Privacy Policy

This Privacy Policy was last updated May 25, 2018.

The following is the privacy policy of the Canadian Centre for Child Protection Inc. (“C3P”).

C3P is a not-for-profit, charitable organization dedicated to the personal safety of all children. The goal of C3P is to reduce child victimization by providing programs and services to the Canadian public. These programs and services include publicly accessible websites; a variety of public awareness activities; the creation, production, and distribution of printed books, training programs and curriculums; educational, professional, and related services and training; and miscellaneous other activities aimed at reducing the incidence of missing and sexually exploited children.

In the course of providing our programs and services, C3P may collect, use, and disclose personal information. The following policy is intended to provide information about why and how we do so.

Federal privacy legislation in Canada, namely the Personal Information Protection and Electronic Documents Act (PIPEDA), applies to personal information that is collected, used, and disclosed in the course of commercial activities. With the exception of the collection, use and disclosure of information for the purpose of processing donations, we do not perform commercial activities; nor operate for commercial purposes; and C3P does not consider the majority of its collection, use, and disclosure of personal information to be a commercial activity. The Centre nonetheless believes that maintaining the privacy of personal information is of the utmost importance and accordingly it adheres to the spirit of PIPEDA in its operation of this Website.

This Privacy Policy describes how personal information obtained by C3P is collected, used, and disclosed by it. This Policy applies to users of our programs and services, visitors to our websites, and donors, and it reflects the spirit of PIPEDA. We encourage you to read this Privacy Policy to gain a better understanding of how your personal information will be treated by our organization.

Definition of Personal Information:

Personal information is any identifiable information about an individual, including: name, e-mail address, mailing address, and telephone number. Personal information does not include aggregated information that cannot be associated with a specific individual.

Privacy Policy Applicable to the Canadian Centre for Child Protection Inc.

We respect your privacy. We developed this Privacy Policy in order to ensure those who deal with us are confident that their personal information will be handled in a reasonable manner. We feel it is important for you to understand what information we collect, why we collect it, how we will use and disclose it, and how you can contact us with privacy-related questions. Whether you are visiting the Website to obtain access to resources and information, to use it to access one of our other websites, or to make a donation, we are committed to respecting your privacy and personal information.

Certain websites operated by C3P, such as Cybertip.ca, MissingKids.ca, and NeedHelpNow.ca, have posted a specific privacy policy to address issues unique to the website and/or the program it represents. Where there is a conflict between a specific policy posted on a website operated by C3P and this general policy, the specific policy will govern to the extent necessary to resolve the conflict.

Our 10 Privacy Principles

In order to observe the spirit of PIPEDA, C3P has adopted the 10 Privacy Principles contained within the Canadian Standards Association Model Code for the Protection of Personal Information. A summary of the principles is set out below.

1. Our responsibility to protect your personal information

   The Canadian Centre for Child Protection Inc. is responsible for personal information under its control, and as such has designated an individual who is accountable for compliance with the following principles.

   Note: See principle 10 for contact information.

2. Our obligation to identify the purposes for collecting personal information

   C3P will identify the purposes for which personal information is collected at or before the time of collection. In general terms, we collect personal information to consider, process, and respond to: requests for information, assistance, and resources, as well as general and specific inquiries; to perform research activities related to existing programs and services; to accept, process, and respond to reports and tips related to children or the protection of children; to accept and process donations; to provide a positive experience to website users and others using our programs and services; to understand website user requirements; and to meet legal and regulatory requirements.

3. The requirement for knowledge and consent

   The individual’s knowledge and consent are required for the collection, use, or disclosure of personal information, except where inappropriate. In determining the appropriate form of consent, C3P shall take into account the sensitivity of the information and the reasonable expectation of the individual.

   Note: The following statement applies to principles 3 and 5:

   In certain circumstances, personal information can be collected, used, or disclosed without the knowledge and consent of the individual. For example C3P may collect, use or disclose personal information if:

   1. it is clearly in the interests of the individual, and consent cannot be obtained in a timely way, such as when the individual is a minor, seriously ill, or mentally incapacitated; or
   2. it is reasonable to expect that seeking the consent of the individual might defeat the purpose of collecting the information, such as in the investigation of a breach of an agreement or a contravention of federal or provincial law;

   C3P may also use or disclose personal information without knowledge or consent in the case of an emergency where the life, health, or security of an individual is threatened.

   C3P may disclose personal information without knowledge or consent to a lawyer representing C3P, to comply with a subpoena, warrant, or other court order, or as may be otherwise required or permitted by law.

4. Limiting information collection

   The collection of personal information will be limited to that which is necessary for the purposes identified by the Canadian Centre for Child Protection Inc. Information will be collected by fair and lawful means.

5. Limiting Use, Disclosure, and Retention of your personal information

   Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual, to comply with a government request, to protect the operations of C3P, to protect children, or as required or permitted by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes. Only those employees of C3P who require access to personal information for work-related reasons, or whose duties reasonably so require, are granted access to personal information.

   Note: See the note to principle 3.

6. Accuracy of your personal information

   Personal information will be as accurate, complete, and up-to-date as necessary for the purposes for which it is to be used.

7. Our responsibility to safeguard your personal information

   The Canadian Centre for Child Protection Inc. has security safeguards in place designed to protect personal information against loss, theft, unauthorized access, disclosure, use, or modification. Such safeguarding measures may include but are not limited to alarm systems, locked cabinets, computer passwords, firewalls, and encryption.

8. Our obligation to be open about our Privacy Policy and practices

   If additional specific information about our policies and practices of personal information management are required, such information will be provided to individuals upon receiving a written request.

9. Your right to access your personal information

   Upon request, an individual will be informed of the existence and use of his or her personal information, and will be given access to that information. An individual will be able to challenge the accuracy and completeness of their information and have it amended accordingly. In order to safeguard personal information, access requests must be in writing, and reasonable steps to verify the identity of the individual making the request will be taken before any personal information will be released.

10. Your right to challenge the compliance of our Privacy Policy

    If for any reason, you have questions or concerns about this Privacy Policy, please contact our Privacy Officer by mailing a letter outlining your concerns to:

    Privacy Officer
    Canadian Centre for Child Protection Inc.
    615 Academy Road, Winnipeg, Manitoba R3N 0E7

    You may also submit your question by contacting us through the Contact Us page accessible from https://protectchildren.ca/en/privacy-policy/privacy-contact/.

General Data Protection Regulation (GDPR) Acknowledgment (for Europeans only)

The Canadian Centre for Child Protection Inc. is a registered Canadian charity that operates numerous programs intended for the Canadian public, including Cybertip.ca, Canada's national tipline to report the online sexual exploitation of children. The Cybertip.ca program operates within Canada, and is geared to a Canadian audience. It accepts reports regarding potential online child sexual abuse or exploitation from the Canadian public, assess if such reports pertain to activity that is illegal and Canada and if so, forwards the reports to the entity or entities with jurisdiction to take action, which often means police — see the full Cybertip.ca privacy policy for details.

The vast majority of reports to Cybertip.ca pertain to online child sexual abuse material (CSAM), which is illegal to access, possess, produce, distribute, and make available in Canada. C3P does not know the identities of the individuals depicted in CSAM, and does not know the country within which such individual(s) may reside. C3P does not offer services to residents of Europe, either through the Cybertip.ca program or otherwise, but acknowledges that a European may be depicted in CSAM assessed by Cybertip.ca, that Europeans may from time to time visit the websites of C3P, and that European hotlines and law enforcement may receive information from the operation of Cybertip.ca. Accordingly, to the extent any information processed through the Cybertip.ca program may be considered personal information about an individual in Europe:

• The purpose for collecting and processing such information and sharing it with law enforcement and international hotlines when needed is to reduce and prevent the online sexual exploitation of children and reduce the public availability of CSAM, activities that C3P believes are not only in the interest of vulnerable and abused children but also for the purpose of legitimate interests pursued by C3P and in the public interest.
• The information processed includes CSAM and related information such as hash values, information that may be included by a reporting person in a report submitted to Cybertip.ca and information generated as a result of processing such report.

Technical and security safeguards are set out in the Cybertip.ca privacy policy, as are retention periods. If you are a person in Europe and you wish to exercise rights granted to you under the GDPR, please contact the privacy officer for the Canadian Centre for Child Protection, as directed in the privacy policy for Cybertip.ca. All requests will be responded to promptly to the extent permissible under Canadian law.

C3P reserves the right to adjust this statement at any time and all adjustments will be posted here.

You may contact C3P if you have a question or complaint by addressing your inquiry to the Data Protection Officer of C3P at 615 Academy Road, Winnipeg, Manitoba, Canada R3N 0E7, or you may complete the contact form, which is accessible within the privacy policy of either C3P or Cybertip.ca.