In accordance with the provisions of the Personal Information Protection and Electronic Documents Act (“PIPEDA”) and other applicable legislation, Christian Women’s Clubs of Canada, carrying on ministry as Stonecroft Ministries (herein called “Stonecroft Ministries”) is committed to protecting the privacy of its donors, volunteers, employees, directors, officers and any other persons about or from whom Stonecroft Ministries collects personal information. Stonecroft Ministries embraces the principles of the Canadian Standards Association Model Code for the Protection of Personal Information to ensure that all personal information is properly collected, used only for the purposes for which it is collected and is disposed of in a safe and timely manner when no longer required.

Stonecroft Ministries is responsible for maintaining and protecting the personal information under its control. Stonecroft Ministries has appointed Lorraine Myrholm, Executive Director, as the Privacy Officer who is responsible to ensure that Stonecroft Ministries complies with its privacy obligations in accordance with applicable privacy laws. Personal information shall only be collected, retained or used after the Privacy Officer gives written approval and such collection, retention and use shall be in accordance with this Privacy Policy. The Privacy Officer shall also provide training to employees and volunteers who are in a position to collect, retain or use personal information.

Stonecroft Ministries collects and uses personal information for a variety of purposes including, but not limited to, • providing services to individuals ministered to by Stonecroft Ministries; • establishing and maintaining members lists; • establishing and maintaining lists of donors. • Establishing a data base for program delivery and administration; • Distribution of program literature and related material Stonecroft Ministries shall identify and explain the purposes for which it collects personal information to the person from whom the personal information is being collected before or at the time the information is collected. The Privacy Officer shall ensure that limited collection, limited use, disclosure and retention principles are respected in identifying why personal information is to be collected.

Consent will be obtained from the person whose personal information is collected, used and disclosed, prior to or at the time of collection unless obtaining the consent would be inappropriate or not required by law.

Sometimes the person’s consent to collection, use or disclosure, may be implied. When it is appropriate, written consent will be obtained. In obtaining consent, the Privacy Officer shall ensure that the individual’s reasonable expectations are respected.

Written consents will be kept on file for as long as the information is reasonably necessary. A person may withdraw his or her consent at any time, subject to legal or contractual restrictions and reasonable notice. The person will be informed of reasonably foreseeable implications of the withdrawal.

Information will not be collected indiscriminately but such collection will be limited to that information required for the purpose or purposes identified by Stonecroft Ministries. Stonecroft Ministries is committed to collecting personal information in a fair, open and lawful manner without misleading or deceiving individuals as to the reason. The Privacy Officer shall ensure that the identifying purposes and consent principles are followed in identifying why personal information is to be collected.

Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the person or as required by law. All collected personal information shall be destroyed, erased or made anonymous as soon as the purpose for which it was collected is no longer relevant, or as permitted by the law. The Privacy Officer shall use her best efforts to ensure that all use, disclosure and retention decisions are based on the principles of consent, identifying purposes and access.

Personal information collected shall be accurate, complete and up-to-date as is necessary for the purposes for which it was collected and to minimize the possibility that inaccurate information might be used to make a decision about an individual. The Privacy Officer shall ensure that personal information is not routinely updated unless it is necessary to fulfill the purposes for which the information was collected.

Personal information will be protected by security safeguards that are appropriate to the sensitivity of the personal information. This safeguarding could include physical measures such as locked filing cabinets and premises security, organizational measures such as restricted access to files with personal information or technological measures such as security software. Measures will also be taken to protect personal information from unauthorized access, disclosure, copying, use or modification. Appropriate care will be taken when personal information is disposed of or destroyed to prevent unauthorized parties from gaining access to it.

Information regarding the privacy policy of Stonecroft Ministries, as well as the personal information management, shall be available as requested. The information will include:

• Name and address of the Privacy Officer
• Means of gaining access to personal information held by Stonecroft Ministries
• A description of the type of personal information held by Stonecroft Ministries, including a general account of its use
• Copy of any brochures or other information that explains the policies, standards or codes of Stonecroft Ministries
• Details as to the personal information that is made available to related parties

Access to personal information will be granted to the person to whom the information pertains where there is an appropriate written request. The existence, use and disclosure of the personal information will be granted within a reasonable period of time and at minimal or no cost to the individual. The person to whom the information pertains shall be given the opportunity to challenge the accuracy of the information. Any inaccuracy or incompleteness of personal information will be amended as required and, when appropriate, the amended information will be transmitted to third parties having access to the information in question. Stonecroft Ministries shall also account for the use that has been made or is being made of this information and give an account as to the third parties to whom it has been disclosed.

Complaints or inquiries about the collection, use, disclosure or retention of personal information and the compliance by Stonecroft Ministries with the above principles should be directed to the Privacy Officer. The Privacy Officer shall inform the complainant of the relevant complaint procedure. The Privacy Officer will investigate complaints and ensure that if a complaint is justified, appropriate measures are taken.

Approved April 30, 2005