Dated: January 16, 2008
2. Personal Information
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.
3. Personal Information at LFO
LFO has relationships with a wide range of lawyers and grant recipients. In doing so, we often collect and use personal information. As well, LFO sends to individuals information concerning developments regarding our various activities.
4. Collecting Personal Information
We collect personal information fairly and in accordance with the law. Generally, we collect personal information directly from individuals to whom it relates.
Sometimes we may obtain information about individuals from other sources including, without limitation, the Law Society of Upper Canada and its licensees, any person interacting with Foundation grantees, other members of the legal profession, financial institutions, information in grant applications, and consumer–reporting agencies (see “Credit Bureaus” below).
In most cases, if we collect, use, or disclose personal information, we will obtain consent from the individual to whom it relates. Sometimes we will ask for consent in writing, but in some cases, we may accept verbal consent. Sometimes consent may be implied through conduct with us or the nature of an individual’s relationship with us. Should consent be withdrawn, that may impact on our activities.
6. Use of Personal Information
We use personal information to receive interest on licensees’ mixed trust accounts, to administer our information databases, to build and to maintain our expertise and knowledge, and to include individuals in our information distribution and marketing activities. We also use personal information to facilitate the making of grants. If an individual no longer wishes to receive information about developments in our various activities, he or she can ask us not to send any further material.
7. Disclosure of Personal Information
LFO does not disclose personal information to third parties (except to the Law Society of Upper Canada) to enable them to market their products and services.
Under certain circumstances LFO may disclose personal information.
Some examples are:
- when the relevant individual has consented to the disclosure;
- when we are required by law to do so, or required by a warrant, a subpoena, or rules of court to do so;
- when either the interest collection or the grant–making activities in which we engage require us to disclose personal information to third parties, an individual’s consent will be implied, unless he or she tells us otherwise;
- where it is necessary to collect interest from a licensee’s mixed trust account;
- where the disclosure is to a successor to all or a part of LFO’s activities;
- if we engage a third party to provide administrative services to us (like computer back–up services, archival file storage, or insurance) and the third party is bound by obligations regarding privacy which are consistent with this Policy; or
- if we retain other professionals or firms in the course of our activities and the professionals or firms are each bound by obligations regarding privacy which are consistent with this Policy;
8. Updating Information
Since we use personal information to engage in our activities, it is important that the information be accurate and up–to–date. If during the course of your relationship with LFO, any of your personal information changes, we ask that you please inform us so that we can make any necessary changes. We may also periodically inquire whether particular individual’s personal information is accurate and up–to–date.
9. Securing Personal Information
LFO takes precautions to ensure that personal information is kept safe from loss, unauthorized access, modification or disclosure. Among the steps taken to protect personal information are:
- premises security;
- confidentiality policies;
- deploying technological safeguards like security software and firewalls to prevent unauthorized computer access or “hacking”; and internal password and security policies.
E–mail is not an entirely secure medium, and appropriate precautions should be taken when contacting us to send personal or confidential information.
11. Credit Bureaus
To help us to try to prevent fraud, and to check the identity of individuals and in order to assess applications, on occasion we may request information about individuals or organizations from the files of consumer–reporting agencies.
12. Web Site
Our website contains links to other sites, which are not governed by this Policy.
On our website, like most other commercial websites, we may monitor traffic patterns, site usage and related site information in order to optimise our web service. We may provide aggregated information to third parties, but these statistics do not include any identifiable personal information.
Any questions regarding personal information should be directed to Ayumi Bailly, Director, Policy and Programs, by e–mail to email@example.com, or by phone to 647.288.8072.