Our Commitment

The BBB Foundation (the Foundation) is commi2ed to protecting the privacy of the personal information of its donors, volunteers, employees, suppliers and other stakeholders. The Foundation values the trust of those it deals with, and of the public. It recognizes that maintaining this trust requires the Foundation to be transparent and accountable in how information is collected and treated. The Foundation adheres to any privacy legislation outlined by the Federal and/or Provincial Government. This policy, once approved, will be posted on the Foundation’s website.

During the course of BBB Foundation’s various activities, the Foundation frequently gathers and uses personal information. Anyone from whom such information is collected should expect that it will be carefully protected and that any use of, or other dealings with, this information is subject to consent. The BBB Foundation’s privacy practices are designed to achieve this.

Defining Personal Information

Personal information is any information that can be used to distinguish, identify, or contact a specific individual, or stakeholder. This information can include an individual’s or stakeholder’s opinions or beliefs, as well as facts about or related to the individual or stakeholder.

Exceptions: business contact information and certain publicly available information, such as names, addresses and telephone numbers as published in telephone directories, business directories, and professional directories or similar such publicly available lists are not considered personal information.

Purposes for Collecting Information

The BBB Foundation’s purposes for collecting, using, retaining and disclosing personal information are:

• To facilitate the raising of monies for the ongoing support of programming needs of the Foundation;

• To be able to respond in an informed manner to questions or concerns about the Foundation’s work;

• To detect and prevent fraud, and to help safeguard the financial interests of the Foundation and its supporters;

• To send information about developments and progress at the Foundation;

• To invite people to attend educational or donor appreciation gatherings;

• To maintain adequate accounting and tax records; and

• To meet legal and regulatory requirements.

Privacy Practices

The BBB Foundation collects, uses and discloses personal information only for purposes that a

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1 reasonable person would consider appropriate in light of the circumstances and in consideration of the original intent or consented use or reason(s) for collection. Personal information as defined and gathered by the Foundation is kept in confidence.

The BBB Foundation’s goal is to have all individuals provide consent for the use and sharing of their personal information in its regular activities. In addition, individuals are routinely offered the opportunity to opt out of the collection and continued use of their information.

The Foundation’s staff are authorized to access personal information based solely on the need to deal with the information for the reason(s) for which it was obtained and consent was received.

Safeguards are in place to ensure that the information is not disclosed or shared more widely than is necessary to achieve the purpose(s) for which it was gathered. The BBB Foundation also takes reasonable measures to ensure the integrity of this information is maintained and to prevent it being lost, stolen, destroyed, or damaged.

For those individuals whose information was collected prior to the implementation of relevant privacy legislation, the Foundation provides the opportunity for them to opt out of any collection and further use of their personal information.

Retention, Accuracy and Storage of Personal Information

The BBB Foundation retains personal information only as long as is necessary to fulfill the purpose for which it was collected and to meet its legal and contractual obligations. If personal information is no longer required, it will be destroyed or rendered anonymous.

The BBB Foundation maintains procedures to ensure that the information collected and used is accurate, up-to-date, and as complete as possible. The Foundation relies on individuals to disclose all relevant information at the time of collection and subsequently when updates or changes are requested.

Individuals may, with proof of entitlement, request access to the information in the BBB Foundation’s possession and that it be corrected, if applicable. Any updates, changes or deletion requests will be processed as soon as possible.

When information is retained, it is stored safely and securely. Reasonable security measures are taken including password protection, secured filing systems, oath of confidentiality, limited access, and security systems for locations where information is stored.

Disclosure of Personal Information

Personal information is exchanged within the BBB Foundation for the purposes of fulfilling its mandate. It is often necessary to disclose personal information in the process of donating and determining eligibility. The Foundation may also be required to disclose information where required by law. Wherever possible personal information shared is rendered anonymous and will not include personal identifiers.

If for any reason there is a deemed need to disclose personal information for purposes other than the original intent for which it was collected, the BBB Foundation will obtain express consent from the individual to do so.

The BBB Foundation does not sell, rent, or trade its mailing lists.

Any information or use of personal details for promotion, or public review will include an authorization and consent from the individuals and guardians involved. This will include the intended use of the

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2 information, consent for the type of information and items that can be disclosed, and any limitations, instructions, or further details.

Recording Your Options

The BBB Foundation will explain one’s options of refusing or withdrawing consent to the collection, use or disclosure of his/her information, and will record and respect an individual’s choices.

In most cases, an individual is free to refuse or withdraw his/her consent at any time, subject to legal or contractual restrictions and reasonable notice. To do this, an individual should contact the Foundation’s office, at which time the options will be explained along with any consequences of refusing or withdrawing consent. The Foundation’s staff will record this information. An individual may change his/her options at any time.

A Donor Bill of Rights

Updating of Privacy Policy

The BBB Foundation regularly reviews its privacy practices for its various activities and updates its policy accordingly.

Contact Information, Access, and Inquiries

The BBB Foundation is committed to being accessible and addressing individuals’ inquiries, comments, concerns, requests, and questions. Any inquiries or requests for access relating to personal information, or our organizations privacy policy on the treatment of personal information should be emailed to: [email protected] or send by mail with requests, comments, or concerns.

Att:  Executive Director

BBB Education Foundation of Manitoba

1030B Empress Street Winnipeg MB R3G 3H4