Accountability

Donor Bill of Rights

Philanthropy is based on voluntary action for the common good. It is a tradition of giving and sharing that is primary to the quality of life. To ensure that philanthropy merits the respect and trust of the general public, and that donors and prospective donors can have full confidence in the nonprofit organizations and causes they are asked to support, we declare that all donors have these rights to:

  • Be informed of the organization’s mission, of the way the organization intends to use donated resources, and of its capacity to use donations effectively for their intended purposes.
  • Be informed of the identity of those serving on the organization’s governing board, and to expect the board to exercise prudent judgment in its stewardship responsibilities.
  • Have access to the organization’s most recent financial statements.
  • Be assured their gifts will be used for the purposes for which they were given.
  • Receive appropriate acknowledgement and recognition.
  • Be assured that information about their donation is handled with respect and with confidentiality to the extent provided by law.
  • Expect that all relationships with individuals representing organizations of interest to the donor will be professional in nature.
  • Be informed whether those seeking donations are volunteers, employees of the organization, or hired solicitors.
  • Feel free to ask questions when making a donation and receive prompt, truthful, and forthright answers.
  • The Donor Bill of Rights was created by the American Association of Fundraising Counsel (AAFRC), Association for Healthcare Philanthropy (AHP), the Association of Fundraising Professionals (AFP), and the Council for Advancement and Support of Education (CASE). It has been endorsed by numerous organizations.

Adopted by the St. Thomas Elgin General Hospital Foundation as a founding principal.

Imagine Canada
Canadian Association of Gift Planners
Association of Fundraising Professionals
Association for Healthcare Philanthropy

Privacy & Confidentiality

Click the link to view our Privacy Policy.

Complaints Policy

Click the link to view our Complaints Policy.

Privacy and Confidentiality

Policy Title: Privacy Policy
Reviewed By: STEGH Foundation Governance & Nominating Committee
Approved By: STEGH Foundation Board of Directors
Original Effective Date: January 2022
Revision Date: May 2024
Next Scheduled Review: April 2027

Mission Statement

To partner with the community to support our Hospital in the delivery of an excellent patient care experience.

Vision Statement

To inspire a lifetime of philanthropic support for our Hospital.

Values

Integrity, Leadership, Community, Results

Policy Statement

The St. Thomas Elgin General Hospital Foundation (the “Foundation”) raises funds to support the activities of the St. Thomas Elgin General Hospital (the “Hospital”). In the course of its fundraising activities, the Foundation collects, uses, and discloses personal information of its donors. The Foundation is also responsible for the personal information of other stakeholders, such as employees and volunteers. This policy (“Policy”) reflects the Foundation’s commitment to protecting the privacy of its donors and other stakeholders and to safeguarding the personal information within its custody and control.

In keeping with this commitment, the Foundation’s personal information practices adhere to the Principles set out in the Canadian Standards Association’s “Model Code for the Protection of Personal Information”, which also forms the basis for most privacy legislation in Canada. The Foundation complies with the privacy guidelines of the Canadian Centre for Philanthropy and the Donor Bill of Rights developed by the American Association of Fund Raising Counsel, the Association for Healthcare Philanthropy, Council for Advancement and Support of Education and the Association of Fund Raising Professionals.

Although they are separate core entities, because the Foundation’s principle activity is to raise funds for the Hospital, the two organizations have adopted similar policies with respect to their fair personal information practices.

This policy applies to all personal information collected, used, disclosed, and retained by the Foundation. This Policy will be reviewed regularly to ensure ongoing compliance with applicable legislation, with established guidelines for charitable organizations and with evolving best practices.

Definitions

For the purposes of this Policy:

Agent” means a person authorized to act for or on behalf of the Foundation in exercising powers or performing duties with respect to personal information including without limitation, employees, managers, directors, casual and contract workers, volunteers, students, physicians, consultants, and vendors.

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.

Procedure

1.0 Principle 1-Accountability for Personal Information

1.1 The Foundation is responsible for personal information within its custody or control.

1.2 All Foundation employees and volunteers are accountable for the personal information they come into contact with in the course of their duties for the Foundation. All Foundation employees and volunteers are required to sign Foundation Confidentiality Agreements.

1.3 The Foundation’s President & CEO is the designated Chief Privacy Officer who is accountable for the Foundation’s compliance with the principles set out in this policy.The President & CEO may be reached as follows:

Email: privacy@steghfoundation.ca
Phone: 519-631-2030 x2264
Mail: St. Thomas Elgin General Hospital Foundation
189 Elm Street, St Thomas, ON
N5R 5C4

1.4 The Foundation has implemented additional policies and procedures to give effect to or supplement this Policy. These policies may be accessed by contacting the President & CEO at privacy@steghfoundation.ca

1.5 The Foundation is responsible for personal information that is has transferred to a third party for processing. The Foundation will use contractual or other means, such as confidentiality agreements and data sharing agreements, to provide a comparable level of protection while the personal information is being processed by a third party.

1.6 Donor Relations

1.6.1 The Foundation shall conduct its fundraising and reporting activities in compliance with Foundation policies and procedures as well as applicable laws and Imagine Canada Standards.

1.6.2 Every effort shall be made to honour a donor or prospective donor’s request to:

  • Limit the frequency of contacts;
  • Not be contacted by telephone or other technology;
  • Not receive printed materials concerning the Foundation;
  • Discontinue contact where it is indicated they are unwanted or a nuisance;
  • Remain anonymous and;
  • Comply with the Donor Bill of Rights

1.6.3 The Foundation does not rent, exchange, sell, or otherwise share its donor list.

1.6.4 The Foundation prepares and issues Official Income Tax receipts for monetary gifts and gifts-in-kind in compliance with all regulatory and policy requirements.

2.0 Principle 2-Identifying Purposes for the Collection, Use and Disclosure of Personal Information

2.1 The Foundation identifies the purposes for which it collects personal information at or before the time that the personal information is collected. The Foundation identifies the primary purposes for which it collects personal information through this Policy, as follows:

2.1.1 Fundraising to meet the needs of the Hospital;

2.1.2 Providing donors and supporters with stewardship and recognition information;

2.1.3 Providing donors and potential supporters with information about the Hospital and Foundation initiatives; and

2.1.4 Meeting legal and regulatory requirements.

2.2 If the Foundation collects personal information for a purpose not identified above or if the Foundation intends to use personal information for a purpose other than the one for which it was originally collected, it will advise the individual of the new purpose and will obtain consent of the individual prior to using the information for the new purpose.

2.3 Foundation employees or volunteers collecting personal information will be able to explain to individuals the purposes for which the information is being collected.

3.0 Principle 3-Consent for the Collection, Use, and Disclosure of Personal Information

3.1 The foundation collects, uses, and discloses personal information only with the consent of the individual. The knowledge and consent of an individual are required for the collection, use, or discloser of personal information about that individual, except where appropriate.

3.2 Consent may be expressed orally (such as in telephone calls) or in writing (such as in pledge forms), including electronically (such as through the Foundations website), or may be implied. The Foundation may obtain names and mailing addresses of Hospital patients from the Hospital on the basis of implied consent as permitted under the Personal Health Information Protection Act, 2004 and by the written agreement between the Foundation and the Hospital that was entered into in accordance with the requirements of the Freedom of Information and Protection of Privacy Act.

3.3 Individuals may limit or opt out of future contact by the Foundation by contacting the President &CEO at privacy@steghfoundation.ca. The Foundation will honor such requests.

3.4 Individuals may withdraw their consent to the collection, use, or discloser of their personal information at any time, subject to legal or contractual restrictions and reasonable notice, by contacting the President & CEO at privacy@steghfoundation.ca. Withdrawals of consent cannot be retroactive, The Foundation will inform the individual of the implications of any such withdrawal.

4.0 Principle 4-Limiting Collection of Personal Information

4.1 The Foundation will only collect personal information for the purposes identified by the Foundation. Personal information will be collected by fair and lawful means.

4.2 The Foundation will not collect personal information indiscriminately. The Foundation does not collect, use or disclose more personal information than is reasonably necessary to meet its purposes.

5.0 Principle 5-Limiting the Use, Disclosure, and Retention of Personal Information

5.1 The Foundation will not use or disclose personal information for purposes other than those for which it was collected, except. with the consent of the individual or as required by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes.

5.2 Safeguards are also in place to ensure that the personal information is not disclosed or shared more widely than is necessary to achieve the purpose for which it was collected and to protect personal information against loss or theft, as well as unauthorized access, collection, disclosure, copying, use, or modification.

5.3 If using personal informing for a new purpose, the Foundation will document this purpose and seek consent for such use and/or disclosure in accordance with section 2.2 of this Policy.

5.4 The Foundation does not sell, rent, or trade mailing lists or other personal information.

6.0 Principle 6-Ensuring Accuracy of Personal Information

6.1 The Foundation will keep personal information as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used and/or disclosed.

6.2 The Foundation will not routinely update personal information, unless such a process is necessary to fulfill the purposes for which the personal information was collected.

7.0 Principle 7-Safeguarding Personal Information

7.1 The Foundation protects personal information with security safeguards appropriate to the sensitivity of the personal information.

7.2 The security safeguards will protect personal information against loss or theft, as well as unauthorized access, collection, disclosure, copying, use, or modification. The Foundation will protect personal information regardless of the format in which itis held.

7.3 The nature of the safeguards will vary depending on the sensitivity of the personal information that has been collected, the amount, distribution, and format of the personal information, and the method of storage. A higher level of protection will safeguard more sensitive personal information. The methods of protection will include:

7.3.1 Physical measures, for example, locked filing cabinets and restricted access to offices;

7.3.2 Organizational measures, for example, limiting access on a “need-to-know” basis; and

7.3.3 Technological measures, for example, the use of passwords, encryption and audits as well as strong data security software and systems to protect the personal information in the Foundation’s custody from hackers and malicious intruders.

7.4 The Foundation will make its employees and agents aware of the importance of maintaining the privacy and security of personal information. As a condition of employment, appointment, or agency all Foundation employees, volunteers, and other agents must sign the applicable Code of Conduct Policy Declaration in accordance with section 1.2 of this Policy.

7.5 Personal information will be securely destroyed so that all reconstruction is not reasonably possible to prevent unauthorized parties from gaining access to the personal information.

8.0 Principle 8-Openness About Personal Information Policies and Practices

8.1 The Foundationwill make readily available to individualsspecific information about its policiesand practices relationto the management of personal information.

8.2 The Foundation will be open about its policies and practices with respect to the management of personal information. The Foundation makes its privacy policy and practices available by posting them on its website. Individuals may also acquire information about the Foundation’s privacy policy and practices by contacting the President & CEO at:

Email: privacy@steghfoundation.ca
Phone: 519-631-2030 x2264
Mail: St. Thomas Elgin General Hospital Foundation
189 ElmStreet, St Thomas, ON
N5R 5C4

9.0 Principle 9-Individual Access to Own Personal Information

9.1 Upon request, the Foundation will inform an individual ofthe existence, use, and disclosure of his or her personal information and the individual will be given access to that personal information. An individual will be able to challenge the accuracy and completeness of the personal information and have it amended as appropriate if there is an error or omission.

9.2 Requests may be made by contacting the President & CEO at:

Email: privacy@steghfoundation.ca
Phone: 519-631-2030 x2264
Mail: St. Thomas Elgin General Hospital Foundation
189 ElmStreet, St Thomas, ON
N5R 5C4

9.3 The Foundation will respond to an individual’s request within a reasonable time and at a reasonable cost to the individual. Fees will be established on a cost recovery basis and individuals will be notified of any feed when their request is made. The requested personal information will be provided or made available in a form that is generally understandable. For example, if the Foundation uses abbreviations or codes to record information, an explanation will be provided.

9.4 When an individual demonstrates to the satisfaction of the Foundation that their personal information is not correct or complete for it its purposes, the Foundation will amend the information as required, in accordance with professional standards of practice.

9.5 When a challenge is not resolved to the satisfaction of the individual, the Foundation will record the substance of the unresolved challenge. When appropriate, the existence of the unresolved challenge will be transmitted to third parties to whom the original personal information was disclosed.

10.0 Principle 10-Challenging Compliance with theFoundation’s Privacy Policy and Practices

10.1 Any concerns about the Foundation’s privacy practices should be addressed to the President & CEO at:

Email: privacy@steghfoundation.ca
Phone: 519-631-2030 x2264
Mail: St. Thomas Elgin General Hospital Foundation
189 ElmStreet, St Thomas, ON
N5R 5C4

10.2 The Foundation will investigate all complaints. If a complaint is found to be justified, the Foundation will take appropriate measures, including, if necessary, amending its privacy policy and practices.

11.0 Website Consent

11.1 The Foundation’s website allows individuals to make a donation to the Foundation or to purchase goods or services from the Foundation. Personalinformation provided by an individualto the Foundation through the website will be treated in accordance with this Policy as set out in section 3.2 of this Policy.

11.2 Credit card information provided by an individual over the Foundation’s website is protected using industry-standard SSL (Secure Socket Layer) technology. This software is routinely updated to maximize protection of such information.

12.0 Compliance with Canada’s Anti-Spam Legislation

The Foundation complies with the requirements of Canada’s Anti-Spam Legislation. The Foundation has the same infrastructure, cybersecurity requirements and follows the same policies and procedures as St. Thomas Elgin General Hospital (STEGH). The Foundation does not send commercial electronic messages (“CEMs”) to any person unless it has express or implied consent from the recipient, the CEM includes identification and contact information for the sender and the CEM has an unsubscribe mechanism.

Review

The Privacy Policy will be reviewed every three years.  

In the interim, this policy may be revised or rescinded if the Board deems necessary.

If this policy is revised or rescinded, all secondary documents will be reviewed as soon as reasonably possible in order to ensure they comply with the revised Policy or, in turn, are rescinded.

References

Donor Bill of Rights

Complaints Policy

POLICY STATEMENT

 The St. Thomas Elgin General Hospital Foundation (the ‘Foundation’) is committed to providing a high level of service to Hospital and Foundation employees and volunteers, contractors, subcontractors, agents, vendors, donors, members of the public, and other community partners in the act of delivering on our Mission, Vision and Values.

This policy is intended to ensure that issues raised by any of these stakeholders are responded to promptly, transparently and fairly.

DEFINITIONS

Complaint: an expression of dissatisfaction about the service, actions, or lack of action by the Foundation as an organization, as a staff member, or as a volunteer acting on behalf of the Foundation.

Examples of complaints include but are not limited to:

· A perceived failure to do something agreed upon;

· A failure to observe policy or procedures;

· An error made by a staff member and/or volunteer;

· Unfair or discourteous actions/statements by a staff member and/or volunteer;

· Unwanted solicitations.

PROCEDURE

Guiding Principles

It is in the best interests of all parties that complaints are dealt with promptly and resolved as quickly as possible.

A review of complaints should be fair, impartial and respectful to all parties.

The process for registering complaints will be documented on the website.

Complainants are advised of their options to address their complaint with a more senior staff person, if they are dissatisfied with their treatment or outcome.

Complainants are provided clear and understandable reasons for decisions relating to complaints.

Updates are provided to complainants during review processes.

Complaints are used to assist in improving services, policies and procedures.

All complaints received are confidential.

Complaint Receipt and Handling

All complaints received by the Foundation Office shall be addressed by the appropriate staff person. In all cases, the Executive Director shall be advised.

Resolving the Complaint

Every effort should be made to resolve complaints in a timely fashion. When receiving a verbal complaint, staff should listen, seek to understand the complaint, and attempt to resolve it immediately.

Complaints received in writing (e-mail and letter) shall be acknowledged within 24 hours, if not sooner, and staff should attempt to resolve the matter within ten (10) business days or as soon as possible.

Where a complaint cannot be easily resolved by front-line staff, it will be brought to the attention of the Executive Director. If the Executive Director cannot resolve the complaint, it will be brought forward to the Executive Committee and, if required, the Foundation’s Board. If the complaint is about the Executive Director, it will be handled by the Chair of the Executive Committee. Complainants will be kept informed of the status of their complaint. Every attempt will be made to resolve escalated complaints within an additional ten (10) business days so that all complaints are resolved within a month of having been received.

In the case of a complaint made about a Hospital program, service, staff member or volunteer, the complaint will be re-directed to the Patient Experience Office.

Documenting the Complaint

It is necessary to keep a record of any complaint that involves a dispute over money as well as any complaint that cannot be resolved immediately (on the same day it is received).

The Executive Director will maintain a tracking record of all complaints, which will include the date the complaint was received, a description of the complaint, who handled the complaint, what was done to resolve the complaint, and a description and date of the resolution.

An annual record of complaints received including number, type and disposition will be provided to the Foundation’s Board.

REVIEW

The Complaints Policy will be reviewed every three years.

In the interim, the Complaints Policy may be revised or rescinded if the Board deems necessary.

If this Policy is revised or rescinded, all secondary documents will be reviewed as soon as reasonably possible in order to ensure they comply with the revised policy or, in turn, are rescinded.

References

Code of Conduct – Staff & Volunteer Policy
Fundraising Practices Policy
Gift Acceptance Policy
Imagine Canada. Standards Program for Canada’s Charities & Nonprofits
Volunteer Canada. The Canadian Code for Volunteer Involvement.
Volunteer Engagement Policy
Workplace Harassment Prevention and Resolution Policy

STEGH Foundation does not engage Board Members for products or services in which the Board Member is an owner, partner or senior manager and would receive payment.

Please contact the Foundation office if you'd like to view more Foundation policies.

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