POLICY STATEMENT:
love & hope foundation canada (lhfc) is
committed to protecting the privacy of the personal information of its donors,
volunteers, and other sponsors. We value the trust of our supporters and of the
public, and recognize that maintaining this trust requires that we be
transparent and accountable in how we treat the information that is shared with
us.
During the course of our various projects and
activities, we frequently gather and use personal information. Anyone from whom
we collect such information should expect that it will be carefully protected
and that any use of or other dealing with this information is subject to
consent. Our privacy practices are designed to achieve this.
We maintain the principles of the Donor Bill of
Rights. Our privacy policy adheres to the Personal Information Protection and
Electronic Documents Act (PIPEDA) and, where applicable, the Personal Health
Information Protection Act (PHIPA).
DEFINING PERSONAL INFORMATION:
Personal information is any information that
can be used to distinguish, identify or contact a specific individual. This
information can include an individual’s opinions or beliefs, as well as facts
about, or related to, the individual. Exceptions: business contact information
and certain publicly available information, such as names, addresses, telephone
numbers, emails and photos as published in grants applications and projects
reports/post, are not considered personal information. Where an individual uses
his or her home contact information as business contact information as well, we
consider that the contact information provided is business contact information,
and is not therefore subject to protection as personal information.
PRACTICES:
1.1 ACCOUNTABILITY
1.1.1 PRIVACY OFFICER
The foundation’s Chief Privacy Officer (CPO) is
the Executive Director, who works closely with the Honorary Secretary, Board of
Directors and the Advisors of lhfc, and in accordance with the principles and
policies of the privacy standard Canada, and PIPEDA, PHIPA and FIPPA
legislation to promote and protect the privacy of all benefactors of lhfc.
1.1.2 THIRD PARTY USE OF PERSONAL INFORMATION
The foundation may uses third party vendors for
services that would not be practical or cost-effective for us to perform
ourselves. Services that employ a third vendor include but are not limited to:
Ø Mail
processing
Ø Database
analysis
In all cases, the third party vendor is
contractually bound to comply with the foundation’s privacy and data protection
requirements, and signs a confidentiality agreement promising that it will take
every precaution to protect the personal information in its possession and to
destroy it upon completion. (Appendix A)
Further, personal information sent between the
foundation and third party vendors will be transferred using secured password-protected
file transfer protocols.
1.2 IDENTIFYING PURPOSES
Before personal information is collected, the
foundation must identify the purpose for which it is being collected. (Appendix
B) Safeguards are in place to ensure that the information is not disclosed or
shared more widely than is necessary to achieve the purpose for which it was
gathered unless otherwise required by law. Should a new purpose be established,
individuals must be notified of the change.
1.3 CONSENT
1.3.1 IMPLIED CONSENT
In the collection, use or disclosure of
personal information, knowledge and consent of the individual is required. This
consent must be meaningful and easily understood. The foundation will consider
a donation or event registration as implied consent to inform the donor of the
impact of their gifts and include them in future communications to support
lhfc, unless otherwise indicated by the donor.
1.3.2 WITHDRAWAL OF CONSENT
The foundation offers individuals the
opportunity not to receive any or all communications from us. Such requests
will be respected and acted on promptly. Opt-out clauses will be included in
all direct mail pieces, e-newsletters, and e-solicitations. Opt-out contact
information is prominently located on the foundation website. To opt-out at any
time, donors are invited to call our foundation at 647 706 1018
1.3.3 FORMER PATIENT SOLICITATION
The foundation receives limited information on
applicant who have been disqualfied. Safeguards have been put in place to
protect their privacy and to eliminate inappropriate mailings.
The foundation does not have direct access to
receipient information; the partners prepares all data selections. All data
received from the partners contains only the information necessary for our
verification practices and adheres to PIPEDA and FIPPA legislation.
Only when an individual responds to a mailing
does the foundation enter their name & address into the secure donor
database. All recipient mailings include an opt-out clause and the foundation
maintains a list of individuals who have opted-out.
1.3.4 PUBLICATION OF DONOR LISTS
With respect to the publication of donor lists
by gift category, donor requests for anonymity will be honored.
1.4 LIMITING COLLECTION
Personal information collected is limited to
that which is necessary to fulfill the purposes identified. Information will be
collected only by lawful means without misleading or deceiving individuals as
to the reason. The source of the data will be indicated on each file.
1.5 LIMITING USE, DISCLOSURE AND RETENTION
The foundation collects, uses and discloses
personal information only for the foundation’s fundraising programs and
initiatives, and to support ongoing administration of our authorized
fundraising activities. When information is no longer needed it will be
securely destroyed.
The foundation only uses the information it
collects for foundation programs that support lhfc.
1.6 ACCURACY
The foundation will take reasonable steps to
ensure that personal information is as accurate, complete, and up to date as possible.
1.7 SAFEGUARDS
The foundation will ensure that steps are taken
to protect personal information from theft and loss, as well as unauthorized
access, disclosure, copying or use. The foundation has established policies and
procedures, as well as technical security to protect personal information.
Hard copies of records are kept in locked
cabinets (if any) and are accessible by foundation staff only on a need to know
basis. All electronic information is stored on secure servers and only
foundation staff with confidential passwords may access electronic records.
Information obtained from donors or visitors to
our website is protected by special electronic security measures. The
foundation only captures information from our website if a visitor chooses to
make a donation, fill out a form or contact us.
1.8 OPENNESS
Our foundation publishes our personal
information protection policies and practices and clearly indicates who serves
as the foundation’s privacy officer. This information is posted on our website
and available in print format and also available upon request.
1.9 INDIVIDUAL ACCESS
Upon request, individuals will be informed of
the existence, use and disclosure of their own personal information and be
given access to that information, as permitted or required by law. An
individual has the right to challenge the accuracy and completeness of the
information and have it amended if appropriate.
All requests for access will be responded
within a reasonable time (not more than 30 days) and at minimal or no cost to
the individual.
1.10 CHALLENGING COMPLIANCE
An individual can challenge the foundation’s
compliance with this policy. If so, the foundation will follow the procedures
outlined in its Complaints Policy.
Policies and procedures will be amended if a
complaint has validity.
UPDATING OF PRIVACY POLICY
This policy will be regularly reviewed and
updated as required. Revisions will be posted on the foundation’s website.
CONTACT INFORMATION
Question, concerns or complaints relating to
the foundation’s privacy policy on the treatment of personal information should
be e-mailed to:
info@lhfc.ca
Attention: Privacy Officer
718 - 5 Massey Square, Toronto, Ontario M4C 5L6,
Canada
Phone: 1-647-706-1018, Email: info@lhfc.ca
Further information on privacy and personal
information may be found on the website of the Privacy Commissioner of Canada
at www.privcom.gc.ca.
POLICY STATEMENT:
love & hope foundation canada is committed
to carry out its mission to support lhfc in providing quality, caring community
needs in the community in the spirit and tradition of the Charity. Every
donation/gift is of great value to us, regardless of size. We value feedback
from all key stakeholders as a means to improve our practices.
PRINCIPLES:
Ø We
value all donors and others who make a complaint and view this as an
opportunity to refine and improve our procedures.
Ø Privacy
is respected.
Ø Requests
for anonymity are respected and strictly adhered to.
Ø Complaints
will be dealt with promptly and sensitively by the appropriate staff member.
PRACTICES:
2.1 To ensure that complaints are kept to a
minimum, we will adhere to strict ethical practices in all our fundraising
activities.
2.2 If a serious complaint cannot be reasonably
addressed by the appropriate level of staff member outlined in the attached
procedures, it will be forwarded to the Executive Director for resolution, and
if necessary to the Advisors Committee with the attention of Chief Adviser.
2.3 All requests for donor anonymity will be
respected.
2.4 All complaints directed to the foundation
office will be acted upon immediately. They will be documented and monitored by
the supervisor of the staff member assigned to address the complaint.
2.5 Normally, all complaints will be brought to
the attention of the Executive Director, and will be addressed by the most
appropriate person possible.
2.6 The foundation’s Privacy Officer will act
upon all complaints related to privacy.
2.7 An annual report on complaints will be
prepared and presented to the Advisors Team and Governance Committee of the
Board to review and take corrective action.
Approved by the Board of Directors January 30,
2023.
Ethical Fundraising Practices Policy
PREAMBLE:
The success of lhfc in meeting the needs of
community is heavily dependent on our ability to inspire confidence and trust
in the minds of our donor public. People make financial contributions to our
foundation for many reasons—a personal experience of the care lhfc provides,
the projects’ reputation for quality and compassionate care, the excellence of
our grants designer, to name a few. But equally important in obtaining and
retaining such financial support is our foundation’s reputation for integrity
and ethical fundraising practices. This policy speaks to several areas of our
fundraising program and outlines the ways in which we seek to operate in the
most ethical manner possible. This shows respect for our donors and clearly
puts the onus on our foundation to be open, honest and transparent in our
raising, investment and disbursal of funds.
I. FINANCIAL PRACTICE AND TRANSPARENCY
1. The foundation’s financial affairs will be
conducted in a responsible manner, consistent with the ethical obligations of
stewardship and all applicable law.
2. All donations will be used to support the
foundation’s objects, as registered with the Canada Revenue Agency (CRA).
3. All restricted or designated donations will
be used for the purposes for which they were given unless the charity has
obtained legal authorization to use them for other purposes. Alternate uses
will be discussed where possible with the donor or the donor’s legal designate.
If the donor is deceased or legally incompetent and the foundation is unable to
contact a legal designate, the donation will be used in a manner that is as
consistent as possible with the donor’s original intent. If necessary, the
foundation will apply to the courts or the appropriate regulatory body to
obtain legal authorization to use the donation for other purposes.
4. Annual financial reports are necessary to
achieve transparency and accountability to donors and the public. They are
accessible on the Foundation’s website, provided upon request and will:
Ø be
factual and accurate in all material respects;
Ø disclose
the gross amount of fundraising revenues (receipted and non-receipted);
Ø disclose
the total amount of fundraising expenses (including salaries and overhead
costs);
Ø disclose
all donations that are receipted for income tax purposes;
Ø disclose
the total amount of expenditures on charitable activities (including gifs to
other charities);
Ø segregate
undesignated and designated funds;
Ø identify
government grants and contributions separately from other donations; and
Ø Financial
Statements will be prepared in accordance with generally accepted accounting
principles and standards established by the Canadian Institute of Chartered
Accountants, in all material respects (or disclose a discrepancy between the
practice and GAAP).
5. The cost-effectiveness of the foundation’s
fundraising programs will be reviewed regularly by the governing board. No more
will be spent on administration and fundraising than is required to ensure
effective management and resource development. The foundation will disclose its
process for evaluating its spending and will comply with CRA recommended cost
of fundraising guidelines.
6. The foundation will, upon request, disclose
the revenue and expense assumptions for its fundraising activity as approved by
its Board in its annual budget.
7. The foundation’s financial statements will
be audited by an independent tax consultant/adviser.
8. An Investment Policy Statement will be in
place setting out asset allocation, procedures for investment decisions, and
asset protection issues. It will be reviewed annually by our Board of
Directors.
9. A Gift Acceptance Policy will be in place to
provide guidance on the types of gifts our foundation can accept. We will
conform with all federal government regulations and legal requirements.
10. The Foundation will act promptly to provide
information requested in its most current form. This includes financial
statements, annual reports, our charitable business number as assigned by CRA,
any information contained in the public portion of the foundation’s most recent
Charity Information Return (T3010) for CRA, a list of the names of our
governing board will be published in our website.
11. The foundation will provide information
that will add to the public’s understanding of and confidence in our
operations, methods, and costs of fundraising by publishing an annual report.
12. We will release a financial summary or
extract, related to and consistent with the information provided in our full
financial statements including minutes.
13. All eligible donations, regardless of
amount, will receive an official gift receipt.
II. RESTRICTED AND DESIGNATED DONATIONS
Our Foundation will prepares and issues
official gift receipts for monetary gifts and for gifts in kind in compliance
with all regulatory requirements. We will follow to a donor’s wishes as they
relate to restricted or designated donations.
III. COLLECTION, MAINTENANCE, USE AND
CONFIDENTIALITY OF DONOR RECORDS
Our Foundation complies with all relevant
provisions of the Personal Information Protection and Electronic Documents Act
and observes the following practices when collecting donor information, maintaining
and using confidential donor records, and protecting donor anonymity:
1. We guard against making unwarranted or
intrusive inquiries into a donor or prospect’s donation/gift history or
personal life and gather only information that is relevant and necessary to our
fundraising efforts.
2. We make all reasonable efforts to ensure the
personal information we collect is complete and accurate
3. We require attribution for all data that we
collect.
4. We encourage donors to review, correct and
update personal information.
5. We require a donor’s consent before
confidential information is released to outside parties.
6. We have established and follow reasonable
time periods for the retention and disposal of donor information.
7. We have established special security
safeguards to protect donor information and limit access to donor files.
8. We give special protection to all records
pertaining to anonymous donors.
9. We recognize that our duty to ensure the
confidentiality of donor records continues even after our relationship with a
donor or prospect has ended.
10. We record a donor’s oral consent regarding
the proposed use of their personal information when information is collected by
phone.
11. We provide donors with an opportunity to
remain anonymous and to request that the donor’s name and/or the amount of the
gift not be publicly released.
12. We honour donors’ and prospective donors’
requests to: limit the frequency of contact; not be contacted by telephone or
other technology; receive printed material concerning the organization; and
discontinue contact.
Solicitation of Former Patients
A natural population for financial support of
the foundation is its Directors. This group comprises the “alumni” of the
foundation who have served as Director. We write to selected former Directors
inviting their financial support. We make every effort to ensure that this
appeal is tasteful, appropriate, and complies with privacy legislation.
Privacy
Our Foundation has a Privacy Policy overseen by
a Privacy Officer.
IV. ELECTRONIC GIFTS
Technology is playing an increasing role in
generosity. To protect the interests of donors who choose to give
electronically, our foundation adheres to the following practice:
1. Our website lists our foundation’s full
name, charitable business number, and mission clearly and immediately for
online donors.
2. For those who wish to contact us other than
through the website or e-mail, we clearly provide alternative contact
information.
3. Eligibility for an official gift receipt is
clearly outlined.
4. All precautions are taken to ensure that
gifts made electronically are safe, private and secure, and that a donor’s
personal information is protected.
5. E-donors are assured that any information
they provide is held in strict confidence, and that this Ethical Fundraising
Practices Policy is clearly listed on our website.
6. Electronic donors will receive
communications or solicitations from the foundation but will have a clearly
identified area where they can “opt out” of receiving any future communications.
Donors will also be given the opportunity to provide direction on how often
they would like to be contacted and by which method, i.e.: mail, phone or
email.
V. GOVERNANCE
1. Our Board of Directors reviews our
fundraising practices and policies on a regular basis and tests them for
continuing relevance, legislative compliance and applicability. Adjustments are
made, as required, to ensure that the maximum amount of donations possible is
applied to our charitable activities in a manner that is consistent with the
long-term interests of our organization and its beneficiaries.
2. Our fundraising policies, practices and
expectations are clearly communicated to all team.
VI. FUNDRAISING PRACTICES
1. In accordance with all applicable laws,
fundraising solicitations on behalf of the Foundation will:
Ø be
truthful;
Ø accurately
describe the foundation’s activities and the intended use of donated funds; and
Ø all
fundraising solicitations by the foundation disclose our name and the purpose
for which the funds are requested. This includes address or other contact
information.
2. The Foundation will be honest and clear on
any claims it makes about the grants. It will refrain from using marketing
materials or making representations that could be misleading. The foundation
will not exploit its beneficiaries. It will be sensitive in describing those it
serves (whether using graphics, images or text) and fairly represent their
needs and how these needs will be addressed.
3. When the Foundation conducts online
solicitations, its practices will be consistent with or exceed the provisions
of the Canadian Code of Practice for Consumer Protection in Electronic
Commerce, which is downloadable at:
http://www.ic.gc.ca/eic/site/cmc-cmc.nsf/eng/fe00113.html.
4. When the foundation conducts face-to-face
solicitations, its practices shall include measures to
Ø provide
verification of the affiliation of the person representing the foundation; and,
Ø secure
and safeguard any confidential information, including credit card information,
provided by donors.
Ø encourage
donors to consult their professional advisors to determine the tax consequences
of their gift.
5. Volunteers, employees and third party
consultants/solicitors who solicit or receive funds on behalf of the Foundation
shall:
Ø adhere
to the provisions of this Canada Standards;
Ø act
with fairness, integrity, and in accordance with all applicable laws;
Ø adhere
to the provisions of applicable professional codes of ethics, standards of
practice, and all relevant foundation policies, etc.;
Ø cease
solicitation of a prospective donor who identifies the solicitation as
harassment or undue pressure, or who states that he does not wish to be
solicited;
Ø disclose
immediately to the Foundation any actual or apparent conflict of interest or
loyalty; and
Ø Disclose
upon request, whether the individual or entity seeking donations is a
volunteer, employee or contracted third party.
Ø not
accept donations for purposes that are inconsistent with the foundation’s
objects or mission.
6. The Foundation will provide, upon request,
its best available information on the gross revenue, net proceeds and costs of
any fundraising activity it undertakes.
7. Paid staff or consultants will be
compensated by a salary, retainer or fee, and will not be paid finders’ fees,
commissions or other payments based on either the number of philanthropic
contributions received or the value of funds raised.
8. The foundation will not sell, rent or
exchange its donor list.
9. The foundation’s governing board will be
informed at least annually of the number, type and disposition of complaints
received from donors or prospective donors.
10. It is the policy of our foundation to have
a written complaints procedure in place to ensure that all complaints from
donors or the community-at-large are handled promptly, courteously, and to the
satisfaction of all parties.
VII. CONFLICTS OF INTEREST
Our by-laws include a written conflict of
interest statement and we address actual or perceived conflicts of interest in
the following manner:
1. We define a conflict of interest for our
fundraisers and advise all fundraisers that they must act in the best interests
of our organization rather than in furtherance of their personal interests or
the interests of third parties.
2. We instruct all fundraisers to avoid
situations where their personal interest conflicts or appears to conflict with
their duties within our organization.
3. We instruct all fundraisers to evaluate
their conduct in light of the impact on our organization.
4. We require our fundraisers to disclose both
actual and apparent conflicts of interest.
5. Our conflict-of-interest disclosure
procedures are clearly articulated and we believe well understood by all staff
and directors.
6. Our staff, directors and volunteers
recognize that the duty to disclose even an “apparent” conflict of interest
requires a consideration of public perception when evaluating whether a
conflict of interest is present.
7. We are mindful of our fiduciary duty to
ensure the disclosure of any conflict of interest that would be of material
interest or relevance to a donor or which may influence a donor’s decision to
give; and
8. Where a donor elects to make a gift in spite
of the presence of a conflict of interest, we encourage that the donor obtain
independent advice regarding his or her gift. Further, we encourage donors to
seek independent advice if the proposed gift might significantly affect the
donor’s financial position, taxable income or relationship with other family
members.
VIII. FUNDRAISER COMPENSATION
Our foundation observes the following
compensation practices:
1. Fundraisers are compensated on the basis of
their experience, expertise and the time
requirements of the position.
2. Where a fundraiser’s performance exceeds job
expectations and additional compensation is merited, eligibility for and
calculation of the amount of compensation to be paid is not based on a
percentage of income (e.g., in the form of donations, gifts, grants and similar
funds) received by our organization as a result of the fundraiser’s efforts.
3. We undertake the institutional planning,
board development and volunteer recruitment necessary to make our fundraising
program successful over time.
CONCLUSION:
All fundraising programs undertaken by our
foundation are reviewed by the Board of Directors to ensure that they are
consistent with our Vision and Mission statements, and that they comply with
this Ethical Fundraising Practices Policy.
Investment Policy
Ethical Investment Practices:
It is the preference of lhfc that investments
are limited to companies or governments (for government-backed securities) that
generally follow ethical guidelines and recognize our relationship with the
founder. In addition, the Finance Director/investment manager will make all
investments in accordance with the CFA Institute’s Code of Ethics and Standard
of Professional Conduct.
In the absence of specific constraints, it is
understood that the Finance Director/ investment manager will fulfill their
duties in a manner which;
1. Prioritizes capital preservation;
2. Maximizes returns and minimizes risk,
given prevailing market conditions;
3. Adheres to the safeguards and diversity
to which a prudent investor would normally adhere; and
4. Selects investments that are
appropriate to the foundation’s vision and mission, philosophy of social
justice, environmental responsibility and humanitarian/economic values.