting the privacy of its members, employees, donors, volunteers, and other stakeholders. We value your trust and recognize that maintaining this trust requires us to be transparent and accountable in how we treat the personal information shared with us.

During the course of our various activities, we frequently gather and use personal information. This information may be obtained directly from you or collected from third parties that have the right to disclose this information to us.

 We will only use your personal information in accordance with this policy unless otherwise required by applicable law. We take steps to ensure that the personal information that we collect about you is adequate, relevant, not excessive, and used for limited purposes.

 Our policy regarding how personal information entrusted to us is collected, used, disclosed or retained reflects the principles set forth in the Personal Information Protection and Electronic Documents Act (Canada).

What is Personal Information?

Personal information is any information that contributes to the identification of an individual and includes details that can be used to distinguish, identify or contact a specific individual.

Business contact information and certain publicly available information, such as names, addresses and telephone numbers as published in telephone directories, are not considered personal information in this context.

Personal information collected by IWOO

IWOO may collect personal information to support program and service delivery, to establish, maintain and manage our relationship with our members, employees, donors and volunteers, and for research, fundraising and public education purposes.

IWOO collects personal information when an individual:

1. Registers to become a member or access IWOO services.
2. Registers for an event
3. Participates in any interactive feature of our websites
4. Makes a donation.
5. Sponsors an event.
6. Become an employee or volunteer.
7. Contacts us with an enquiry, comment or suggestion
8. Subscribes to a mailing list or follows IWOO’s social media accounts

 Personal information collected may include:

1. Name
2. Contact information such as home address, telephone number, e-mail address (when e-mail message was sent to IWOO through the website, the time the message was sent and the IP address from which it was sent is automatically collected)
3. Demographic information such as age and gender
4. Health information (in any offered programs where such information may be relevant)
5. Credit card or bank account information you provide for IWOO membership or any other paid event
6. Language and communications preferences
7. Service or event-specific information such as name and phone number of an emergency contact individual, dietary restrictions and accommodation preferences.

Use of personal information

Members

Registering for a service or event

When a member registers for an IWOO service or event, they may be asked for personal information such as name, email address, mailing address, phone number emergency contact information, special dietary requirements and accommodation preferences.

 We collect this information to facilitate participation in the event and to provide the services requested. We will use the emergency contact information only as required in the event of an emergency.

 This information is collected to identify the individual, recommend/deliver specific services or technical aids, or for research purposes.  Personal information may be used to contact the individual or the individual’s designated contact (if any) when necessary. With the individual’s permission, IWOO may also send them information about other programs or services of interest. An individual may opt out of receiving such communications at any time by contacting us as set out in the “Contact us” section below.

 Registering online

When registering online, the individual may choose to provide IWOO with information about their personal interests. We use this information in order to send the individual information geared to their interests. An individual may change their personal interests at any time by updating their profile.

IWOO may sometimes use e-mail addresses and phone numbers to investigate activity that may violate the terms of acceptable use associated with a particular IWOO service or program offering.

Employees and Volunteers

Access by employee and volunteer to their personal information

Access to personal information is restricted to authorized employees who have a legitimate reason to access it. An employee or volunteer may access and verify his/her personal information subject to some exceptions, for example, the law requires that we refuse access to information that would reveal personal information about another individual. If access is refused, the reason for refusal will be provided. 

Employees’ personal information

IWOO uses personal information about employees in order to establish, manage and terminate the employment relationship.  This includes:

1. Personal information collected in the hiring process, including information on resumes and application forms (contact information, personal and professional history, qualifications, emergency contact information, results of criminal records checks, information collected from references)
2. Payroll information including, social insurance number, rate of pay, hours of work, deductions, bank account information, any court orders
3. Benefit information including premiums or contributions, coverage information, date of birth, marital status, dependent information, medical information
4. Performance information including work history, performance reviews, discipline and related notes, documentation on job qualifications, internal competition information
5. For other purposes identified when the information is collected.

Volunteers’ personal information

IWOO uses personal information about volunteers for the purposes of recruiting volunteers, establishing and managing an effective volunteer program, and for other purposes identified when the information is collected.  This includes:

1. Personal information collected in the recruiting process including information on application forms (contact information, personal and professional history, qualifications) and information collected from references
2. Information related to the volunteer’s services including availability, schedule, duties, and notes related to volunteer qualifications

 Donors and other stakeholders

When a donation is made, IWOO collects the donor’s name, address, and credit card or bank information for the purpose of processing the donation and issuing a tax receipt. As a form of appreciation, and to remind others of the ongoing need for support, IWOO may publicly recognize the donor’s name, unless the donor indicates their preference not to be recognized in any way. The donor’s name may be published in association with the range of the dollar amount of the donation.

Donations may also be made in honour or in memory of someone, or to sponsor a participant in one of our events. IWOO collects personal information about the recipient of the donation, or the family of the recipient in the case of a donation in memory, such as their name, addresses and contact information. We collect this personal information in order to notify the recipient of the donation. We do not use or disclose the recipient’s personal information for any other purpose unless they give us permission to do so. The donor has the option to decide whether they would like to be identified as the sender of the donation. We do not publish the amount of any donation made in honour or in memory. As the sponsor of a participant in one of our events, the donor has the option to decide whether or not the amount of the donation may be publicly available.

Opportunity to provide IWOO financial support

IWOO may occasionally provide its members, employees, volunteers and other stakeholders with the opportunity to donate to IWOO through our direct mail, telemarketing or other fundraising programs. We collect and keep only as much personal information about donors and prospective donors as we need in order to raise funds efficiently. To ensure we offer opportunities of interest to the individual, our philanthropy staff will know you are a member, the year you became a member, and which services or programs you use. You may opt out of receiving donation opportunities by contacting us as set out in the “Contact us” section below.

 Mailing lists and newsletters

If an individual signs up for a mailing list, IWOO uses their email to send information including but not limited to notice of events and programs. IWOO provides regular communications to its members, employees, donors, volunteers and other stakeholders through electronic mail and social media. Any personally identifiable information provided by you will be used for the purpose of delivering electronic mail, research and/or marketing. An individual may opt out of receiving such communications at any time by contacting us as set out in the “Contact us” section below.

 Website information

Generally, individuals can visit our website without providing us with any personal information. The site does use cookies and click-through tracking software. The site also logs information such as device details (e.g. mobile, tablet), IP address (a number that is automatically assigned to the individual’s computer or device when used to browse the Internet and from which the general geographical location of the device can be derived), and other related information such as page requests, browser types (e.g. Explorer, Chrome, Safari or Firefox), operating systems, date and average time spent on our Website. This information is used to analyze and understand site usage (e.g. which pages or sections are most popular and the times of peak activity), and generally to assist in planning for future improvements to our service.

 During the course of any visit to our website, the pages viewed, along with a short text file called a ‘cookie,’ are downloaded to the individual’s computer. Many websites do this because cookies enable website publishers to do useful things such as find out whether the computer has connected with the website before. This is done on a repeat visit by viewing the cookie left there on the last visit. Cookies, by themselves, do not provide an individual’s email address or other personal information unless the individual chooses to provide this information.

The “help” portion of the toolbar on most browsers shows how to prevent the browser from accepting new cookies, how to have the browser notify when a new cookie is received, or how to disable cookies altogether.

 Disclosure of personal information

Individuals have a right to limit what happens to their personal information; that is to say, with whom it may be shared and for what purpose.  IWOO  does not disclose, rent, sell or otherwise disclose personal information without the individual’s consent, except as set out in this Privacy Policy or as otherwise required or permitted by law.

 Member information

We will disclose an individual’s personal information internally only to employees and volunteers who need to know in order to provide and support the services the individual has requested.

 Research

From time to time IWOO may conduct research through surveys, interviews with members or by using IWOO member information. In all cases members are informed that the information they are providing is being used for research purposes only and that all information will be kept confidential. Participants are given a unique study ID number that is anonymous and not identifiable. All data and recordings of interviews are restricted to members of the research team. There is no disclosure of participant information to outside people or researcher organizations outside IWOO and no names are used in any discussion within the research team. Members’ names are not included in any printed material that is part of the research study, or in any publications concerning the research. All information acquired during the research is saved in a locked folder on an IWOO internal database. Only members of the research team have access. Audio files )if applicable) are deleted once they have been transcribed to the secure database.

 Member lists are not provided to outside organizations for the purpose of research. On occasion, IWOO research may contact members on behalf of an external organization or agency and ask if they are willing to participate in research conducted by an outside agency. They are fully informed that their participation is entirely voluntary, is confidential and is in no way linked to their membership at IWOO.

Employee and volunteer personal information

IWOO may disclose personal information of an employee or volunteer to others solely in connection

with the purpose for which the information was collected, as consented to by the individual, or as required or permitted by law.

If an employee or volunteer wishes to limit the sharing of their personal information as permitted by law, the individual may submit a request to the Board of Directors specifying which items of personal information are to be limited and to whom these items are to be restricted. The Board will advise the individual whether the requested information can be restricted as requested.

 Outside service providers

The term ‘outside service provider’ includes vendors, consultants and service delivery partners or agencies.

IWOO may contract with outside service providers to perform certain services on its behalf.  These organizations are given only the information necessary to perform those services, and we take steps to ensure that such information is securely transferred and stored and is used only for the purposes intended.

 Service providers with whom we share personal information may perform activities in the United States or another country in which case personal information is subject to laws in the United States or that other country. For example, personal information may be shared in response to valid demands from government authorities, courts and law enforcement officials in the country where the data resides.

 IWOO agreements with service providers set out our expectations regarding privacy and protection of personal information; specifically, they require that the service provider:

1. Maintain the confidentiality and security of personal information provided by IWOO and use it only in compliance with applicable privacy laws.
2. Prohibit access, use or disclosure of personal information for any purpose other than providing the services covered by the agreement.
3. Report immediately to IWOO any access, use or disclosure of personal information provided by IWOO other than for the provision of the services covered by the agreement. 
4. Provide access controls and safeguards for the secure management, retention and destruction of personal information provided, as applicable.
5. Consistent with IWOO’s legal obligations to protect the privacy of personal information in its care, the service provider affords IWOO the right to audit its compliance with our privacy requirements or provide a copy of its most recent independent information security and/or privacy audit.

 IWOO will not provide personal information to an outside service provider if de-identified or aggregate information will serve the purpose.

IWOO and our service providers may provide personal information in response to a legal requirement to do so, or in the case of a breach of agreement or infringement of law to a fact-finding entity, or as otherwise required or permitted by law.

Social Media / Forums

If you voluntarily submit or post any information, photographs or other content to any IWOO forums, Twitter pages, Facebook pages or other social networking pages/sites, certain elements of your personal information may be automatically included in the posting, including your user name and email address, and this information may be collected and used by others. IWOO has no control over and is not liable for the collection, use or disclosure of any posted user content by users of such forums and social media networking pages. Any personal information posted, used or disclosed via such sites is not subject to this Policy.

 Legal requirement

IWOO may disclose your personal information to a government institution that has asserted its lawful authority to obtain the information or where we have reasonable grounds to believe the information could be useful in the investigation of unlawful activity, or to comply with a subpoena or warrant or an order made by a court, person or body with jurisdiction to compel the disclosure of information, or to comply with court rules regarding the disclosure of records and information, or to protect the rights and property of IWOO or otherwise as permitted or required by law.

Security – Safeguarding personal information

IWOO takes reasonable measures to ensure that our systems keep personal information safe from loss or theft, unauthorized access, use, copying, disclosure or modification.  Safeguards include but not limited to:

1. Designated systems security officer accountable for information security controls and ongoing oversight to strengthen IWOO information security
2. Firewalls, intrusion-detection, anti-virus, strong passwords, inactivity based screen lock, mandatory PDA access control and other software solutions for technical security
3. Confidentiality sign-off by all employees and Board of Directors
4. Orientation, familiarizing and training staff on our Privacy Policy and practices, and an ongoing emphasis on the importance of safeguarding any personal information to which they are privy.

 

Retention and disposal of personal information

The length of time IWOO keeps personal information varies depending on the service and the type of information. Personal information is kept for as long as it may be reasonably needed for service, research, legal or business purposes. When personal information is no longer required for these purposes, it is securely destroyed or deleted. 

Access to and correction of personal information

Individuals have the right to access and correct inaccuracies in the personal information IWOO has about them in our records.  To do so, they should contact IWOO as described in the “Contact us” section below. To protect individual privacy, IWOO will take reasonable steps to help verify the individual’s identity before granting access or making corrections to personal information.

 Privacy breach

As soon as IWOO becomes aware of a possible infringement of our Privacy Policy, we will take immediate action to contain, investigate and remediate the situation and communicate with affected parties, as required by law and our breach management practice.

 Linking to outside websites

Links to third-party websites from IWOO’s website are provided for the convenience of our users. IWOO has no control over, and therefore has no responsibility or liability for, the manner in which the organizations that operate such linked websites may collect, use, disclose or otherwise treat your personal information. The inclusion of any link does not imply IWOO’s endorsement of any other organization, its websites, or its products and/or services.

 Changes to Privacy Policy

The Privacy Policy may be updated periodically to reflect changes to our personal information practices. Such changes will be posted on the IWOO website.

 Contact us

To review or update your personal information in IWOO’s possession, or withdraw consent for the collection, use and/or disclosure of your personal information or name from an email or other mail list, please contact us at:

1761 Sheppard Ave. East, Ground Floor, Toronto, ON M2J 0A5 (416) 496-9566, or by email at [email protected]

 Individuals have the right to challenge our compliance with applicable privacy legislation.  For any inquiries or comments about this Privacy Policy, contact IWOO at (416) 496-9566 or by email at [email protected]

 Further information on privacy in general and on individual rights in regard to personal information is available on the website of the Privacy Commissioner of Canada.