BETH RADOM CONGREGATION'S PRIVACY POLICY

Your Privacy Rights
Beth Radom Congregation recognizes the importance of privacy and the sensitivity of personal information. We take seriously our obligation to keep this information confidential and we protect it with physical, electronic and procedural safeguards. In order to comply with applicable privacy legislation and to instill confidence in our members and potential members that the personal information they entrust to us is safe, we have developed this Privacy Policy.
“Personal Information” means information about an identifiable individual but does not include the name, title, business address or telephone number of any employee of any organization.  Beth Radom collects financial and contact information from you in respect of yourself and your family members.

Why Does Beth Radom Congregation Collect Personal Information From You?
Beth Radom Congregation collects personal information from you so that we can provide our members and our community with a range of services and activities, which include:

  • Yahrzeit reminders and aliyot;                    
  • Newsletters, general notices and mailings and generally communicate with our members and family members;
  • general announcements, including life cycle events, illness and death of family members;
  • general billing, and dues/donation collection;
  • fundraising efforts;
  • Brotherhood and Sisterhood programs and activities;
  • to understand and assess the needs and requirements of our members and potential members in offering services, programming and events to meet those needs;
  • to communicate and assist the Beth Radom Congregation Supplementary Hebrew School, Jumpin’ 4 Judaism (‘J4J’), in providing educational services to students.

Membership in a religious community brings with it certain “understandings”, one of which is that certain information or news about members and their life cycle events will be shared with the community. We will continue to share this sort of information unless we are notified that it is not to be shared.

How Do We Collect Your Personal Information
We collect information only by lawful and fair means and not indiscriminately. We may collect personal information directly from you when you become a member of Beth Radom Congregation, during the term of your membership, or registration for Beth Radom Congregation’s education programs. We may on occasion obtain information about you from other sources, such as other family members or members of Beth Radom Congregation.

Consent
Consent for the collection, use and/or disclosure of personal information may be obtained orally or in writing and may be expressly given or implied. We may also from time to time ask you to give your written consent to the use and disclosure of specific personal information. In determining how we obtain your consent, we will take into account the sensitivity of your personal information that we are collecting, using and/or disclosing. We will use and disclose your personal information only in accordance with this policy.
If You Don’t Consent
The choice to provide us with personal information is always up to you. Upon request, we will explain your options of refusing or withdrawing consent to the collection, use and disclosure of your personal information and will record and respect your written choices. However, your decision to withhold partic­ular details may limit our ability to provide our services to you. This measure is necessary to protect the integrity of the services offered by Beth Radom Congregation. Furthermore, any refusing or withdrawing of consent is always subject to any overriding legal requirements or commitments.

Disclosure of Your Personal Information
Under certain circumstances Beth Radom Congregation may disclose your personal information without your consent:            

  • when we in good faith believe the law requires or authorizes us to do so, including reporting to Canada Revenue Agency of donations received;
  • when the services that you have expressly requested from us require us to give your information to third parties (for example, to a funeral parlour, caterer, educator, non-employed clergy) your consent will be implied unless you tell us otherwise;
  • where it is necessary to establish or collect dues or contributions; or
  • if the information is already publicly known.

We never make our membership list available to third parties in any form, except as set out in this document or unless we have your prior consent. Personal information provided to third party service providers (such as accountants, computer back-up services, or archival file storage) with whom we have contractual arrangements will have comparable levels of protection to the internal protection which Beth Radom Congregation maintains for personal information.

Is My Personal Information Secure?
Beth Radom Congregation takes all reasonable precautions to ensure that your personal information is kept safe from loss, unauthorized access, modification or disclosure.  Among the steps taken to protect your information, depending on its type and sensitivity, are:

  • premises security;
  • restricted access to personal information;
  • deploying technological safeguards such as security software and firewalls to prevent hacking or unauthorized computer access;
  • internal password and security policies; and
  • where necessary or appropriate, by requiring third parties to sign a confidentiality agreement.

As Beth Radom Congregation is responsible for any personal information under its control, including personal information that Beth Radom Congregation may transfer to a third party for processing, we will use contractual or other means to provide a comparable level of privacy protection when personal information is being processed by a third party on behalf of Beth Radom Congregation.

Updating Your Information
Since we use your personal information to provide services to you, it is important that the information be accurate and up-to-date. If any of the information changes, or if you should become aware that the personal information which we have is incorrect, please inform us so that we can make the necessary changes.

Access to Your Personal Information
You may request access to any personal information we hold about you. Summary information is available on written request. More detailed requests that require archive, retrieval or copying costs may be subject to reasonable reimbursement for our actual costs.

Can I be Denied Access to My Personal Information?
Your rights to access your personal information are not absolute. We may deny access when:

  • denial of access is required or authorized by law or the rules of a formal dispute resolution process, such as a Beth Din;
  • information relates to existing or anticipated legal proceedings against you;
  • granting you access would have an unreasonable impact on other people’s privacy;
  • to do so would prejudice negotiations with you;
  • to protect Beth Radom Congregation’s rights and property; or
  • the request is frivolous

If we deny your request for access, or refuse a request to correct information, we will explain why.

How Long Do You Keep My Personal Information?
We retain your personal information for as long as you are a member and afterwards for as long as is reasonably necessary for us to complete our dealings with you, or as may be required by law or for purpose of compliance with our religious obligations. Because synagogue records are often a valuable source of information which may be required for halachic or genealogical purposes, selected items of personal information may be retained indefinitely.

Web Site
Our Web site, www.bethradom.com, may contain links to other sites which are not governed by this privacy policy. While no specific personal information is retained with respect to any visitor to our website, we may monitor traffic patterns, site usage and related site information to optimise our web service. In the continuing development of our website we may provide aggregated information to third parties, but these statistics do not contain any identifiable personal information.

Communicating with Us
e-mail is not a 100% secure medium and you should be aware of this when contacting us to send personal or confidential information.

Changes to this Privacy Policy
This policy is effective June 1, 2008. Since Beth Radom Congregation regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time. Please refer to our website for revisions and updates.

Requests for Access
If you have any questions, wish to review your personal information, comment on this policy or make a complaint; please contact our privacy officer at:

Beth Radom Congregation
18 Reiner Road
Toronto, On, M3H 2K9
Canada
416-636-3451

Principle 4 - Limiting Collection of Personal Information

BETH RADOM CONGREGATION shall limit the collection of personal information to that which is necessary for the purposes identified by BETH RADOM CONGREGATION.  BETH RADOM CONGREGATION shall collect personal information by fair and lawful means.

In conducting surveys, BETH RADOM CONGREGATION limits the amount and type of personal information it collects.  We collect only the amount and type of information needed for the purposes identified to individuals.

BETH RADOM CONGREGATION collects personal information about an individual primarily from that individual or a member of that individual’s household.  Except as permitted by law, BETH RADOM CONGREGATION will only collect personal information from external sources, such as client organizations, if individuals have consented to such collection.

Principle 5 - Limiting Use, Disclosure, and Retention of Personal Information

BETH RADOM CONGREGATION shall not use or disclose personal information for purposes other than those for which it was collected, except with the consent of the individual or as required or permitted by law. Personal information shall be retained only as long as necessary for the fulfillment of those purposes.

BETH RADOM CONGREGATION may disclose a respondent’s personal information to:

(a)           a client of BETH RADOM CONGREGATION where the respondent has consented to such disclosure;

(b)           a third party engaged by BETH RADOM CONGREGATION to perform functions on its behalf;

(c)           a public authority or agent of a public authority if, in the reasonable judgment of BETH RADOM CONGREGATION, it appears that there is imminent danger to life or property which could be avoided or minimized by disclosure of the information; or

(d)           a third party or parties, where the respondent consents to such disclosure or disclosure is required or permitted by law.

Only BETH RADOM CONGREGATION’s employees with a business need-to-know, or whose duties reasonably so require, are granted access to personal information about respondents.

BETH RADOM CONGREGATION shall keep personal information only as long as it remains necessary or relevant for the identified purposes or as required by law.  Depending on the circumstances, where a respondent may have to be re-contacted for purposes of clarifying responses to a survey, or to seek additional responses, BETH RADOM CONGREGATION shall retain the personal information for a period of time that is reasonably sufficient to allow this re-contact.

BETH RADOM CONGREGATION shall maintain reasonable and systematic controls, schedules and practices for information and records retention and destruction which apply to personal information that is no longer necessary or relevant for the identified purposes or required by law to be retained.  Such information shall be destroyed, erased or made anonymous.

Principle 6 - Accuracy of Personal Information

Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used.

Personal information used by BETH RADOM CONGREGATION shall be sufficiently accurate, complete, and up-to-date to minimize the possibility that inappropriate information may be used to make a decision about a respondent.

BETH RADOM CONGREGATION shall update personal information about respondents and employees as necessary to fulfill the identified purposes or upon notification by the individual.

Principle 7 - Security Safeguards

BETH RADOM CONGREGATION shall protect personal information by security safeguards appropriate to the sensitivity of the information.

BETH RADOM CONGREGATION shall protect personal information against such risks as loss or theft, unauthorized access, disclosure, copying, use, modification or destruction, through appropriate security measures, regardless of the format in which it is held.

BETH RADOM CONGREGATION shall protect personal information disclosed to third parties by contractual agreements stipulating the confidentiality of the information and the purposes for which it is to be used.

All of BETH RADOM CONGREGATION’s employees with access to personal information shall be required to respect the confidentiality of that information.

Principle 8 - Openness Concerning Policies and Procedures

BETH RADOM CONGREGATION shall make readily available to individuals specific information about its policies and procedures relating to the management of personal information.

BETH RADOM CONGREGATION shall make information about its policies and procedures easy to understand, including:

(a)           the title and address of the person or persons accountable for BETH RADOM CONGREGATION’s compliance with its Privacy Policy and to whom inquiries and/or complaints can be forwarded;

(b)           the means of gaining access to personal information held by BETH RADOM CONGREGATION; 

(c)           a description of the type of personal information held by BETH RADOM CONGREGATION, including a general account of its use; and

(d)           a description of what personal information is made available to related organizations (e.g. subsidiaries).

Principle 9 – Individual Access to Personal Information

Upon request, BETH RADOM CONGREGATION shall inform an individual of the existence, use, and disclosure of his or her personal information and shall give the individual access to that information.  An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate.

Upon written request to the Privacy Officer, BETH RADOM CONGREGATION will inform an individual of the existence, use and disclosure of his/her personal information and shall be given access to that information

In certain situations, BETH RADOM CONGREGATION may not be able to provide access to all the personal information that it holds about a respondent.  For example, BETH RADOM CONGREGATION may not provide access to information if doing so would likely reveal personal information about a third party or could reasonably be expected to threaten the life or security of another individual.  Also, BETH RADOM CONGREGATION may not provide access to information if disclosure would reveal confidential commercial information.

In order to safeguard personal information, a respondent may be required to provide sufficient identification information to permit BETH RADOM CONGREGATION to account for the existence, use and disclosure of personal information and to authorize access to the individual’s file.  Any such information shall be used only for this purpose.

BETH RADOM CONGREGATION shall promptly correct or complete any personal information found to be inaccurate or incomplete.  Any unresolved differences as to accuracy or completeness shall be noted in the individual’s file.  Where appropriate, BETH RADOM CONGREGATION shall transmit to third parties having access to the personal information in question any amended information or the existence of any unresolved differences.

Respondents and employees can obtain information or seek access to their individual files by contacting the BETH RADOM CONGREGATION Privacy Officer.

Principle 10 - Challenging Compliance

An individual shall be able to address a challenge concerning compliance with the above principles to the designated person or persons accountable for BETH RADOM CONGREGATION’s compliance with the BETH RADOM CONGREGATION Privacy Policy.

BETH RADOM CONGREGATION shall maintain procedures for addressing and responding to all inquiries or complaints from its respondents regarding BETH RADOM CONGREGATION’s handling of personal information.

BETH RADOM CONGREGATION shall, on written request, inform its respondents about the existence of these procedures as well as the availability of complaint procedures.

The person or persons accountable for compliance with the BETH RADOM CONGREGATION Privacy Policy may seek external advice where appropriate before providing a final response to individual complaints.

BETH RADOM CONGREGATION shall investigate all complaints concerning compliance with its  Privacy Policy.  If a complaint is found to be justified, BETH RADOM CONGREGATION shall take appropriate measures to resolve the complaint including, if necessary, amending its policies and procedures.  The respondent shall be informed of the outcome of the investigation regarding his or her complaint.

Additional Information

For more information regarding the BETH RADOM CONGREGATION Privacy Policy, please contact the BETH RADOM CONGREGATION.

Please visit the Privacy Commissioner of Canada’s website at www.privcom.gc.ca.