Privacy Policy

United Way British Columbia (“UWBC”, “we” or “us”) supports the development of healthy, caring, and inclusive communities by strengthening vital connections that support people in need. Serving over 4 million people, we focus on urgent response, children and youth, seniors, poverty, mental health, and food security. UWBC recognizes that our supports and other constituents trust us to treat their information with respect for their privacy and a commitment to protecting the confidentiality of data. We value the trust of those we deal with and of the public, and we recognize that maintaining this trust requires us to be transparent and accountable in maintaining the confidentially of the personal information that you choose to share with us or that we may gather by other lawful means. 

This privacy policy statement outlines the principles that UWBC applies in order to ensure the confidentiality and integrity of your personal information, and helps you understand how we collect, access, use, retain, protect, disclose and dispose of personal information. 

Information 

This policy applies to personal information, including the personal information of prospective, current and past donors, board members, individuals who engage with us on community initiatives, and other stakeholders. 

Personal information refers to information about an identifiable individual. Personal information is information that is recorded in any form, both factual or subjective, and that can be used to distinguish, identify or contact a specific individual. Personal information excludes anonymous or de-identified data that is not associated with a particular individual. Personal information may include details such as your name, contact details, donation information, and transaction records. It does not include certain business contact information, specifically name, title, business address or telephone number of an employee of an organization, when used to contact an individual for business purposes. It does not include certain publicly available information, such as names, addresses, and telephone numbers as published in directories. 

This policy describes the categories of personal information that we collect, how we use your personal information, how we secure your personal information, when we may disclose your personal information to third parties, and when we may transfer your personal information outside of Canada. This policy also describes your rights regarding the personal information that we hold about you and how you can access and correct your personal information. 

We will only use your personal information in accordance with this policy unless otherwise permitted or 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 appropriate purposes 

Activities, Operations, Services, and Channels 

This policy applies to all activities, operations and services of UWBC and to all the channels through which we operate and provide those services, including but not limited to by phone, our website, and events. Including if necessary, amending our policies and practices.

UWBC is an autonomous organization, legally separate from United Way of Canada and other United Ways. While all United Ways share a commitment and respect for personal information privacy, details on how each United Way does so can be obtained by contacting the United Ways individually. 

Minors 

On occasion, we may collect the personal information of minors, as appropriate. In certain circumstances, we may request the consent of a parent/guardian of that minor child to collect that information. 

Privacy Policy Principles 

UWBC embraces the principles of the British Columbia Personal Information Protection Act (PIPA) and manages the collection, access, use, retention, disclosure and disposal of personal information in keeping with those principles. 

The following principles reflect our pledge to protect the privacy of your personal information. 

1. Accountability: 

We are responsible for the personal information under our control. While senior management is ultimately accountable for the protection of personal information, UWBC’s Privacy Officer establishes and monitors appropriate privacy practices and governance. 

We are responsible for personal information in our possession or custody, including information that has been transferred to a third party for handling or administrative purposes. Where we choose to have certain services provided by third party service providers, we select the service provider carefully. We take reasonable precautions to ensure that the service providers protect your personal information. We will use contractual or other means to provide a comparable level of protection when a third party is processing the information. 

All employees, agents (including authorized volunteers) and authorized services providers of UWBC are required to protect the confidentiality of your personal information. All employees and agents are required to sign and adhere to a Code of Conduct which ensures they are informed about the importance of privacy protection. UWBC provides employees and agents with periodic information to ensure they are knowledgeable about our privacy policy, related policies, and privacy developments. 

2. Identifying Personal Information: 

We only collect the personal information that we determine we need for identified purposes below. We may collect relevant information, including your: 

• Name 
• Contact information including telephone number, postal address, and email address 
• Identification documents 
• Date of birth 
• Donor information 
• Event or program participant information 
• Transaction information 
• Communications including when you communicate with us or respond to communications from us via email, chat, audio or video calls, or physical documents 
• Website analytics information, including device information such as information about your operating system, browser, software applications, IP address, geolocation, security status and other similar device information to improve your experience, to protect against fraud, and manage risk. 
• Website use information, such as browsing behaviour on the UWBC website and links, as well as other data gathered from the use of web tools (for example, cookies) to better understand your interests and needs so that we can serve and support you better. 

We obtain personal information about you lawfully and fairly. We may collect personal information about you when you voluntarily provide it to us, from third parties, and/or from sources that are available to the public. You can choose not to provide us with certain information in some situations, but if you make this choice, we may not be able to address your needs. We collect, use and disclose personal information only for certain purposes that we identify to you. The purposes for which we collect the personal information are identified at the time we collect it. 

We may use cameras or other recording devices in and around our premises, in online meetings, and other locations for business activities and the security of our people and property. 

UWBC may, acting reasonably, collect information about identifiable individuals from published or public sources for the purposes of developing relationships with individuals. 

Identifying Purpose: 

We will identify and document the purposes for which we collect, use, or disclose personal information at or before the time of collection. 

The purposes will be limited to those which are related to our business and which a reasonable person would consider appropriate in the circumstances. We collect, use, and disclose personal information about you for various purposes, including to: 

• Establish and verify your identity. 
• Ensure we have accurate and up to date information about you. 
• Administer your involvements with us, including your donations, event participation, community engagements, and contact you about your continued involvement. 
• Process your transactions, including processing donations and payments, redirecting a donation or any part of a donation to another charity as instructed by the donor, issuing tax receipts, confirming renewal of giving, responding to information requests and maintaining a donation history. 
• Support workplace organizations who engage us to run internal employee giving and engagement philanthropy programs which may include information of employees, retirees or contractors of those organizations. 
• Engage and manage prospective, current, and past donor relationships. 
• Establish and maintain the volunteer relationship, including to assist volunteers in performing their volunteering roles and responsibilities and to keep them informed about relevant UWBC activities and the work of UWBC. 
• Know who our donors, volunteers and other supporters are and understand their needs and interests in order to manage and further develop our resources to fulfill our mission and meet their preferences and expectations 
• Respond to your information requests. 
• Communicate with you about the impact of your donation and, about issues and events that may be aligned with your interests. Communication methods may include sending you literature on United Way or inviting you to events or information sessions. 
• Thank you for your contributions. 
• With your consent, publicly recognize your financial or non-financial contributions. 
• Share information with other individuals or organizations, including organizations which you redirect donations to, volunteer at on our behalf, or interact with on our behalf. 
• Generate statistics and aggregate reporting to help us and our partner organizations understand where we can have greater impact on the community. 
• Meet legal and regulatory requirements and inquiries. 
• Investigate legal claims. 
• Protect you and us against fraudulent actors, behaviours and transactions. 
• Protect UWBC against other legal, regulatory, financial, or business risks. 
• Use it as otherwise permitted by law. 

If we plan to use personal information we have collected for a purpose not previously identified, we will identify and document this purpose before such use. 

We will make a reasonable effort to specify the identified purposes, orally or in writing, to the individual from whom the personal information is collected either at the time of collection or after collection but before use. We will state the identified purposes so that an individual can reasonably understand how the information will be used or disclosed. 

We will not sell or rent your personal information to third parties. However, we may communicate personal information where permitted or required by law or for the purposes outlined in this policy. 

Consent 

Personal information will only be collected, used, or disclosed with the knowledge and consent of the individual, or as required by law. 

The way in which we seek consent, including whether it is expressed (orally, electronically or in writing) or implied (by an action or inaction), may vary depending upon the sensitivity of the information and the reasonable expectations of the individual. An individual can withdraw consent at any time, subject to legal or contractual restrictions and reasonable notice. We will inform individuals of any implications of withdrawing consent. 

Typically, we will seek consent for the use or disclosure of information at the time of collection. In certain circumstances, such as where we want to use your personal information for a purpose not previously identified, consent may be sought after the information has been collected but before use. 

You can manage or withdraw your consent and communication preferences at any time by contacting us. To manage your privacy consent and communication preferences, you can reach us by phone, email, or postal mail. We will comply with your change or withdrawal, subject to legal, contractual or technical restrictions. 

3. Limiting Collection 

We will limit the amount and type of personal information collected to that which is necessary for our identified purposes, and we will only collect personal information by fair and lawful means. 

4. 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 individual or as permitted or required by law. 

We will not sell or rent your personal information to third parties. 

We disclose personal information for various purposes, including in the following circumstances: 

• In the case of donors giving through their workplace, your workplace has access to certain personal information in the execution of the Employee Campaign. UWBC is respectful of the donor’s right to privacy and works with the individuals responsible for the Employee Campaign to limit with whom we share the information, and to only share information necessary for the purposes of the campaign. Furthermore, employers may have internal policies on their access and use of employee personal information; UWBC respects and works within the requirements of the organization’s policies. We share information with other United Ways if we administer a donation belonging to another United Way community. We disclose your information only to the specific United Way involved in your donation. 
• If you designate your donation to another charity and have provided consent, we may provide your name, workplace if the donation is part of an Employee Campaign, and designation amount to the selected charity. You may withdraw permission by contacting us. If you do so, we send the donation on an anonymous basis. 
• We may contract with carefully selected third parties to perform services for us or on our behalf. When we select the third parties, we ensure that they use security and privacy standards comparable to our own. When we allow those third parties to access personal information, it is limited only to that which is needed for the third party to complete their contractual obligations to UWBC. Those third parties are not entitled to use or disclose personal information for their own marketing or other purposes. 
• Where a third party hosts an event using UWBC’s systems to register participants, your information may be shared with the host solely for the purposes of managing the event and your participation in the event. 
• We may release personal information to legal or regulatory authorities or law enforcement in cases of suspected or actual criminal activity or contravention of law, for the detection and prevention of fraud, or when required to satisfy the legal or regulatory requirements or governments, regulatory authorities, or their self-regulatory organizations or to comply with a court order or for the protection of our assets.
• In the event of a reorganization, merger, or other change in corporate control, we may transfer associated personal information, 
• In all other situations, we will disclose your personal information only with your consent, or as otherwise required or permitted by law. 
  
  

Under some circumstances we may anonymize your personal information so that it can no longer be associated with you. We reserve the right to use such anonymous and de-identified data for any legitimate business purpose without further notice to you. 

Personal information will be retained only as long as necessary to fulfil the identified purposes, or as required by law. UWBC has guidelines and procedures for the retention and destruction of personal information. When we destroy personal information, we will use safeguards to prevent unauthorized parties from gaining access to that information during the process. 

As your personal information is retained, we store the personal information that we collect electronically or physically at the UWBC offices, or at the offices of our third-party services providers, as applicable. As such, your personal information may in some circumstances be stored in a jurisdiction outside of the one in which you reside, including the United States and other jurisdictions that may not be deemed to provide the same level of privacy protection as Canada. We ensure that your personal information is protected in accordance with the data protection requirements of that jurisdiction. 

Personal information which has been used to make a decision about an individual will be retained long enough to allow the individual access to the information after the decision has been made and, in the event of an access request or a challenge, long enough to exhaust any recourse an individual may have under the law. Where personal information is no longer required to fulfil the identified purposes, it will be destroyed, erased, or made anonymous. 

5. Accuracy 

We maintain appropriate procedures to ensure that personal information in our possession is as accurate and up to date as is necessary for the purposes for which it is to be used. We rely on you to provide us with any changes to your personal information, and in particular to your contact information. Failure to notify us of changes to your personal information may negatively impact the way we communicate with you, transact with you, and/or fulfil our legal and regulatory obligations. 

If you believe any of the information which we have collected about you is incorrect or incomplete, you have the right to ask us to change it or delete it. If your personal information is inaccurate or incomplete, we will make the necessary changes. Where appropriate, we will transmit any material amendments to your personal information to our third-party service providers with need for your personal information. 

6. Safeguards 

We will protect personal information with safeguards appropriate to the sensitivity of the information. 

Our safeguards will protect personal information against loss or theft, as well as unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. We will make our employees, volunteers and authorized service providers aware of the importance of maintaining the confidentiality of personal information, and we will exercise care in the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information. 

Our methods of protection include security measures, organizational measures including security clearance and limiting access on a “need-to-know” basis, and technological measures such as the use of passwords and encryption. When it comes to the handling of electronic records for payment purposes, UWBC adheres to Payment Card Industry Data Security Standards (PCI DSS). 

7. Openness Concerning Policies and Practices 

We will make readily available specific information about our policies and practices relating to the management of personal information. 

The information we will make available will include: how to gain access to personal information; the type of personal information held by us, including a general account of its use; general information concerning our policies; what personal information is made available to other United Ways or a donor’s designated agencies; and how to contact our Privacy Officer. 

8. Individual Access 

Upon written request, we will inform an individual of the existence, use, and disclosure of their personal information and we will give the individual access to that personal information. An individual can challenge the accuracy and completeness of their personal information and have it amended as appropriate. 

We will respond to an individual’s written request within a reasonable time (generally within 30 days), subject to the complexity, volume, and sensitivity of the request. We will assist any individual who informs us that they need assistance in preparing a request. We may require an individual to provide sufficient information to permit us to provide an account of the existence, use, and disclosure of personal information. 

While our response will typically be provided at no cost, depending on the nature of the request and the amount of information involved, we reserve the right to impose a cost. In these circumstances, we will inform the individual of the approximate cost to provide the response and request direction from the individual on whether or not to proceed with the request. Requested information will be provided or made available in a form that is generally understandable. Where possible, we will indicate the source of the information. 

In providing an account of third parties to which we may have disclosed personal information about an individual, we will attempt to be as specific as possible. 

If an individual successfully demonstrates the inaccuracy or incompleteness of personal information, we will amend the information as required. If a challenge is not resolved to the satisfaction of the individual, we will record the substance of the unresolved challenge. Where appropriate the amended information or the existence of the unresolved challenge, as the case may be, will be transmitted to third parties having access to the information in question. 

In certain situations, we may refuse a request or not be able to provide access to all the personal information we hold about an individual. Exceptions to the access requirement will be limited and specific, as permitted or required by law. Where permitted, the reasons for denying access will be provided to the individual upon request. 

9. Recourse 

UWBC has appointed a Privacy Officer who is responsible for this Privacy Policy and our compliance. 

If you have any privacy concerns or requests, you may contact any of our employees with whom you normally interact to discuss your concerns or requests. If you are unsure of whom to contact or have further concerns, you may contact the office of our Privacy Officer by sending an email to privacy@uwbc.ca. Any individual can address a challenge concerning our compliance with any of the Privacy Principles to our Privacy Officer. 

You may register a privacy-related complaint by emailing the UWBC’s Privacy Officer. We will investigate all written complaints. If we find a complaint to be justified, we will take all appropriate measures, including, if necessary, amending our policies and practices. 

Changes to this Privacy Policy 

UWBC may at any time, without notice to you and in its sole discretion, amend this policy from time to time. The most current version of this Privacy Policy is found on the UWBC website.