The Canadian Health Food Association ("CHFA”) is a non-profit federally chartered trade association that promotes natural health products, whole foods and organics as the primary source of well-being for all Canadians. Given the nature of our organization and the composition of our membership, we do not normally collect Personal Information in the course of providing our services. However, to the extent that CHFA may collect Personal Information, we have prepared this policy to inform you about our ongoing commitment to ensuring that any Personal Information that may be obtained remains accurate and confidential.
What is personal information?
We consider "Personal Information" to mean any information, recorded in any form, about an identified individual or an individual whose identity may be inferred or determined from such information, other than business contact information (e.g. name, title, business address).
Why CHFA may collect personal information
CHFA may use the Personal Information provided verbally or in writing (including via electronic media) by its members or other third parties in order to:
(a) Offer educational and certification programs on natural products and nutrition and related materials to members and non-members;
(b) Provide an electronic newsletter to members, non-members and consumers;
(c) Provide members and non-members with information about our trade shows (including by means of direct marketing);
(d) Communicate with and determine the needs of our members;
(e) Permit affiliated organizations and preferred suppliers to provide products, services and information to members;
(f) Process credit card and other forms of payment information for products and services provided by CHFA to its members or third parties;
(g) Meet legal and regulatory requirements; and
(h) Such other purposes consistent with these purposes.
The personal information we ask for will depend upon which services you may obtain and may include personal contact information and financial information required to process payment for products and services.
How CHFA collects and uses personal information
CHFA only collects, uses and discloses Personal Information for purposes that would be considered reasonable in the circumstances and only such information as is required for the purposes of providing products, services or information to members and non-members. We use only fair and lawful methods to collect Personal Information. Our use of Personal Information is limited to the purposes described in this Policy and CHFA does not otherwise sell, trade, barter, exchange or disclose for consideration any Personal Information it has obtained.
When CHFA may disclose your personal information
CHFA may disclose your Personal Information to individuals or organizations:
a) Who assist CHFA in informing you about our services;
b) Who are affiliated organizations and preferred suppliers who wish to tell you about their products or services or to inform you about other opportunities; or
c) Who are your advisers or service providers.
CHFA may also transfer your personal information to our third party service providers, for example IT service providers who are involved in maintaining, reviewing and developing our business systems, procedures and infrastructure including testing or upgrading our computer systems, or financial service providers who are involved in the processing of payments for the products or services that we offer to you.
Where CHFA discloses Personal Information to organizations that perform services on its behalf, we will require those service providers to use such information solely for the purposes of providing services to CHFA, its members or the person concerned and to have appropriate safeguards for the protection of that Personal Information. [nb: are any of CHFA’s service providers located outside of Canada? If so, should add the following: “Some organizations that perform services on behalf of CHFA are located in foreign jurisdictions and your Personal Information may be accessible to law enforcement and national security authorities of that jurisdiction. In the event sensitive Personal Information is provided to CHFA, we will not disclose such Personal Information unless it is required in order to provide our services. Where Personal Information may be subject to transfer to another organization in contemplation of a merger, sale of CHFA assets or change of ownership of all or part of CHFA, we will do this only if the parties have entered into an agreement under which the collection, use and disclosure of the information (including any Personal Information) is restricted to those purposes that relate to the transaction, including a determination of whether or not to proceed with the transaction, and is to be used by the parties to carry out and complete the transaction. Please note that there are circumstances where the use and/or disclosure of Personal Information may be justified or permitted or where CHFA is obliged to disclose information without consent. Such circumstances may include:
a) Where required by law or by order or requirement of a court, administrative agency or governmental tribunal;
b) Where CHFA believes, upon reasonable grounds, that it is necessary to protect the rights, privacy, safety or property of an identifiable person or group;
c) Where it is necessary to establish or collect monies owing to CHFA;
d) Where it is necessary to permit CHFA to pursue available remedies or limit any damages that we may sustain; or
e) Where the information is public.
Where obliged or permitted to disclose information without consent, CHFA will not disclose more information than is required.
Unless permitted by law, no Personal Information is collected, without first obtaining the consent of the individual concerned to the collection, use and dissemination of that information. However, we may seek consent to use and disclose Personal Information after it has been collected in those cases where CHFA wishes to use the information for a purpose not identified in this Policy or not previously identified or for which the individual concerned has not previously consented. By providing Personal Information to CHFA you agree and consent that we may collect, use and disclose your Personal Information in accordance with this Policy. In addition, where appropriate, specific authorizations or consents may be obtained from time to time. In most cases and subject to legal and contractual restrictions, you are free to refuse or withdraw your consent at any time upon reasonable, advance notice. It should be noted that in certain circumstances, certain services can only be offered if you provide Personal Information to CHFA. Consequently, if you choose not provide us with any required Personal Information, we may not be able to offer you the services requested. We will inform you of the consequences of the withdrawal of consent.
The accuracy and retention of personal information
CHFA endeavors to ensure that any Personal Information provided and in its possession is as accurate, current and complete as necessary for the purposes for which we use that information. If we become aware that Personal Information is inaccurate, incomplete or out of date, CHFA will revise the Personal Information and, if necessary, use its best efforts to inform third parties which were provided with inaccurate information so that those third parties may also correct their records. We keep your Personal Information only as long as it is required for the reasons it was collected. The length of time we retain information varies, depending on the service and the nature of the information. This period may extend beyond the end of a person’s relationship with us but it will be only for so long as it is necessary for us to have sufficient information to respond to any issues that may arise at a later date. CHFA has in place a Document Retention Policy, which outlines the procedures for the retention and subsequent destruction, deletion, erasure or conversion into an anonymous form of CHFA records including those that contain Personal Information. Currently, the principal places in which CHFA holds Personal Information is in the city of Markham, Ontario and nearby municipalities where off-site storage facilities may be located.
Protection of personal information
CHFA endeavours to maintain appropriate physical, procedural and technical security with respect to its offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure, or modification of Personal Information. This also applies to our disposal or destruction of Personal Information. CHFA further protects Personal Information by restricting access to it to those employees that the management of CHFA has determined need to know that information in order that we may provide our services or information. If any employee of CHFA misuses Personal Information, this will be considered as a serious offence for which disciplinary action may be taken, up to and including termination of employment. If any individual or organization misuses Personal Information - provided for the purpose of providing services to or for CHFA - this will be considered a serious issue for which action may be taken, up to and including termination of any agreement between CHFA and that individual or organization.
Access to your personal information
CHFA permits the reasonable right of access and review of Personal Information held by us about an individual and will endeavor to provide the information in question within a reasonable time, generally no later than 30 days following the request. To guard against fraudulent requests for access, we may require sufficient information to allow us to confirm that the person making the request is authorized to do so before granting access or making corrections. We will provide information from our records in a form that is easy to understand. CHFA reserves the right not to change any Personal Information but will append any alternative text the individual concerned believes to be appropriate. CHFA reserves the right to decline to provide access to Personal Information where the information requested:
a) Would disclose (i) Personal Information, including opinions, about another individual or about a deceased individual; or (ii) trade secrets or other business confidential information that may harm CHFA or the competitive position of a third party;
b) Would interfere with contractual or other negotiations of CHFA or a third party;
c) Is subject to solicitor-client or litigation privilege;
d) Is not readily retrievable and the burden or cost of providing would be disproportionate to the nature or value of the information;
e) Does not exist, is not held, or cannot be found by CHFA;
f) Could reasonably result in (i) serious harm to the treatment or recovery of the individual concerned, (ii) serious emotional harm to the individual concerned or another individual, or (iii) serious bodily harm to another individual;
g) May harm or interfere with law enforcement activities and other investigative or regulatory functions of a body authorized by law to perform such functions; or
h) May be withheld or is requested to be withheld under applicable legislation.
Where information will not or cannot be disclosed, the individual making the request will be provided with the reasons for non-disclosure. CHFA will not respond to repetitious or vexatious requests for access and in making such a determination, we will consider such factors as the frequency with which information is updated, the purpose for which the information is used, and the nature of the information. CHFA will not charge you for verifying or correcting your information, however, to the extent permitted by applicable law, there may be a minimal charge imposed if you need a copy of records.
Our Web server track general information about visitors such as their domain name, time of visit and which pages are being accessed. This information is used internally, only in aggregate form, to better serve visitors by helping us to:
a) Manage our site;
b) Diagnose any technical problems; and
c) Improve the content of our Web site.
Resolving your privacy concerns
In the event of questions about: (i) access to your Personal Information; (ii) our collection, use, management or disclosure of Personal Information; or (iii) this Policy; please contact CHFA’s privacy officer by sending an email to firstname.lastname@example.org or calling 1-800-661-4510 . CHFA will investigate all complaints and if a complaint is justified, we will take all reasonable steps to resolve the issue.