UWCA endeavours to maintain physical, technological, and procedural safeguards that are appropriate to the sensitivity of the Personal Information in question. These safeguards are designed to prevent Personal Information from loss and unauthorized access, copying, use, modification, or disclosure. Examples of these safeguards include password, encryption, and other electronic security means; locked or limited access premises and file cabinets; and the security monitoring methods. UWCA cannot guarantee the security of transferring information by virtual means, including via the Internet or telephone.
Retention of Personal Information
Except as otherwise permitted or required by applicable law or regulatory requirements, UWCA endeavours to retain Personal Information only for as long as it believes is necessary to fulfill the purposes for which the Personal Information was collected (including, for the purpose of meeting any legal, accounting, or other reporting requirements or obligations). UWCA may, instead of destroying or erasing Personal Information and where this is economically feasible, make it anonymous such that it cannot be associated with or tracked back to a specific individual.
Updating Personal Information
It is important that Personal Information contained in UWCA’s records is both accurate and current. UWCA asks that Personnel, donors, customers and suppliers keep it informed of changes to Personal Information during the course of the individual’s employment, charitable or business relationship with UWCA.
If an individual believes the Personal Information about them held by UWCA is not correct, the individual may request an update of that information by making a request to our Privacy Officer using the contact information set out below.
Accessing Personal Information
An individual may ask to see the Personal Information that UWCA holds about them. If individuals want to review, verify, or correct their Personal Information, they may contact our Privacy Officer at the coordinates set out below. Please note that any such communications must be in writing (whether by traditional or electronic means).
When making an access request, UWCA may require specific information from an individual to confirm their identity and right to access, as well as to search for, and provide that individual with, the Personal Information that it holds about them. UWCA may charge a fee to access Personal Information; but it will advise of any fee in advance. If help is needed in preparing a request, please contact the office of our Privacy Officer. Where Personal Information will be disclosed to an individual, UWCA will endeavour to provide the information in question within a reasonable time, and in most cases, no later than 30 days following the request.
An individual’s right to access the Personal Information that it holds about them is not absolute. There are instances where applicable law or regulatory requirements permit or require UWCA to refuse a Personal Information access request. UWCA also reserves the right to decline to provide access to Personal Information where the information requested:
- would disclose:
- Personal Information, including opinions, about another individual or about a deceased individual; or
- trade secrets or other business confidential information that may harm UWCA or the competitive position of a third party, or interfere with contractual or other negotiations of UWCA or a third party;
- is subject to solicitor-client or litigation privilege;
- is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information;
- could reasonably result in serious harm to any individual.
- may harm or interfere with law enforcement activities and other legal or employment related investigative or regulatory functions.
In addition, the Personal Information may no longer exist, may have been destroyed, erased or made anonymous in accordance with UWCA’s record retention obligations and practices.
In the event that UWCA cannot provide an individual with access to their Personal Information, it will endeavor to inform that individual of the reasons why access has been denied, subject to any legal or regulatory restrictions.
Out of Country Storage and Processing of Personal Information
UWCA has and will invest in new data management systems and software solutions on a routine basis, in order to work with or provide its services to its Personnel, Representatives, donors, customers, suppliers and others. As data processing technologies continually evolve, more systems and software solutions utilize “cloud-based” delivery models, where data processing and storage functionality is delivered from outside UWCA’s premises and through the internet or similar connections to the service provider, and where UWCA does not host the system or software solution within its physical premises. Accordingly, while UWCA maintains its responsibility for the protection of this data and of the Personal Information contained within it, Personal Information collection, use, disclosure, processing and storage may actually occur outside of Canada.
- The purposes for which UWCA may utilize such cloud-based systems and solutions for the collection, use, disclosure, processing and storage of Personal Information, are those purposes that are otherwise described in this Policy.
- UWCA has and will only engage service providers for such collection, use, disclosure, processing and storage of Personal Information, where such Personal Information is or will be located in and outside Canada.
- Any Personnel, Representative, donor, customer, supplier or third person may obtain further information about UWCA’s collection, use, disclosure, processing and storage of such Personal Information, or about UWCA’s policies and practices with respect to such service providers, located in and outside Canada, by contacting UWCA’s Privacy Officer through the contact information below.