Privacy Policy
Sustain Ontario is a project of TIDES CANADA INITIATIVES SOCIETY (TCI). The TCI support team provides the Sustain Ontario project with support in all areas of operations including finances, grant administration, human resources, and risk management. The TCI Board has full governing, legal, and fiduciary responsibility for Sustain Ontario.
The Scope and Application of Sustain Ontario’s Privacy Policy for Members’ Information
The Policy applies to the personal information of Sustain Ontario members. The Policy applies to the management of personal information in any form whether oral, electronic, or written. The Policy sets out the following:
- The information that Sustain Ontario collects about Sustain Ontario’s members;
- How Sustain Ontario uses the information that Sustain Ontario collects;
- How Sustain Ontario protects member’s financial information; and
- How to contact Sustain Ontario if you have any questions or concerns.
Sustain Ontario’s Privacy Policy for Members’ Information
This statement discloses the privacy practices and policies for Sustain Ontario’s use of the personal information that members provide to Sustain Ontario. Our privacy policy answers some of your most frequently asked questions, and lets you know how we use and protect the information that you entrust to us. If you have any questions about Sustain Ontario’s practices and policies then please e-mail us at members@sustainontario.ca.
Sustain Ontario respects your personal privacy. We believe ensuring the security of your personal information is an important part of our job, and we strive to protect any personal information you may provide us. If we ask you to provide any personal information, we will tell you the purposes for which we intend to use that information. Your personal information is not lent or sold to anyone for any purpose.
How does Sustain Ontario use members’ information?
The main reasons that Sustain Ontario collects information about member organizations are:
- To publicize member organizations’ information on Sustain Ontario’s website in the member directory;
- Information is publicized to facilitate members contacting other members.
- Information is publicized to indicate members’ support of sustain Ontario.
- Information is publicized to allow the public to connect with members.
- To contact members to facilitate members participation in Sustain Ontario;
- To disclose the composition of Sustain Ontario’s membership base to government and other organizations when advocating for change in the food system; and
- To process membership dues with credit or debit card processing companies.
What information is collected and disclosed in Sustain Ontario’s Online Member Directory?
The following self-identified information is collected and disclosed publicly:
- Main Contact for your organization:
- Full name
- Title
- Work E-mail
- Work Phone number
- Areas of expertise
- Food Systems Focus
- Geographical region that your organization works in or represents
- Date that your organization was established
- Mission statement
- Your organization’s connection with food or farming
- Organization’s e-mail address
- Website URL
- Organization’s phone number
- Organization’s fax number
- Social Media Links for Facebook, Twitter and Linked In
- Organization’s address
- Including roadway, city, province, country and postal code.
What information is collected and used to contact members?
The following information is collected and used to contact members:
- Organization’s e-mail address
- Organization’s phone number
- Organization’s fax number
- Organization’s address
- Including roadway, city, province, country and postal code.
- Main Contact for your organization:
- Full name
- Title
- Work E-mail
- Work Phone number
Why is it necessary for Sustain Ontario to collect, use and disclose members’ information for the member directory and to contact members?
Sustain Ontario requires members who are stakeholders in the food system to support and participate in Sustain Ontario to transform Ontario’s food system. Publicly supporting Sustain Ontario, and collaborating with other members are members’ responsibilities. Members’ responsibilities are reflected in the following pledge that members must make:
“As a member of Sustain Ontario, we commit to working collaboratively with diverse groups from across the province to help create a food system that is healthy, ecological, equitable and financially viable.”
Public disclosure of members’ information and receiving updates from Sustain Ontario is necessary for members to fully support and participate in Sustain Ontario and for Sustain Ontario to provide the benefits of membership.
When can members’ request that their information is not disclosed in the member directory?
Members are not able to opt out of Sustain Ontario’s collection, use and disclosure of information about their organization unless that information is closely linked to an individual person. If a member believes that their organization’s information is closely linked to an individual person, and would not like information about their organization to be disclosed in the member directory then the member can modify the fields below via their directory listing through their online Membee-managed profile or the member can send a request to members@sustainontario.ca. All other information collected about members for the purpose of public disclosure will still be disclosed in the member directory.
- Main Contact for your organization:
- Full name
- Title
- Work E-mail
- Work Phone number
- Organization’s address
- Including roadway, city, province, country and postal code.
What information is collected, aggregated and disclosed about Sustain Ontario’s membership base when Sustain Ontario advocates for change in the food system?
- Areas of expertise
- Food Systems Focus
- Geographical region that your organization works in or represents
- Date that your organization was established.
- Number of full-time and part-time employees
Why is it necessary for Sustain Ontario to disclose Sustain Ontario’s membership base when advocating for change in the food system?
When Sustain Ontario engages with food system stakeholders the stakeholders must know who Sustain Ontario represents for Sustain Ontario to effectively advocate for change in Ontario’s food system. A diverse and large membership base induces food system stakeholders to recognize that Sustain Ontario’s initiatives are holistic and comprehensive. Sustain Ontario’s disclosure of the diversity and size of Sustain Ontario’s membership base strengthens Sustain Ontario’s ability to advocate for food system change on behalf of Sustain Ontario’s members.
How can members ensure that the information held by Sustain Ontario is accurate?
Membership information previously provided to Sustain Ontario can be updated by members after logging into Membee on the Member Profile page (https://sustainontario.com/members/member-profile) or members can update their information by e-mail at members@sustainontario.ca, or by phone at 647.348.0235.
What information is collected and used to process membership dues?
Sustain Ontario does not collect any credit or debit card numbers from members when membership dues are paid. Transactions are processed by PayPal. Sustain Ontario is a project of Tides Canada. Tides Canada, and not Sustain Ontario, has a contractual relationship with PayPal. Please read Tides Canada’s privacy policy to learn what information Tides Canada collects, uses and discloses when transactions are processed through PayPal. Members can access Tides Canada’s privacy policy here: Tides Canada’s Privacy Policy.
Please read PayPal’s privacy policy to learn why, and how PayPal collects, uses and discloses your personal information when processing membership due transactions. Members can access PayPal’s privacy policy here: PayPal Privacy Policy.
How can members find out what information is held about them by Sustain Ontario?
At your request, we will provide you with a statement explaining the extent to which we hold personal information about you, and we will explain how that information has been used or disclosed by us. This page will be updated if information about the collection, use and disclosure of your personal data changes.
Can this policy change and how will members be notified of changes to this policy?
Sustain Ontario may update this privacy policy in the future. We will notify you about material changes to this privacy policy by placing a prominent notice on our website. As well, a history of those changes will be noted here, beginning with changes published after February 25, 2014.
Any changes in our use of personal information contrary to Members’ initial consent will be posted, in advance, on our website with instructions regarding consent to any changes. Notices may also be posted and sent by email. All changes will remain in compliance with federal and provincial privacy legislation.
What should members do if they have any questions or concerns?
Should you have questions or concerns about Sustain Ontario’s collection, use and disclosure of information then please e-mail members@sustainontario.ca. If you have any concerns that cannot be addressed by Sustain Ontario then you may contact the Office of the Information and Privacy Commissioner of Ontario:
Office of the Information and Privacy Commissioner of Ontario
2 Bloor Street East, Suite 1400
Toronto, Ontario M4W 1A8
Phone: (416) 326-3333
Toll-free: 1 (800) 387-0073 (free within Ontario)
Email: info@ipc.on.ca
Web Site: http://www.ipc.on.ca/
Background: Sustain Ontario’s Privacy Policy for Member’s Information and the Personal Information Protection and Electronic Documents Act
For the most part, the Personal Information Protection and Electronic Documents Act (PIPEDA) probably does not apply to the majority of information collected, used and disclosed by Sustain Ontario about Sustain Ontario’s member organizations. PIPEDA probably does not apply to the majority of information collected by Sustain Ontario because (a) the collecting of membership fees is not considered a commercial activity; and (b) because an organization’s information typically cannot be considered personal information.
Section 2(1) of PIPEDA states that commercial activity means “any particular transaction, act or conduct or any regular course of conduct that is of commercial character, including the selling, bartering or leasing of donor, membership or other fundraising lists.”
Section 4(1)(1) of PIPEDA provides that PIPEDA “applies to every organization in respect of personal information that the organization collects, uses or discloses in the course of commercial activities”.
The Privacy Commissioner’s Fact Sheet states: “Collecting membership fees, organizing club activities, compiling a list of member’s names and addresses, and mailing out newsletters are not considered commercial activities”. The Privacy Commissioner’s Fact Sheet is not legally binding, but the Privacy Commissioner’s statement informs the meaning of a commercial activity under PIPEDA. Given the Privacy Commissioner’s interpretation, Sustain Ontario’s collection of membership fees and compiling member’s contact information is unlikely to be deemed a commercial activity.
Section 2(1) of PIPEDA states that personal information “means information about an identifiable individual, but does not include the name, title or business address or telephone number of an employee of an organization”.
The Privacy Commissioner stated:
“The word “individual” means a natural person, so it follows that it does not include legal persons such as corporations, partnerships or associations. There may be circumstances where information relating to an entity such as a sole proprietorship is so closely linked to an individual person, that the information can be said to be about that individual, but for the most part “personal information” must be about an identifiable individual and not merely associated with the individual, by name for example.”
Again, the Privacy Commissioner’s statement is not legally binding, but the Privacy Commissioner’s statement informs the meaning of personal information under PIPEDA. Given the Privacy Commissioner’s interpretation, member organization’s information collected, used, and disclosed by Sustain Ontario is unlikely to be considered personal information unless the organization is so closely linked to an individual that the organization’s information can be said to be about the individual.
Therefore, PIPEDA would not generally apply to the information collected, used and disclosed by Sustain Ontario about Sustain Ontario’s members. However, Sustain Ontario has chosen to abide by the principles and framework of PIPEDA in Sustain Ontario’s collection, use and disclosure of Sustain Ontario’s member’s information.