Privacy Policy

The Alzheimer Society of Manitoba is part of the Alzheimer Society Federation in Canada (“Federation”). The Federation includes the Alzheimer Society of Canada, as well as provincial and regional societies (together, these are the “Federation Partners”). You can find a full list of the Federation Partners in Schedule A of this Privacy Policy.

The Federation is a national movement dedicated to supporting individuals and families affected by Alzheimer’s disease and other dementias, while working toward a cure. The Federation Partners collaborate to achieve this shared mission. To support this work, the Alzheimer Society of Manitoba may share Personal Information with other Federation Partners when necessary to fulfill these purposes.

The Alzheimer Society of Manitoba (“ASM” or “we”) knows how important your privacy is to you. Our relationship with you is founded on trust and we are committed to maintaining that trust. The ASM recognizes that your right to privacy is an essential issue and understands your interest in protecting your Personal Information. For these reasons, the ASM Privacy Policy incorporates high standards as set out in federal and provincial Canadian privacy legislation and confirms our dedication to protecting your privacy and maintaining the trust that you have placed in our organization. This Privacy Policy may be updated from time to time by ASM 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, alone or in combination with other information.

1. Collection of Personal Information

ASM is committed to identifying and documenting the purposes for collecting Personal Information at or before the time of collection. The types of Personal Information we may collect from you include:

• Name
• Contact information (address, email, and/or phone, title)
• Relationships

When you provide Personal Information to us, we assume you agree to its collection and use for the purposes identified at the time of collection or in this Privacy Policy. We collect Personal Information only when necessary and only when you choose to provide it.

2. Use of Personal Information

The above noted Personal Information we collect from you may be used by ASM and Federation Partners for the following limited purposes:

• To cross-reference Personal Information between and amongst all Federation Partners
• To enable ASM to share information with you about our upcoming events and/or programs and services
• To invite you to make a donation to help support the work of ASM

Some of the Personal Information we collect is needed in order to satisfy the requirements of Canada Revenue Agency (CRA). We may provide more details about the Personal Information we collect, or how we use it, either at the time of collection or through updates to this Privacy Policy. You may choose not to provide your Personal Information; however, this may limit your ability to take part in ASM activities.

If you have previously provided your Personal Information and wish to withdraw or change your consent, you may unsubscribe by contacting the Chief Privacy Compliance Officer. Their contact information is provided at the end of this Privacy Policy.

3. Disclosure of Personal Information

By providing your personal information to us, you place your trust in us — and we deeply appreciate it. We take pride in serving you and protecting your privacy.

The Alzheimer Society of Manitoba (ASM) may share your personal information only in the limited ways described below. If you wish to withdraw your consent to share your personal information, please contact our Chief Privacy Compliance Officer using the details provided at the end of this Privacy Policy. Please note that withdrawing consent may affect our ability to serve you and maintain your relationship with us.

ASM and its Federation Partners may share personal information with one another when necessary to fulfill the purposes outlined in this Privacy Policy or those disclosed at the time of collection.

In some circumstances, we may also disclose your personal information without consent if the law, a court order, or a government authority requires us to do so. We may also disclose information if we have reasonable grounds to believe it is necessary to protect the rights, privacy, safety, or property of an individual or group.

ASM remains responsible for Personal Information in its possession or control, including information transferred to third parties for processing or storage. When we engage third parties to perform services on our behalf, we enter into confidentiality or contractual agreements requiring them to protect the information with security measures comparable to those outlined in this Privacy Policy.

4. Storing, Processing and Securing Personal Information

ASM 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 The Canadian Standards Association created and approved our Personal Information guidelines. When we use third-party service providers to store or process Personal Information, we include contractual and other safeguards to protect it. In some situations, third-party service providers may store or transfer Personal Information to countries that do not always follow Canadian privacy laws. However, ASM carefully selects trustworthy service providers who commit to protecting the privacy of your Personal Information, and we make every reasonable effort to ensure they uphold that commitment.

We use a variety of secure means to store and safeguard your Personal Information. These include:

• Password protected databases with access limited to authorized staff
• We store all paper-based information in locked filing cabinets or secure offsite storage facilities. In compliance with CRA legislative rules, we retain this information for seven years. After that period, a certified company shreds the records offsite, following the highest industry standards for information and data security.
• We save all ASM electronic files on a secure, password-protected network. An external IT company monitors the firewall regularly and ensures that all network traffic meets industry standards for information protection and data security.
• Our building premises remain secured by a 24/7 monitored alarm system, and only authorized staff have access after hours.

Relevant ASM staff members may access your Personal Information only when needed. Access is granted on a strict need-to-know basis to carry out the purposes for which the information was collected. This may include organizing fundraising campaigns, processing donations, or managing marketing and communication activities.

5. Website Use

ASM may collect and use an individual’s IP address, and date and time that the individual accessed our website, to help identify the individual, gather broad demographic information about users of the website, diagnose problems with our systems, and administer the website.

We use “Google Analytics” to collect information about use of the website. Google Analytics is a web analytics service that uses cookies to track information about the use of the website such as how often users visit the sites, what pages they visit when they do so, and what other websites they used prior to coming to the website. This information is used to improve website. Google Analytics only collects the IP addresses assigned to you on the date you visit the site, rather than your name or other identifying information about an individual. Information collected through the use of Google Analytics is not combined with personally identifiable information.

Google’s ability to use and share information collected by Google Analytics about your visits to the website is restricted by the Google Analytics Terms of Use and the Google Privacy Policy. Google Analytics stores information on servers in the United States and the governments, courts or law enforcement, or regulatory agencies of the United States may be able to obtain disclosure of Personal Information through the laws of the United States. You can prevent Google Analytics from recognizing you on return visits to the website by disabling cookies on your browser. If you choose, you can opt out by turning off cookies in the preferences settings in your web browser. For more information on Google Analytics, please visit: https://www.google.com/analytics/.

6. The Model Code for the Protection of Personal Information

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

i. Accountability

ASM is responsible for the Personal Information collected and maintained by it and which is under its control. In order to fulfill this responsibility, we have designated a Chief Privacy Compliance Officer whose contact information is available at the bottom of 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:

1. Developing procedures to protect Personal Information;
2. Developing procedures to receive and respond to complaints and inquiries;
3. Training our staff about our policies and practices respecting Personal Information; and
4. Developing and distributing information to our staff and the general public explaining our policies and procedures respecting Personal Information.

ii. Identifying Purposes

ASM is committed to being transparent with you about how we collect and use your Personal Information, as outlined above. To demonstrate this commitment, we obtain your consent before using your Personal Information for any purpose other than the one for which we originally collected it or those described in this Privacy Policy. If you would like to know what Personal Information we hold about you, please contact us at the address provided below.

iii. Consent

ASM is committed to helping you understand how we collect, use, and protect your Personal Information. We make it a priority to obtain informed consent from every individual who provides their Personal Information to us. If we plan to use your Personal Information for a new purpose not identified at the time of collection or in this Privacy Policy, we will first seek your consent for that purpose. All ASM employees, personnel, and agents explain how we use Personal Information to anyone who inquires and obtain informed consent from those who share their information with us.

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 also may ensure that we have your continuing consent to use and retain your Personal Information. We 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:

1. Conform to obligations imposed by law or statute;
2. Meet an emergency need; and/or
3. 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 on our ability to serve you and to maintain your
relationship with us.

iv. Limiting Collection

ASM collects only the Personal Information necessary for the limited purposes described above. We are committed to collecting Personal Information in a fair, open, and lawful manner. For this reason, we do not indiscriminately collect Personal Information. We collect Personal Information to fulfill the above-noted purposes only, and for no other purposes.

v. Limiting Use, Disclosure and Retention

ASM uses Personal Information only for the purposes we originally collected it for or those stated in this Privacy Policy. We obtain your consent before using it for any new purpose. We retain Personal Information only as long as necessary to fulfill those purposes or as required by law. When we no longer need the information, we securely shred and dispose of it. During disposal or destruction, we take all necessary measures to prevent unauthorized access or misuse of the information. ASM ensures that any third party service providers are following our policies regarding the retention and destruction of Personal Information.

vi. Accuracy

ASM 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 the Chief Privacy Compliance Officer assigned to oversee the day-today care and control of Personal Information by writing or emailing your request to the address set out below.

vii. Safeguards

ASM has developed and implemented security safeguards appropriate to the sensitivity of the Personal Information kept by us. We ensure that all employees who handle Personal Information receive proper training and understand the measures required to protect it. We dispose of or destroy any Personal Information once we no longer need it to fulfill the purposes for which we collected it.

viii. Openness

ASM makes information about its policies and practices respecting the collection and maintenance of Personal Information available to all interested parties. We are happy to answer any questions you may have about how we collect and maintain Personal Information. Please forward any questions in writing or email to the address set out below.

ix. 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 set out below.

x. Challenging Compliance

As noted above, ASM 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 policies or about your Personal Information under our care and control. We investigate all complaints received by us and will respond in writing in a timely manner.If we find a complaint to be justified, we will take appropriate action to resolve the matter to the complainant’s satisfaction.

7. Additional Information

Further to this [general privacy policy] additional policies and procedures governing the collection, storage, use and destruction of personal health information pursuant to the Personal Health Information Act are available.

If you would like more information about our policies, or if you would like to access or correct the Personal Information we have about you in our records, then please contact our Chief Privacy Compliance Officer by email or in writing, as provided below:

ATTENTION: CHIEF PRIVACY COMPLIANCE OFFICER
Tiffany Harder – Database Officer
Alzheimer Society of Manitoba
10-120 Donald Street
Winnipeg, Manitoba
R3C 4G2
tharder@alzheimer.mb.ca

SCHEDULE A: FEDERATION PARTNERS

National

Alzheimer Society of Canada

Provincial Societies

For Yukon and Nunavut please contact the provincial Alzheimer Society office closest to where you live.

Alzheimer Society of Alberta and Northwest Territories

The Alzheimer Society of B.C.

Alzheimer Society of Manitoba

In New Brunswick, the Alzheimer Society

Alzheimer Society of Newfoundland & Labrador

The Alzheimer Society of Nova Scotia

Alzheimer Society of Ontario

Alzheimer Society of Prince Edward Island

Federation of Quebec Alzheimer Societies

Alzheimer Society of Saskatchewan