Foodshake is committed to protecting the privacy and confidentiality of information it receives or creates in the course of conducting its business operations. Foodshake fulfills this commitment to privacy and confidentiality by complying with the federal Personal Information Protection and Electronic Documents Act and by adopting the practices set out in this Privacy Policy (the “Policy”).
APPLICATION
The Policy applies to any personal information that Foodshake collects, uses or discloses in the course of its business operations and/or in the provision of its services. All Foodshake employees, volunteers, contractors, sub-contractors and third parties are subject to the Policy.
Exception: The Policy does not apply in respect of the personal information that Foodshake collects, uses, discloses or maintains about its current and former employees. Those guidelines are instead contained in Foodshake’s internal Employee Privacy Policy. The Privacy Policy does apply in respect of Personal Information that Foodshake collects, uses, discloses and maintains about volunteers and candidates for employment.
PURPOSES FOR WHICH INFORMATION IS COLLECTED, USED OR DISCLOSED
Foodshake only collects, uses and discloses personal information for purposes that are appropriate in the circumstances and only such personal information as is required for the purposes of conducting its operations and/or providing its services.
Foodshake is committed to ensuring the fair handling of personal information at all times, throughout the organization and in its dealings with third parties.
The purposes for which Foodshake may collect, use, disclose or retain personal information include, but are not limited to:
Determining eligibility for products or services;
Processing payments for services, for example, to reimburse volunteers;
Contacting individuals to provide information or updates and to inform of projects, programs, products and initiatives;
Conducting research and assessing trends that affect the business and its activities;
Assessing or verifying educational or other credentials; or
Recruitment purposes.
Foodshake’s use of the information it collects is limited to the purposes set out above, or to those that are identified at the time of collection.
Personal information will be collected, wherever possible, directly from the individual to whom the information relates, but under certain circumstances, Foodshake may also collect personal information from third parties.
Foodshake will not sell, trade, barter, exchange or disclose for consideration any personal information that it obtains.
III. LIMITS ON THE COLLECTION OF INFORMATION
Foodshake collects only the amount and type of information that is necessary for an identified purpose and will do so only by fair and lawful means.
LIMITS ON THE USE AND DISCLOSURE OF INFORMATION
Foodshake will not use or disclose personal information in its custody or control (or to which it has access in the course of providing regulatory support) except as necessary in the course of performing its duties.
Foodshake only uses or discloses personal information for the purposes for which it was collected, unless the individual consents or the use or disclosure is authorized by law.
CONSENT
Foodshake respects and values an individual’s right to provide or withhold consent in relation to his or her information. Except where the law authorizes collection, use and disclosure of personal information without consent, and prior to collecting, using and disclosing such information, Foodshake will obtain the meaningful consent of the individual to whom the personal information relates:
Wherever practical, Foodshake will put additional emphasis on key elements, such as what personal information is being collected, with which parties’ personal information will be shared, and identify potential harms and other consequences arising from the collection, use or disclosure of personal information;
Foodshake will be transparent and prepared to explain why any given collection, use or disclosure is a condition of service; and
Foodshake will draft consent requests and processes in ways that are user-friendly and provide information in a generally understandable format so that individuals can understand that to which they are consenting.
In the limited circumstances where Foodshake requires access to personal information in the course of providing regulatory support, the duty to obtain consent rests with the regulators’ employee at the point of collection, such that additional consent will not be obtained by Foodshake.
An individual can refuse to consent to the collection, use or disclosure by Foodshake of their personal information, or they may withdraw their consent at any time by providing reasonable notice. In certain cases, the refusal or withdrawal of consent may limit the individual’s eligibility for Foodshake services, products or programs.
ACCURACY
Accurate information is vital to Foodshake’s ability to provide high-quality services. To this end, Foodshake strives to keep personal information as accurate, complete and up-to-date as possible, taking into account its use and the interests of the individual to whom the information relates.
In certain cases, Foodshake may contact individuals who have provided their personal information in order to verify the accuracy of the information. Otherwise, individuals should be encouraged to inform Foodshake, promptly, if there are any changes to their personal information.
VII. RETENTION OF PERSONAL INFORMATION
Foodshake will only keep an individual’s personal information for as long as it is required for the reason it was collected. The length of time varies, depending on the purpose for which it was collected and the nature of the information. This period may extend beyond the end of an individual’s relationship with Foodshake but it will be only for so long as it is necessary for Foodshake to have sufficient information to respond to any issues that may arise at a later date.
When personal information is no longer required, Foodshake will take steps to destroy, erase or render anonymous the information.
VIII. ACCESSING INFORMATION
An individual may request access to their personal information that is under the custody or control of Foodshake. Foodshake will endeavour to provide the requested information within a reasonable time, generally no later than 30 days following its receipt of the request.
Foodshake will disclose or grant access to the information unless there is a compelling reason against disclosure. Examples of such situations where Foodshake will not disclose this information include but are not limited to where:
a legal privilege restricting disclosure applies;
another law prohibits disclosure;
it may harm or interfere with law enforcement activities and other investigative or regulatory functions;
it does not exist, is not held, or cannot be found by Foodshake;
it would disclose trade secrets or other confidential information of Foodshake;
it would interfere with contractual or other negotiations of Foodshake or a third party; or
it is not readily retrievable and the burden or cost of providing the information would be disproportionate to the nature or value of the information.
SAFEGUARDS
Foodshake recognizes that appropriate safeguards are fundamental to maintaining the privacy and confidentiality of information.
Foodshake takes reasonable steps to protect the information it receives or creates against theft, loss, misuse, unauthorized access, disclosure, modification or destruction. These steps include using appropriate physical, organizational and technological measures to protect the confidentiality of all personal information that Foodshake retains or collects, regardless of the format in which it is held. Specifically, Foodshake has adopted security measures, including locked cabinets, restricted access, data networks protected by industry-standard firewalls, encryption and password protection systems in order to protect the personal information in its possession.
Additionally, Foodshake’s employees are aware of the importance of maintaining the privacy, confidentiality and security of personal information and will receive periodic training on the relevant safeguards that are in place.
Foodshake will take all reasonable steps necessary to ensure that any personal information collected in the course of its business operations and/or in the provisions of services is accessed only by Foodshake staff who have a “need to know” any such personal information.
OPENNESS, ACCOUNTABILITY AND COMPLIANCE
Foodshake is dedicated to implementing the principles described in this Policy, and to ensuring that stakeholders, including the government, the general public, and business partners – their officers, staff, and members – are aware of Foodshake’s privacy practices.
On an annual basis, Foodshake’s Legal Counsel will review the Policy and monitor compliance accordingly.
Persons wishing to access their personal information, or with any questions about this Policy, may contact Foodshake in via email:
foodshakeapp@gmail.com
If a person’s concerns are not resolved by Foodshake to their complete satisfaction, they are encouraged to contact the Federal Privacy Commissioner.