Skills for Change PRIVACY POLICY
This Privacy Policy was last modified on July 22, 2019.
Skills for Change of Metro Toronto (“Skills for Change”) is a non-profit organization serving immigrants and refugees in the Greater Toronto Area. This Privacy Policy describes the personal information management practices of Skills for Change relating to its clients, students, prospects and other individual public stakeholders, as applicable.
Changes to this Privacy Policy
Skills for Change reserves the right to change this Privacy Policy from time to time. We recommend that you review this policy periodically so that you are aware of any changes. Your continued use of our website following the posting of any changes to this policy constitutes your acceptance of these changes. The date on which this Privacy Policy was last amended appears at the top.
Personal information
In this Privacy Policy, “personal information” refers to information about an identifiable individual but does not include information about individuals in their professional capacity, including an individual’s name, business title, business address (including email address), business telephone number, Skills for Change client status. This policy explains the reasons why we collect your personal information, as well as how we handle that information.
It should be noted that most of the Skills for Change’s activities are not subject to privacy law. The federal Personal Information Protection and Electronic Documents Act (“PIPEDA”), being the privacy law applicable to the private sector in Ontario, applies to the collection, use and disclosure of personal information in the course of commercial activities. Since the core activities of Skills for Change are not commercial in nature, PIPEDA does not apply to most of our activities. PIPEDA only applies to the limited forms of commercial activity that Skills for Change engages in outside of our core activities.
Types of information we collect
We gather personal information from individuals in person, over the phone, by correspondence via mail or email, or through our website (e.g. profile updates, downloadable and fillable forms or applications). The types of information we collect depends on whether or not an individual is a client or a student of any Skills for Change program. The personal information we may collect includes name and contact information (where not business information), and financial information required to purchase our goods and services, including credit card information.
The public areas of Skills for Change’s website can be visited without providing any personal information. Personal Information is only collected if visitors voluntarily choose to provide personal information. We need to validate the identities of visitors to the non-public areas of our website, where access is restricted to members or students.
We may collect personal information such as date of birth, gender, languages spoken, language preference, place of residence, course enrolment information, and particulars of current and previous employment, education, professional development, and volunteer activities.
For members engaged in public practice or public accounting as a sole proprietor, partner or shareholder of a firm or professional corporation, we may collect further information such as business name, names of partners, shareholder information, preferred areas of practice, position codes, practice review results, and professional liability insurance information.
How we use personal information
Skills for Change uses personal information (and/or professional information) we collect to confirm an individual’s identity, to respond to inquiries or comments, to send important notices about the program, to fulfil legal and regulatory requirements, to carry out our business activities and generally to provide individuals with the products and services they request.
Skills for Change uses the personal information you provide to process financial transactions (including student fees, and purchases of products or services), to process program transactions (including applications, event registrations, continuing professional development reporting, course enrolment, seminar enrolment, academic results processing, advanced standing requests, transcript distribution, and the employment referral service), to communicate information or materials we are required to communicate by law or regulation (including notice of annual meetings), and to maintain the register of clients.
Subject to obtaining consent, we may use personal information (and/or professional information) to provide you with tailored communications (including information about products or services available for purchase, notices of professional development, career and volunteer opportunities, speaking engagements or participation in special interest groups) that we believe will be of interest.
We may conduct surveys. If you choose to participate in such surveys, we will use the information you provide to better understand your professional profile, your needs, and the needs of users of accounting services.
If you do not wish to receive promotional communications from Skills for Change, you may withdraw your consent to receive these communications at any time by contacting Skills for Change at communications@skillsforchange.org or by mail at Skills for Change – Marketing & Communications, 791 St Clair Ave W, Toronto, ON M6C 1B7.
Sharing personal information
Skills for Change may disclose the personal information of clients, participants and/or students to its regulators, funders and affiliated organizations, including Employment Ontario (EO), and Immigration, Refugees and Citizenship Canada (IRCC). Such disclosure is made: to permit these bodies to enrol clients and conduct regulatory audits; to facilitate inter-regional mobility of clients, participants and students; for the operation of academic programs, the provision of products or services; and to communicate information or materials required by law or regulation. These bodies may also use your personal information to contact you with other materials such as information about professional development programs, surveys, marketing, and public relations.
Skills for Change may provide your personal information to our third-party service providers responsible for administering our marketing and promotional activities or providing the products and services you have requested. Skills for Change may also provide your personal information to our affinity program partners so that you are eligible to receive their products and services at favourable rates. We require these organizations to have privacy policies or to abide by our policies in relation to the personal information we share with them, including a requirement to use the information only for the purposes for which it was provided.
For participants, Skills for Change may also disclose your personal information (and/or professional information) to government entities to advocate on your behalf or as otherwise may be required or requested by them.
From time to time, Skills for Change or our third-party service providers or affinity partners may store or process your personal information outside of Canada. While outside of Canada your personal information may be subject to disclosure in accordance with the laws of the foreign jurisdiction.
Your consent
By providing Skills for Change with your personal information and/or by using our website, you are consenting to the collection, use and disclosure of your personal information in accordance with the terms of this Privacy Policy. If Skills for Change requests additional personal information or intends to use or disclose your personal information differently than described in this policy, we will advise you when we collect it or before we use it as to how we will use the information.
There are circumstances established at law under which Skills for Change may collect, use or disclose your personal information without obtaining your consent, for example: (i) to collect a debt owed to us, (ii) to meet government tax reporting requirements, (iii) to carry out and satisfy our regulatory responsibilities and obligations (including those relating to member and student discipline), and (iv) to comply with an order made by a court.
Refusal and withdrawal of consent
Where your consent is required, you may refuse or withdraw your consent to the collection, use and disclosure of your personal information. You should be aware that your choice to refuse or withdraw consent may negatively affect your ability to meet Skills for Change’s requirements or Skills for Change’s ability to provide you with certain products or services. If you would like information about the effect, if any, of refusing or withdrawing your consent, you may contact us at the address indicated below.
Retention and disposal of personal information
Skills for Change keeps personal information for as long as it is necessary for the purposes for which it was collected. Accordingly, we may retain personal information for different lengths of time, depending on the nature of the personal information and the purposes for which it was provided to us. We dispose of personal information in a manner that ensures the continued security of the information.
Security safeguards
Skills for Change takes steps to protect your personal information against unauthorized access, disclosure, inappropriate alteration and misuse. Skills for Change uses technological safeguards such as encrypted passwords, secure socket layer (SSL) and at least 128-bit encryption technologies. Given that electronically transmitted data is not 100% secure, we make no warranties as to the security of any information you submit electronically, which you do at your own risk.
Access and correction of personal information
If you wish to access, correct or update your personal information in Skills for Change’s records, you may contact us at the address indicated below. Some information may not be accessed, such as information that contains personal information of others, or is otherwise protected under the law. You may also access, correct or update some of your personal information online by following the links on our website.
Cookies, IP addresses, and links to other websites
Skills for Change uses Google Analytics. This tool uses cookies to collect and generate information about your visits to our website (including your IP address) that is transmitted to their servers in an anonymous form for processing. We study patterns of website activity so we can improve the experience of visitors to our site. Google currently offers a free Google Analytics opt-out tool. Click here for the tool. Skills for Change may also use marketing software to enable personalization services.
We may use cookies and similar technologies to provide you with tailored information. Cookies allow us to know that you’re logged in and help us to administer our marketing activities and perform analytics. A cookie is an element of data that a website can send to your browser, for storing on your hard drive so we can more easily recognize you when you return to our website. You may set your browser to notify you when you receive a cookie and you may choose to decline, delete or disable cookies. You should be aware that if you do so you may not be able to access or run certain applications that are on our website.
Skills for Change‘s website logs IP addresses, but not the email addresses, of visitors. This real-time information is aggregated, logged, and used to measure statistical information about the usage of the site, including the total number of visits, page errors, average time spent on the site, and pages viewed, both in real-time and within a certain historical time frame. Skills for Change uses this aggregated information to measure the use of our website and to improve its content and usage.
Skills for Change’s website may contain links to other internet sites owned and operated by third parties. While we try to provide a link only to sites that share our high standards and respect for privacy, we are not responsible for the content or the privacy practices of those sites. Since you are solely responsible for deciding whether to visit any particular site, we strongly recommend that you review the privacy policies applicable to those other websites before you proceed to visit the site or provide any personal information there.
QUESTIONS OR CONCERNS
If you have any questions or concerns about Skills for Change’s privacy and information practices, contact our Communications Officer by email at communications@skillsforchange.org or by mail at Skills for Change, 791 St. Clair Ave W, Toronto, ON M6C 1B7.