The Regina Humane Society (RHS) organization and its employees serve and are accountable to the membership and a number of community stakeholders including:

Purpose

To establish the Regina Humane Society’s (RHS’s) commitment to protecting personal information and to ensure that it is collected, used, disclosed, retained and safeguarded in accordance with applicable privacy legislation, including the Personal Information Protection and Electronic Documents Act (Canada) (PIPEDA), where it applies.

Scope

This policy applies to all RHS operations and to all employees, volunteers, contractors, Board and Board Committee members, and other representatives who collect, use, disclose or otherwise handle personal information on behalf of the RHS.

Background

PIPEDA governs the collection, use and disclosure of personal information by organizations in the course of commercial activities. The RHS also holds personal information in connection with its charitable, employment, animal welfare, enforcement and other activities.

Whether or not PIPEDA applies to a particular activity, the RHS will manage personal information in a manner consistent with the ten fair information principles set out in PIPEDA and with any other applicable legal, contractual or funding requirements.

Policy

 The RHS will make this policy available on its website and upon request. The RHS is accountable for personal information under its control and will apply the following requirements.

Accountability

The RHS will designate a Privacy Officer to oversee compliance with this policy, respond to access requests, inquiries and complaints, and coordinate the response to privacy incidents. Everyone within the scope of this policy is responsible for protecting personal information and reporting any suspected loss, unauthorized access, use or disclosure promptly in accordance with RHS procedures.

Identifying Purposes and Limiting Collection

The RHS will identify the purposes for collecting personal information before or at the time of collection and will collect only the information reasonably necessary for those purposes. Depending on the individual’s relationship with the RHS, this may include:

• • contact and identification information;
  • information provided when adopting, surrendering, licensing, reporting or seeking services for an animal;
  • information related to donations, memberships, payments and tax receipts;
  • volunteer, employment and contractor information;
• information reasonably required to provide veterinary, cremation, emergency or other animal welfare services;
• information collected in connection with animal protection investigations, municipal enforcement or other statutory responsibilities; and
• images, video or audio collected through security systems, recorded communications or events, where notice is provided when reasonably practicable.

Consent and Communications

The RHS will obtain consent for the collection, use and disclosure of personal information where required by law. Consent may be express or implied, depending on the sensitivity of the information and the reasonable expectations of the individual. Consent is not required where collection, use or disclosure is required or authorized by law.

An individual may withdraw consent, subject to legal or contractual restrictions and reasonable notice. The RHS will record requests not to receive optional communications and will comply with applicable anti-spam requirements. An opt-out does not apply to communications necessary to provide a requested service, complete a transaction, protect animal or public welfare, conduct enforcement activities, or meet a legal obligation.

Use of Personal Information

The RHS will use personal information only for the purposes identified at collection, for a purpose consistent with those purposes, or as otherwise permitted or required by law. These purposes may include:

• providing and administering animal welfare programs and services, including registrations and enrolments;
• communicating with individuals about services, transactions, programs, events and, with appropriate consent, fundraising activities;
• processing payments and donations and issuing tax receipts;
• administering employment, volunteer, membership and governance activities;
• meeting legal, regulatory, contractual, funding and reporting requirements; and
• conducting audits, evaluation, research and analysis to improve RHS programs and services, using aggregated or de-identified information where reasonably possible.

Disclosure of Personal Information

The RHS will not sell or rent personal information. The RHS will disclose personal information only with consent or where the disclosure is necessary for an identified purpose or is otherwise required or authorized by law. This may include disclosure to:

• service providers that support information technology, payment processing, mailing, fundraising or other operational services;
• veterinarians, emergency services, animal welfare organizations or other parties involved in providing services or protecting animal or public welfare;
• municipal, provincial or federal authorities, law enforcement agencies, courts, legal counsel or other parties in connection with enforcement activities, legal proceedings or statutory responsibilities; and
• other parties where the individual has consented or the disclosure is required or authorized by law, including disclosure of membership information where required by applicable corporate legislation.

Service providers may use personal information only for the services they have been engaged to provide and must protect it appropriately.

Information held by the RHS on behalf of a municipality, government ministry or other public authority will be managed and disclosed in accordance with the applicable agreement, legal authority and direction of that public authority.

Some service providers may store or process personal information outside Canada. In those circumstances, the information may be subject to the laws and lawful access requirements of the jurisdiction in which it is stored or processed.

Safeguards and Privacy Incidents

The RHS will use reasonable administrative, technical and physical safeguards appropriate to the sensitivity of the information to protect it against loss, theft, unauthorized access, disclosure, copying, use, alteration or destruction. Access will be limited to those who require the information for an authorized purpose. Suspected privacy incidents will be contained, assessed, documented and addressed, including notification where required by law.

Retention and Disposal

The RHS will retain personal information only for as long as reasonably necessary to fulfill the purposes for which it was collected and to meet legal, contractual and operational requirements. Personal information will be securely destroyed or de-identified when it is no longer required, in accordance with the RHS Record Retention and Destruction Policy.

Access, Correction, Inquiries and Complaints

An individual may request access to, or correction of, personal information held by the RHS by submitting the Access to Information Request Form or contacting the Privacy Officer. The RHS will verify the requester’s identity and respond within a reasonable time. Access may be limited where required or permitted by law, including to protect third-party privacy, legal privilege, confidential commercial information, safety, or the integrity of an investigation or proceeding.

Records held by the RHS on behalf of a municipality, government ministry or other public authority, including records related to municipal or provincial enforcement activities, must be requested from the applicable public authority through its access-to-information process.

The Privacy Officer is authorized to investigate and respond to inquiries or complaints concerning this policy or the RHS’s handling of personal information. Contact information for the Privacy Officer will be published on the RHS website or otherwise provided upon request.

The Privacy Officer can be reached at (306) 543-6363 ext. 338

Websites and External Links

RHS websites may contain links to third-party websites for convenience. The RHS is not responsible for the privacy practices or content of third-party websites, and individuals should review the privacy policies of those sites.

Changes to this policy

The RHS may revise this policy from time to time. The current version will be posted on the RHS website.