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ndds

PRIVACY POLICY

Effective: February 19, 2015

Table of Contents

1 - PURPOSE

2 - POLICIES

2-1 COLLECTION OF PERSONAL INFORMATION

2-2 USE OF PERSONAL INFORMATION

2-3 DISCLOSURE OF PERSONAL INFORMATION

2-4 STORING, PROCESSING AND SECURING PERSONAL INFORMATION

2-5 WEBSITE USE

2-6 THE MODEL CODE FOR THE PROTECTION OF PERSONAL INFORMATION

2-7 ADDITIONAL INFORMATION


1 - PURPOSE

ndds or we is a not-for-profit organization committed to promoting optimal child development by providing a simple, affordable checklist that assists in early identification of childhood developmental delays and providing suggestions and activities that foster age appropriate development. ndds is committed to keeping the Personal Information of our users accurate, confidential and secure. The purpose of this Privacy Policy is to provide information regarding the Personal Information that ndds collects, uses and discloses.

ndds knows how important your privacy is to you. Our relationship with you is founded on trust and we are committed to maintaining that trust. We recognize that your right to privacy is an essential issue and understand your interest in protecting your Personal Information. For these reasons, ndds’ Privacy Policy incorporates high standards as set out in federal and provincial Canadian privacy legislation and confirms our dedication to protecting your privacy, while maintaining the trust that you have placed in our organization. This Privacy Policy may be updated from time to time by ndds at which time we will give you reasonable notice. Please check our website periodically to see the current Privacy Policy.

For the purposes of this Privacy Policy, “Personal Information” refers to any information about an identifiable individual. Information will be about an “identifiable individual” where there is a serious possibility that an individual could be identified through the use of that information, either alone or in combination with other information.

2-1 COLLECTION OF PERSONAL INFORMATION

1. ndds is committed to identifying the purposes for which Personal Information is collected at or before the time the information is collected, and to documenting the purposes for which Personal Information is collected. The Personal Information we may collect from you includes:

(a) Contact information, such as your name and/or the name of your organization, as well as your complete mailing address, telephone and fax numbers, website address, and email address;

(b) Date of birth and first name of the child and email address of the parent or caregiver registering for or purchasing the “ndds” or the Electronic “endds”;

(c) When making purchases, credit card information, not including personal banking information will be collected;

(d) When using the website, the user’s IP address is collected and personal email address will be requested; and

(e) Other Personal Information that may be collected to be used for purposes that an individual would consider reasonable in the circumstances.

2. When you voluntarily provide us with your Personal Information we assume that you consent to ndds collecting it and using it for the specific purposes identified at the time of the collection, or in this Privacy Policy. We do not collect Personal Information indiscriminately nor do we collect any information about you unless you willingly provide it to us.

3. If at one time you provided us with your Personal Information you may withdraw your consent to our collection of your Personal Information at any time, subject to legal or contractual restrictions and reasonable notice, by contacting the Chief Privacy Compliance Officer listed in this Privacy Policy. Please note that the withdrawal of your consent may impact on our ability to serve you and to maintain our relationship.

2-2 USE OF PERSONAL INFORMATION

1. The above noted Personal Information that ndds collects from you may be used by ndds for the following limited purposes:

(a) Customer contact information is used to complete sales and shipping transactions;

(b) Credit card information is collected for the payment of purchases;

(c) Date of birth of the child is required in order to email the parent/guardian the initial age-related checklist;

(d) Email addresses are used to send checklists and to send reminder emails to users when it is time for the user to complete the next checklist; and

(e) To determine Ontario residency and therefore establish if the user can access the free version of the checklists and activities available for Ontario residents on the ndds website.

2. We will provide further details to you about Personal Information that we may collect or use, either at the time we ask you to provide that information or through changes to this Privacy Policy. Although you may choose not to share your Personal Information with ndds, if you choose not to do so, the information you receive regarding ndds services and your ability to use ndds material may be limited.

3. If at one time you provided your Personal Information for a particular program or service, but you wish to remove your Personal Information, you may unsubscribe by contacting the Chief Privacy Compliance Officer listed in this Privacy Policy.

2-3 DISCLOSURE OF PERSONAL INFORMATION

1. By providing your Personal Information to ndds, you have confirmed your trust in us. We are honoured by this and take pride in serving you. ndds may share your Personal Information with third parties in the following limited ways:

(a) Statistics from Ontario users downloading PDFs and accessing the endds from the ndds website are shared with the Ministry of Children and Youth Services (“MCYS”) as part of ndds’ licensing agreement with the MCYS; and

(b) When requested, endds statistics are shared with health units in Ontario for their catchment area.

(c) Personal Information is shared with Moyer Printing in order to fulfill and ship products ordered.

Personal Information is only shared with MCYS or Ontario health units in a format that does not disclose the identity of the users or their children.

2. Personal Information may also be disclosed without your consent if required by law or where ndds believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety, or property of an identifiable person or group.

3. In addition, we may use Personal Information collected from or on behalf of another organization without your consent if you had consented to the use of the Personal Information by the other organization, and we are using the Personal Information solely for the purposes for which the information was previously collected and to carry out work on behalf of the other organization.

4. We may also disclose Personal Information to another organization without your consent if you had consented to the use of the Personal Information by us, and we are disclosing the Personal Information to the other organization solely for the purposes for which the information was previously collected.

5. ndds remains responsible for Personal Information in its possession or custody, including information that ndds transfers to a third party. As such, ndds enters into confidentiality or contractual agreements with third parties to whomndds transfers Personal Information requiring them to provide a level of security comparable to that provided under the ndds Privacy Policy.

2-4 STORING, PROCESSING AND SECURING PERSONAL INFORMATION

1. ndds stores and maintains Personal Information in conformity with the requirements of the Personal Information Protection and Electronic Documents Act and the Model Code for the Protection of Personal Information. We use a variety of secure means to store your Personal Information. These include:

(a) Electronic order forms (with the exception of credit card information) are stored in Simply Accounting software;

(b) Personal Information collected from Ontario residents registering for PDF downloads and accessing endds and similar Personal Information from customers purchasing the online version of ndds and endds is stored on the one of two secure servers stored in a home office and monitored several times daily; and

(c) Hard copies of order forms containing Personal Information and credit card information are stored in locked filing cabinets in secure areas.

2. The ndds Management Consultant is the only person who has on-going access to your Personal Information to fulfill the purposes indentified upon the collection of the information or for the purposes stated in this Privacy Policy. The Management Consultant is the only person with access to the PayPal account or the Simply Accounting software. The President and Treasurer of ndds are permitted access to Personal Information on a need-to-know basis, upon request. The ndds IT Consultant has access to all electronic deliverables and to all information saved on the ndds server that he/she is responsible for; however, the IT Consultant does not have access to financial information. When providing your information over the phone, the Office Assistant records the information and passes it along to the Management Consultant.

3. ndds does not store any credit card or banking information electronically. All online orders are paid through a PayPal terminal, which does not store credit card numbers and the complete card number is not visible to the ndds Management Consultant. Credit card numbers are not stored in the Simply Accounting software and are blacked out on hard copy order forms once processed.

2-5 WEBSITE USE

1. In order to login to the website, an individual’s email address is collected and the computer’s IP address is also collected to determine Ontario residency. If the person chooses to use the interactive checklist on the website, they provide their child’s birth date (but no other personal information) in order to determine which checklist to provide. For each subsequent child registered, the child’s first name and birth date are collected.

2. An individual may choose to share and store their location information so the website can recognize them when the individual returns to the website and the information can be used to determine Ontario residency.

3. ndds may provide links to other websites managed by third parties through our website. As we cannot control or be responsible for the actions or policies of such third parties, you should check the applicable privacy policy of such third parties when visiting their websites or when providing any Personal Information to them. Please also note that we cannot control or prevent the use of cookies or any information obtained through cookies by such third parties.

4. Information voluntarily disclosed online in discussion areas or other public areas of our website can be collected, used and disclosed by third parties. Any submissions made to discussion areas or other public areas on our website are done at the user’s risk and on the understanding that such information may be accessible to third parties. We cannot control and will not be liable for any damages that may arise from such user activity.

2-6 THE MODEL CODE FOR THE PROTECTION OF PERSONAL INFORMATION

ndds applies the ten principles of the Model Code for the Protection of Personal Information when collecting, using or disclosing your Personal Information:

1. Accountability

ndds is responsible for the Personal Information under its control, which it has collected and maintained. In order to fulfill this responsibility, we have designated a Chief Privacy Compliance Officer, whose contact information in this Privacy Policy, to be responsible for the day-to-day care and control of Personal Information. We have taken the following measures to ensure compliance with this Privacy Policy:

(a) Developing procedures to protect Personal Information;

(b) Developing procedures to receive and respond to complaints and inquiries;

(c) Training our staff about our policies and practices respecting Personal Information; and

(d) Developing and distributing information to our staff and the general public explaining our policies and procedures respecting Personal Information.

2. Identifying Purposes

ndds is committed to being open with you regarding how it collects and uses Personal Information, as discussed above. To demonstrate this openness, we require the consent of individuals prior to using their Personal Information for any purpose other than that for which it was originally collected or stated within this Privacy Policy. Similarly, if any individuals wish to be advised of the Personal Information we have that is related to them, they can contact us at the address set out below.

3. Consent

ndds is committed to ensuring that you are aware of how your Personal Information is used. We are dedicated to obtaining the informed consent of individuals who provide us with their Personal Information. If your Personal Information is to be used for a new purpose not previously identified, consent for that new purpose will be obtained. To this end, all of our employees, personnel or agents are instructed to provide information about how Personal Information is used by us to all interested individuals who inquire, as well as obtain the informed consent of those who provide their Personal Information to ndds. As well, we may periodically request written confirmation from you to ensure that the Personal Information collected and maintained by us is up-to-date and accurate. We may also ensure that we have your continuing consent to use and retain your Personal Information. ndds will not disclose your Personal Information without your consent. It will only do so if required by law or in the good faith belief that such action is necessary to:

(a) Conform to obligations imposed by law or statute;

(b) Meet an emergency need; and/or

(c) As required pursuant to a criminal investigation.

You may withdraw your consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting the Chief Privacy Compliance Officer. Please note that the withdrawal of your consent may impact ndds’ ability to serve you and to maintain your relationship with ndds.

4. Limiting Collection

ndds restricts the collection of Personal Information only to that information that is necessary for the limited purposes noted above. We are committed to collecting Personal Information in a fair, open and lawful manner. For this reason, ndds does not indiscriminately collect Personal Information. We collect Personal Information to fulfill the above-noted purposes only, and for no other purposes.

5. Limiting Use, Disclosure and Retention

ndds does not use Personal Information for purposes other than those for which it was originally collected, unless stated in this Privacy Policy, or it has first obtained the consent of the person from whom such information was received. We retain Personal Information for as long as it is needed or legally required, and only for the fulfillment of the purposes for which it was originally collected. If ndds is disposing of or destroying Personal Information which is no longer needed, we ensure that the appropriate measures are taken regarding the disposal or destruction so as to prevent unauthorized parties from gaining access to the information. ndds ensures that any third parties are following ndds’ policies regarding the retention and destruction of Personal Information.

6. Accuracy

ndds is committed to maintaining accurate, complete and up-to-date Personal Information. If you are aware of changes to the Personal Information you have given to us, simply inform us of the changes and we will update our records accordingly. You may check and correct your Personal Information by contacting ndds and the Chief Privacy Compliance Officer assigned to oversee the day-to-day care and control of Personal Information by writing or emailing your request to the address set out below.

7. Safeguards

ndds has developed and implemented security safeguards appropriate to the sensitivity of the Personal Information kept by us. We also ensure that any of our employees who deal with Personal Information are properly trained and are aware of the necessary and appropriate measures required to protect Personal Information. Any Personal Information kept by us is disposed of or destroyed once it is no longer needed to meet the purposes for which it was collected, or when we are legally able to do so.

8. Openness

ndds makes information about its policies and practices respecting the collection and maintenance of Personal Information available to all interested parties. We are pleased to answer any questions that you may have regarding the collection and maintenance of Personal Information. Please forward any questions in writing or email to the address set out below.

9. Individual Access

You can also request access to your Personal Information held by us. However, we reserve the right to confirm the identity of the person seeking access to Personal Information before complying with any access requests. Please forward your access request in writing or email to the address below.

10. Challenging Compliance

As noted above, ndds has designated an official who is responsible for the day-to-day care and control of Personal Information. This official will receive and respond to all information requests regarding our Privacy Policy or about your Personal Information under our care and control. We have procedures in place to receive and respond to complaints or inquiries about our policies and practices relating to the handling of Personal Information. We inform individuals who make inquiries or lodge complaints of the existence of relevant complaint procedures. We investigate all complaints. If a complaint is found to be justified, then we take appropriate measures to resolve the matter including, if necessary, amending our policies and practices. We reserve the right to seek legal advice where appropriate before providing a final response to inquiries or complaints.

2-7 ADDITIONAL INFORMATION

If you would like to receive more information about our Policies, withdraw the Personal Information you may have provided in the past, or access or correct your Personal Information, please contact our Chief Privacy Compliance Officer by e-mail or in writing, as provided below:

ATTENTION: CHIEF PRIVACY COMPLIANCE OFFICER

Joan McGoey, ndds Management Consultant

ndds

PO Box 1493

North Bay, ON, P1B 8K6

Tel: 705-303-5081 / 1-888-582-0944 FREE

Fax: 705-752-4247

joan.ndds@ontera.net

 

e: info@ndds.ca
t: (705) 472-9211 or 1-888-582-0944
f: (705) 472-9588