Privacy Policy
Your Privacy Rights
Congregation Darchei Noam (“Darchei Noam”) 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, potential members and individuals who access services offered by Darchei Noam (“you”) that the personal information they entrust to us is safe, we have developed this Privacy Policy.
“Personal Information” means information about an identifiable individual. Darchei Noam collects financial and contact Personal Information from you about you and your family members. Personal Information is defined in section 2 of the Freedom of Information and Protection of Privacy Act and more particularly described below.
Why Does Darchei Noam Collect Personal Information From You?
Darchei Noam collects Personal Information so that we can provide our members and our community with a range of services and activities, which include:
- Yahrzeit reminders and aliyot
- Bulletin and general notices and mailings
- General announcements, including life cycle events, illness and death of family members
- Identifying the appropriate membership category for you/your family
- Membership privileges
- Membership status determination
- Our fundraising efforts
- Receipts for donations
- To generally communicate with our members and their spouses and family members
- To understand and assess the needs and requirements of our members and potential members and offering services, programming and events to meet those needs
- As applicable, to assist the Darchei Noam Hebrew School and Youth Education Programming (YEP) in providing services and programs to the younger members of our community
- To assist potential members in finding their place at Darchei Noam.
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 Personal Information only by lawful and fair means and not indiscriminately. We may collect Personal Information directly from you when you access our services, make a donation, become a member of Darchei Noam, or during the term of your membership. We may on occasion obtain information about you from other sources, such as other family members or members of Darchei Noam.
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.
All members have access to Darchei Noam’s secure “members only” portal, where each member can see what information is stored about you and your family. Certain information about your family, such as your transaction history, will only ever be viewable by you and authorized persons on behalf of Darchei Noam (Directors and Staff), and only for purposes necessary for the business of the congregation. Through the portal, you have the ability to identify what Personal Information, including contact information, you are willing to share with other members of the congregation through the portal, and what you prefer to keep private. You can change the information at any time by accessing the members’ portal.
If You Do Not 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 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 Darchei Noam. 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 Darchei Noam 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, or in response to a subpoena or a court order
- 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
- In an emergency, e.g., if your health or safety is in danger
- Where it is necessary to establish or collect contributions
- 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 Darchei Noam maintains Personal Information.
Is My Personal Information Secure?
Darchei Noam 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 Personal 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
- Where necessary or appropriate, by requiring third parties to sign a confidentiality agreement
As Darchei Noam is responsible for any Personal Information under its control, including Personal Information that Darchei Noam 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 Darchei Noam’s behalf.
Updating Your Personal 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 either make the changes yourself in the members’ portal or inform the Darchei Noam office 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 to the Darchei Noam privacy officer. More detailed requests that require archive, retrieval or copying costs may be subject to reasonable reimbursement for our actual costs. You also have access to all this information on the members’ portal
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 Darchei Noam’s rights and property
- The request is frivolous or vexatious
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 religious, historic, or genealogical purposes, selected items of Personal Information may be retained indefinitely.
Web Site
Our Web site, www.darcheinoam.ca, may contain links to other sites which are not governed by this Privacy Policy. Darchei Noam, on its own or through third party providers, collects certain non-personal information, including data about domain names and IP addresses used to access the Darchei Noam Web site, as well as the type of browser and system you are using. This data is used for statistical purposes and to optimize our Web service. In the continuing development of our Web site, we may provide aggregated information to third parties, but these statistics do not contain any identifiable Personal Information. Personal information will not be posted on any of our digital channels.
Communicating with Us
E-mail is not a 100% secure medium and you should be aware of this when contacting us to send Personal Information or other confidential information.
Challenging Compliance
An individual shall be entitled to address a challenge concerning compliance with this privacy policy to the privacy officer. All such correspondence shall be sent in writing, by email, mail or hand delivered to the privacy officer at the address below. The privacy officer shall acknowledge receipt of every correspondence challenging compliance within a reasonable period, shall conduct a timely investigation, and shall respond to any allegations in a timely manner. The privacy officer shall retain a log of all challenges or complaints and shall report in writing annually (or more frequently if requested) to the President of Darchei Noam, or the President’s designate. The privacy officer shall seek advice from legal or other professionals, at the officer’s discretion, before responding to any complaints or challenges to compliance. If a complaint or challenge is found to be justified, Darchei Noam shall take appropriate measures, including, if necessary and where reasonable, amending its policy and practices. The complainant shall be informed of the steps taken regarding the complaint or challenge, without breaching Darchei Noam’s or any other individual’s privacy, legal rights or Personal Information.
Changes to this Privacy Policy
This Policy was originally passed as effective June 1, 2019. This revised Policy is effective February 1, 2021. Since Darchei Noam regularly reviews all of its policies and procedures, we may change our Privacy Policy from time to time. Please refer to our Web site 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. The Privacy Officer will be the Secretary of the Board of Directors and can be contacted at:
Congregation Darchei Noam
864 Sheppard Avenue West
Toronto, ON M3H 2T5
Attention: Privacy Officer
(416) 638-4783 x22
February 1, 2021