The purpose of this policy is to govern SoulStream’s collection, use and disclosure of personal information in a manner that recognizes both the right of individuals to protect their personal information and the need of SoulStream to collect, use or disclose personal information for purposes toward fulfilment of its objectives as a not-for-profit organization.
SoulStream Initiatives respects the privacy of the personal information of its independent contractors, students, donors, partners, and other stakeholders. SoulStream is committed to protecting the privacy of personal information entrusted to them. In line with that commitment, SoulStream seeks to be transparent and accountable with respect to the collection, use, disclosure and security of personal information.
This policy sets out the principles that SoulStream Initiatives applies with respect to the collection, use, disclosure and protection of personal information.
This policy applies to personal information of SoulStream’s employees, independent contractors, students, donors, partners and other stakeholders as well as applicants for admission as students and continuing education participants or contracted agencies.
SoulStream’s Governance Board has designated its Executive Director and Administrator to take overall responsibility for the protection of personal information and compliance with this policy.
SoulStream Initiatives shall implement policies and procedures to:
- Protect personal information.
- Receive and respond to complaints and inquiries.
If a comment is left on SoulStream’s website, the option is given to save name, email address and website in cookies. This is for the individual’s convenience, freeing a need to fill in the details again when leaving another comment. These cookies will last for one year.
Purposes for Collection
SoulStream shall identify and communicate orally or in writing the purposes for which personal information is being collected at or before the time of collection. SoulStream shall not use or disclose for any new purpose any personal information without first identifying and documenting the purpose and obtaining the written consent of the individual concerned. The main purposes for which SoulStream collects personal information are as follows:
SoulStream’s contact form collects an individual’s first name and last name and email address for the purpose of correspondence. SoulStream will only use this information to respond to an individual’s specific request.
Employees and Independent Contractors
Personal information of employees and independent contractors is collected to fulfill the following purposes:
- Maintain administrative and financial records in accordance with provincial and federal regulations.
- Maintain personnel files in accordance with approved SoulStream policies.
- Communicate, via email, telephone or personal interview, details regarding special activities, events and planning.
- Comply with legal and regulatory requirements.
Personal information of initiative participants is collected to fulfill the following purposes:
- Determine eligibility for admission to Living from the Heart and Art of Spiritual Direction and workshops.
- Provide educational services.
- Process financial transactions and applications for financial aid.
- Transfer information upon graduation to inquiring institutions.
- Provide accurate information to a third party when the student has requested a reference.
- Comply with legal and regulatory requirements.
- When applying for one of SoulStream’s courses or workshops, personal information is collected for the purpose of correspondence. Personal information may include: first name and last name, address, phone numbers, email address, personal and educational background details. This information will only be used to respond to and process the application to the specific course or workshop.
- People who act as references for student applicants provide name, email, phone number, and information regarding their relationship to the applicant.
Alumni / Partners
Personal information of alumni and partners is collected to fulfill the following purposes:
- Facilitate communication: mailing/e-mail/telephone/face-to-face contact for the objective of relating SoulStream’s activities and news.
- Establish and maintain responsible relations with alumni and partners and to provide ongoing service.
- Understand alumni and partner needs and preferences.
- Develop, enhance, advise and provide products and services.
- Comply with legal and regulatory requirements.
Personal information of donors is collected to fulfill the following purposes:
- Facilitate communication through email contact for the objective of relating SoulStream’s activities and to facilitate fundraising activities and news.
- For administration and maintenance of donation information and to ensure compliance with legal and regulatory requirements.
The knowledge and consent of individuals, expressed or implied, are required for the collection, use and disclosure of personal information. Consent will not be obtained through fraudulent means or by deceptive methods, and clear communication will be employed to fairly and reasonably draw the individual’s attention to the issue of consent.
An individual’s expressed consent is communicated to SoulStream either personally or through an authorized representative. As appropriate, individual expressed consent to the collection, use and disclosure of personal information in exclusive conditions will be sought. In other circumstances, SoulStream will seek implied consent from individuals in situations where it is more fitting to seek consent through “opt-out” opportunities presented through direct mail publications, telephone, e-mail or other communication methods. Where such mechanisms are not employed by an individual, SoulStream shall be entitled to assume that the individual has consented.
Withdrawal of Consent
Any individual may withdraw his or her consent to the collection, use or disclosure at any time, subject to legal or contractual restrictions and reasonable notice. SoulStream shall comply with these requests and inform the individual of the implications and restrictions of such withdrawal of consent.
As prescribed by legislation, SoulStream may lawfully collect personal information without the knowledge or consent of the individual only under certain circumstances. Some examples are:
- When collection of the personal information is clearly in the interest of the individual and consent cannot be obtained in a timely way.
- When collection and use of personal information is required in the case of an emergency that threatens the life, health or security of an individual.
- When collection of the personal information with the knowledge or consent of the individual would compromise the availability of the accuracy of the information and the collection is reasonable for purposes of an investigation or a proceeding.
- When the information is already publicly available.
- When the information is collected from another organization that collected it with the consent of the individual and the information is collected solely for the purposes for which it was previously collected and to assist that organization.
Collection of personal information shall be limited to that which is necessary for the purposes identified by SoulStream. The collection of personal information shall primarily be obtained from the individual concerned with his or her consent, either expressed or implied, through fair and lawful means.
Means of Collection
Personal information may be collected in many ways including, but not limited to:
- Personal communications between the individual and SoulStream.
- Publicly available information.
- Responses to mailings or other media.
- Communications from authorized representatives or individuals.
- Responses from SoulStream sponsored, or co-sponsored, events or activities.
Use, Disclosure and Retention
SoulStream shall not use or disclose personal information for purposes other than that for which the information was collected, except with the consent of the individual or as required or permitted by law. Personal information shall be retained only as long as is necessary for the fulfillment of those purposes. Personal information that is no longer required for its identified purposes or for legal or business requirements shall be destroyed or made anonymous.
Administration and independent contractors are responsible for ensuring that student information is kept securely and retained and disposed of according to SoulStream’s approved policies and procedures.
Assignments are the property of the participant who prepared them. Participants are responsible for the retention of assignments that have been returned to them. Assignments may be retained by SoulStream only so long as there is operational need for them. Assignments will be confidentially erased from administration and independent contractors’ files and electronic storage one year after course completion.
SoulStream shall not sell, rent or loan the personal information of its independent contractors, students, donors, partners and partnered relationships to third parties. Except as stated below, personal information is not disclosed to any third party even those whose purpose could be construed to be compatible with that of SoulStream Initiatives. In disclosing personal information to third parties, SoulStream shall make every reasonable effort to ensure that the organizations to which the information is disclosed use that information only for the purposes for which it was disclosed.
The data we collect will be processed anonymously and “Data sharing” is disabled.
In addition to Google Analytics, an individual’s IP address may be tracked for analytics purposes through SoulStream’s web hosting company, Siteground, whose servers are based in Iowa, USA. Siteground takes security seriously. See this article and this GDPR blog post.
If an individual leaves a comment, the comment and its metadata are retained indefinitely. This allows SoulStream to recognize and approve any follow-up comments automatically instead of holding them in a moderation queue.
For users that register on SoulStream’s website (if any), the personal information provided in their user profile is stored. All users can see, edit or delete their personal information at any time (except they cannot change their username). Website administrators can also see and edit that information.
Personal information of an individual will not be disclosed to a third party unless consent has been obtained:
Students of SoulStream Initiatives
The SoulStream Administrator distributes to facilitators and their interns, class lists which shall include contact information of students registered for classes.
Officials and official Agencies
Personal information concerning individuals may be disclosed when it is legally required to do so (e.g. information required by subpoena or court order).
Visitor comments may be checked through an automated spam detection service.
SoulStream uses Microsoft OneDrive to store website backups, which include database archives. Backup files are saved for a maximum of five years.
SoulStream shall make reasonable efforts to ensure that all personal information collected is accurate and complete, and shall also make reasonable efforts to keep the personal information up-to-date. It is the responsibility of the individual to whom the information relates to notify SoulStream of any changes or corrections to that information. Inaccurate information shall be corrected upon request made by the individual to whom the information relates. Supporting legal documentary evidence may be requested to substantiate the request.
SoulStream shall ensure the security of all personal information that is retained. Security arrangements will be employed to protect personal information against loss or theft, as well as against unauthorized access, disclosure, copying, use, modification or disposal. Personal information shall be protected regardless of the format in which it is held. The nature of the safeguards will vary depending on the sensitivity of the personal information that has been collected, the amounts, distribution, and format of the information, and the method of storage. More sensitive personal information will be safeguarded at a higher level of protection.
Methods of Protection
- Physical: restricted access to offices, security systems with individual password protection.
- Organizational: disclosure of personal information within SoulStream shall be limited to those whose job responsibilities require access to such information.
- Technological: software security on LAN and individual computers is ensured through passwords and restrictive access.
- All personal data entered on SoulStream’s website contact form or in blog comments are stored in a secure database. Personal information from website forms and course applications shall be retained only as long as is necessary for the fulfillment of those purposes. Deletion request may be made at any time.
- SoulStream monitors the security of its servers and will act immediately if any irregularities are observed. If SoulStream’s website gets hacked and potentially data is compromised, SoulStream will inform all affected individuals via email as soon as possible.
Faculty and staff are regularly advised of privacy issues and their role in ensuring the protection of personal information.
Third Party Disclosure
SoulStream may receive data from websites such as Google Analytics and social media sites that track online activity.
Destruction of Personal Information
SoulStream Initiatives shall ensure that care and attention is paid to the disposal or destruction of personal information to prevent unauthorized parties from gaining access to the information.
SoulStream shall make available:
- The means of gaining information to personal information held by SoulStream.
- A description of the type of personal information retained by SoulStream and its use.
Communication tools that will be employed to highlight the above shall include, but are not limited to:
- SoulStream website.
- SoulStream Administration.
Upon request in writing, SoulStream shall inform an individual of the existence, use and disclosure of his or her personal information and the individual shall be given access to that information, except where the law requires or permits SoulStream to deny access. The individual must provide sufficient information to permit SoulStream, with a reasonable effort, to provide an account of the existence, use and disclosure of personal information. This information provided will only be used to respond to the request for access made by the individual. SoulStream shall comply with the request within sixty days upon receipt of a request.
SoulStream may lawfully deny access by an individual to his or her personal information where:
- The information is protected by solicitor/client privilege.
- Disclosure of personal information results in the disclosure of the personal information of another individual.
Links to Other Web Sites
SoulStream’s website is not directed to persons under 16. If a parent or guardian becomes aware that his or her child has provided SoulStream with personal information without consent, he or she should contact us. SoulStream does not knowingly collect personal information from children under 16. If SoulStream becomes aware that a child under 16 has provided it with personal information, SoulStream will delete such information from its files.
Notification of Privacy Statement Changes
Compliance and Complaints
All complaints will be investigated. If the Administrator determines a complaint is justified, SoulStream will take appropriate measures, including, if necessary, amending its policies and procedures. The complainant shall be notified of the outcome of the investigation regarding his or her complaint.
If the Administrator is unable to address the complainant’s concerns, the issue shall be referred to the Executive Director.
35535 Mckee Rd
Abbotsford, BC V3G 3E4
Phone: (604) 854-1214