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PRIVACY & CONFIDENTIALITY: OBLIGATIONS AND PRACTICES

 

  1. Definitions

 

Personal Information: 

Personal information is data about an “identifiable individual”. It is information that on its own or combined with other pieces of data, can identify you as an individual. 

Confidential Information: 

Confidential information is sensitive data or knowledge that is shared with an organization under the condition that it is protected from unauthorized access or disclosure.

 
  1. Legal Obligations (Provincial and Federal)

 

Provincial

The Right to Information and the Protection of Privacy Act applies to pubic bodies but does not apply to Morning Gate Church (MGC).

 

According to the Government of NB website, RTIPPA does not apply to:

 

  • Private sector businesses and organizations, non-profit organizations, and professional groups. These organizations are subject to the federal Personal Information Protection and Electronic Documents Act (PIPEDA). 

 

Federal

The Office of the Privacy Commissioner of Canada states: Non-profit organizations are 

usually not subject to the Personal Information Protection and Electronic Documents Act

 (PIPEDA) because they do not typically engage in commercial activities. 

 

PIPEDA defines commercial activity as:

"…any particular transaction, act or conduct or any regular course of conduct that is of a commercial character, including the selling, bartering or leasing of donor, membership or other fundraising lists."

 

The following activities are not considered commercial and are not subject to PIPEDA:

 

  • collecting membership fees

  • organizing club activities

  • compiling a list of members' names and addresses

  • mailing out newsletters

  • fundraising

 

Because MGC does not engage in commercial activity, it is exempt from PIPEDA. 

  1. Privacy & Confidentiality Practices

 

Morning Gate Church collects only information needed to fulfil the purposes and conduct the activities of the church. 

 

Collection of Information

 

MGC collects personal or confidential information for the following purposes:

  • Communication with members, adherents, or those who provide contact information

  • Ministry personnel/lay employee records

  • Pension and benefits records

  • Elected Board member information

  • Information required for church records

  • Stewardship development and donor information

  • Legal/regulatory requirements

  • Financial and asset information

  • Charitable receipting requirements

  • Benevolent fund recipients’ information for potential T5007 information for CRA

 

MGC is committed to the careful handling of both personal and confidential information. 

 

Guiding Principles

 

MGC is committed to the careful handling of both personal and confidential information. 

 

  • Personal or confidential information collected or obtained is used only for the purposes of the church and is never sold. 

  • Personal or confidential information, not needed for the purposes of the church, is not collected or maintained.

  • Access to sensitive information is controlled. Safeguards are implemented where possible to protect data. 

    • Limited access to software

    • Limited access to computers

    • Limited access to email accounts

    • Blind email distribution lists for church-wide communications

      • Emails between Board, committee or group members do not use blind carbon copy (Bcc) to allow for better communication.

    • Locked, fireproof, waterproof safe for select record storage

    • Safety Deposit box for select record storage

  • Accuracy of data is maintained.

  • Data is retained for only as long as needed for church purposes, or as required by law. 

  • Each person has the right to obtain their own personal information that is in the possession or control of MGC. MGC has the right to refuse a request for access to personal information if:

  • the information would likely reveal personal information about another individual

  • the information is protected by solicitor-client privilege

  • granting access would reveal confidential financial information

  • doing so could reasonably be expected to threaten the safety or security of another individual

  • the information was generated in the course of a formal dispute resolution process

  • the information was collected in the course of a disciplinary process within MGC that is ongoing as of the date of the request​

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  1. Contact Information

 

For more information, contact Morning Gate Church, Inc.

Email: mgc@bellaliant.com

Phone: (506) 458-0093

Address:  Morning Gate Church, 74 Morning Gate Drive, Fredericton, NB E3B 0G6 

Website: morninggatechurch.ca

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