Privacy of personal information is an important principle to the First Nations Housing Professionals Association (FNHPA). We are committed to collecting, using and disclosing personal information responsibly and only to the extent necessary for the appropriate provision of the products and services we provide to our members in our role as a not-for-profit organization. We also try to be open and transparent as to how we handle personal information. The following describes our privacy policies.
1. What is personal information?
Personal information is information about an identifiable individual, including that which relates to his/her personal characteristics (e.g. gender, age, income, home address or phone number, ethnic background, family status), his/her health (e.g. health history, health conditions, health services received by them), or his/her activities or views (e.g. religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is not to be confused with business information (e.g. an individual’s business address and telephone number), which is not protected by PIPEDA, the Personal Information Protection and Electronic Documents Act, an act of the Federal government.
2. Who we are
In existence since 2018, the FNHPA is a voluntary, not-for profit industry association, representing First Nation housing professional and others that support FNHPA’s purpose. FNHPA’s purpose is to: expand housing capacity for First Nations in Canada by providing leadership to support housing professionals with services such as developing, promoting and delivering quality standards, practices, research, certification, education services, and networking.
In order to achieve this purpose, we utilize the services of the association staff, as well as a number of volunteers (who are FNHPA members), consultants and organizations that may, in the course of their duties, have limited access to the personal information we hold. We restrict their access to personal information as much as is reasonably possible. We also have their assurance that they comply with appropriate privacy principles.
3. We collect personal information: Primary Purposes
Like all industry not-for-profits, we collect, use and sometimes disclose personal information in order to serve our members. At no time do we rent, sell, barter, exchange or distribute our membership list to any third party for commercial purposes.
For our members, the primary purpose we collect and maintain personal information is to ensure our members qualify for membership and that, once established as members in good standing, we can provide general membership services, standards and exclusive membership benefits and that we can communicate appropriately with them. Examples of personal information we collect for this purpose include:
- contact information, email address (if available)
- organizational information
- work information
- member number (assigned by FNHPA)
For members of the general public and potential employers, we respond to enquiries for names of members and indicate whether or not they are members.
Beyond that, the FNHPA may transmit or disclose personal information, where appropriate, to association volunteers who are also members of the FNHPA (Board members, Committee members, staff), primarily for the purposes of networking, standards and service promotion and delivery.
4. Membership History
The FNHPA maintains records on members and former members, in order to respond to questions related to products or services provided during their membership years. We retain our non-member information for seven years after the last contact as these records are helpful should a non-member choose to rejoin the organization, after which it is permanently destroyed in order to reduce the risk of accidental or inadvertent disclosure.
5. We collect personal information related to our secondary to our primary purposes
Like most organizations, we also collect, use and disclose information for purposes related to or secondary to our primary purposes.
Invoicing & Payment –The FNHPA invoices members for annual dues. In addition, the FNHPA collects fees from members for services acquired.
Personal Information Collected (that is not already collected as part of the primary purpose):
- Payment details: cash / personal or business cheque or credit card / debit card account number and authorization
- Names, event choices and dietary preferences of guests registering to attend events with FNHPA members
Member Research –From time to time, third parties may be provided with membership information in order to conduct surveys, focus groups or polls, the results of which are used to assist in the strategic, tactical or operational activities of the organization. In such cases, members are notified in advance and any personal information collected is reported back to the FNHPA and its members in aggregate, in order to remain anonymous and confidential. Third party research firms, under contract to the FNHPA, comply with privacy and confidentiality principles.
Cookies –The FNHPA website may use “cookies” that identify you as a return visitor. A cookie is a piece of data that a website can send to your browser, which may then store the cookie on your hard drive. So, when you come back to visit FNHPA’s website again, information can be tailored to suit your individual preferences. The goal is to save you time and provide you with a more meaningful visit and to measure website activity such as number of hits per page and usage patterns. Web Browsers will allow you to disable cookie collection if you wish, or inform you when a cookie is being stored on your hard drive.
Issues of Ethics & Discipline –As a requirement of membership, FNHPA members agree to be guided by a published Code of Ethics. In the event we receive a complaint, an Ethics and Discipline Committee will investigate. In the course of such an investigation, personal information may be collected and disclosed to the Board of Directors or others in order that appropriate disciplinary action can be taken.
Quality Control & Risk Management –From time to time the FNHPA may review membership files for the purposes of ensuring we provide high quality services, including assessing the performance of our staff and volunteers. In addition, external consultants (auditors, lawyers, association management consultants, etc.) may, on our behalf, conduct audits or performance improvement reviews, including reviewing membership files and interviewing staff and volunteers. External consultants working under contract to the FNHPA must adhere to FNHPA’s privacy and confidentiality policies.
External Regulation –Various government agencies (Canada Revenue Agency, Information & Privacy Commissioner, Human Rights Commission, Ontario, government funders, etc.) have the authority to review our files and interview our staff as part of their mandates. External regulators have their own strict privacy obligations.
6. You can look at your information
With only a few exceptions, FNHPA members and former members have the right to see what personal information we hold. We can help you identify what records we might have about you. We will also try to help you understand any information you do not understand (short forms, technical language, etc.). We will need to confirm your identity, if we do not know you, before providing you with this access. We reserve the right to charge a nominal fee for such requests.
We may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days, if at all possible, and explain the reasons.
If you believe there is a mistake in the personal information we maintain in our files, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation to support your request. Where we agree that we have made a mistake, we will make the correction and notify anyone to whom we have sent this information. If we do not agree that we have made a mistake, we will still agree to include in our records a brief statement from you on the point and we will forward that statement to anyone else who received the earlier information.
Do you have any questions or concerns? Do you wish to make a formal complaint about our privacy practices? You may do so in writing to our Privacy Officer. They will acknowledge receipt of your complaint; ensure that it is investigated promptly and that you are provided with a response in writing.
First Nations Housing Professional Association
Board Approved November 15, 2018