Version effective since 03 Oct 2019.
The Praxis Spinal Cord Institute (Praxis) is fully committed to protecting the privacy of our employees, prospective employees, contributors, volunteers and all stakeholders. We value your trust and understand that upholding this trust requires us to be transparent and accountable as to how we use any personal information you provide to us.
In fulfilling our mission, from time to time we may collect and use personal information (as defined in this policy). Praxis operates in multiple jurisdictions to achieve its mandate, and in doing so, Praxis is compliant with Canadian legislative requirements, international data protection standards, and privacy best practices.
The purpose of these regulations are to govern the collection, use and disclosure of personal information and personal health information by organizations in a manner that recognizes both the right of individuals to protect their personal information and the need of organizations to collect, use or disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances.
What is Personal Information/ Personal Health Information?
Personal information is information about an identifiable individual such as someone’s name, home address, home phone number, personal email address, social insurance number, gender, income or family status. Personal information also includes donation information.
Personal health information is identifying information that relates to the provision of health care to the individual. It can include patient survey data, patient reported outcomes, and abstracted health information. At Praxis, personal health information is sometimes collected by researchers and securely transmitted to Praxis for storage, analysis and aggregate reporting.
Why We Collect and Use Personal Information
Praxis collects and uses personal information for purposes necessary to fulfill our mission and in order to comply with any legal requirements. This includes the following purposes:
- To share information about Praxis with stakeholders and those who may be interested in our activities.
- To track and issue tax receipts for donations received in accordance with Canada Revenue Agency requirements.
- To establish, build, and maintain relationships.
- To process financial transactions (including donations).
- To determine the eligibility of an individual or community to receive a grant and/or to issue grants.
- To use photographs taken at events related to Praxis in our publications including: newsletters, registration forms or on our website.
- To establish, maintain and manage employment relationships between Praxis and its personnel.
- To share other people’s stories in relation to Praxis and spinal cord injury (SCI) in general.
- To improve our ability to provide services in accordance with our mission.
- To carry out activities to further our charitable purpose.
Praxis discloses personal information only for purposes necessary to fulfill our mission and in order to comply with legal requirements. This includes the following purposes:
- To assist an individual in receiving a grant or service in accordance with our mission.
- To use photographs in future publications including: newsletters, registration forms, or on our website.
- To establish, maintain, and manage employment relationships between Praxis and its personnel.
- To share other people’s stories in relation Praxis and SCI in general.
- To give donor recognition where permission to do so has been granted by the donor.
- To use third party service providers to process personal information on our behalf or to assist us with various other services such as research and mail distribution (refer to Limits on Collection, Use and Disclosure section for more detail).
- To carry out activities to further our charitable purpose.
In order to achieve the above stated purposes, Praxis collects the following types of information:
- Contact information including name, address, phone number, and email.
- Financial information required to process donations.
- Spinal cord injury information.
- Photographs to use in future publications including: newsletters, registration forms, and on our website.
- Personal stories (which are voluntarily provided).
Limits on Collection, Use and Disclosure
Praxis will only collect, use, and disclose personal information for the purposes stated above and in accordance the Personal Information Protection Act (BC), the federal Personal Information Protection and Electronic Documents Act, and any other applicable privacy regulations. If we do require your personal information for any purposes other than those for which it was originally obtained, we will first ask for your permission to do so.
In the case of employee home contact information, no employee is authorized to share this information with anyone outside of Praxis unless authorized by that employee. In the case of emergency contact information, it is only to be used in the case of an emergency.
How We Disclose Personal Information
The only times in which personal information will be disclosed to other organizations is when service providers are contracted on our behalf to process your information or assist us with various other services such as mail distribution and research, if it is to help an individual in receiving a grant or service in accordance with our mission, or if we are required to do so by law.
Praxis will not rent, sell, lease, or barter your information to any organizations or individuals.
How We Obtain Consent to Collect, Use and Disclose Personal Information
When Praxis does find it necessary to collect, use and/or disclose personal information, consent to do so will be obtained either through express consent, deemed consent, or by giving an individual the opportunity to decline consent.
Praxis will make every effort to notify an individual of the purpose for collection, use or disclosure of personal information and give a reasonable chance to refuse consent and/or to withdraw consent at a later date. Only extenuating circumstances which are in the best interests of donors/participants will permit the contacting of donors/participants whom have opted out of being on our contact list.
In the case of photographs or information collected at school events, consent to use this information will be acquired from the school in accordance with its privacy policies and practices. In the case of photographs and film taken by Praxis at other private events, signs will be placed at the entrances and other visually accessible places to notify people that this will be taking place, what the photographs and film will be used for, and that give the contact information for the privacy officer or delegate should that person wish to not have their photographs and film used or disclosed.
At any time after collection, an individual may withdraw their consent by giving a reasonable amount of notice to Praxis.
Retention of Personal Information
Praxis acts in accordance with the Canada Revenue Agency’s guidelines for retaining donor information for a time period of six years from the end of the year in which the donation was made. Any other personal information used to make a decision about an individual will be retained for a minimum of one year. Permission for use or disclosure of this information can be withdrawn at any time.
Accuracy of Information
Praxis ensures that any personal information in our custody is accurate and up to date. In most instances we rely on individuals to notify us of any changes to their information.
Security and Protection of Online Donation Information
Praxis maintains appropriate security measures to safeguard personal information depending upon the sensitivity of the information and how it is stored. Measures include locked cabinets, restricted access to certain records on a need- to- know basis, the use of passwords, the use of encryption, and legally binding confidentiality agreements with all Praxis personnel.
Use of “Cookies”
Most web browsers automatically accept cookies. Users can be notified when this happens, or prevent it from occurring, by setting the appropriate browser selections.
Use of Internet Protocol (IP) Addresses
Praxis uses IP addresses to assist in diagnosing server problems. We reserve the right to perform statistical analyses of user behaviour and characteristics, to measure interest in and user traffic patterns to the various sections of our website, to prevent abuse in our online forums, and to help us improve design, layout and navigation.
Links to Other Websites
Praxis’ website contains links to other websites that may be of interest to the visitor to our site. By providing these linkages, Praxis is not responsible for the privacy practices, content, transactions, and functioning of the linkages of these sites. Users submitting information to these third party websites should review the privacy statements of these sites before providing them with personally identifiable information.
Policy Updates and Changes
If you have any questions or concerns about our information handling practices, you may contact our privacy officer at:
Praxis Spinal Cord Institute
6th Floor, Blusson Spinal Cord Centre
6400 – 818 W 10th Avenue, Vancouver, BC V5Z 1M9