A. Types of Information Collected
Canadian Mennonite Publishing Service (CMPS) potentially collects, updates and stores the following types of information. Not all types of information are collected for each subscriber or donor.
- name, mailing address, church membership or affiliation, telephone and e-mail contact details, and circulation information for current and former magazine subscribers
- name, mailing address, telephone and e-mail contact details, payment method and donation history information for current and past donors
- name, mailing address, telephone and e-mail contact details for those submitting information, articles, photographs or artwork to the magazine for possible publication
- contact information for those that send in correspondence or are our suppliers, advertisers or others with business relationships with CMPS
B. How Information Is Collected
CMPS collects and updates subscriber information either directly from subscribers or, for those receiving subscriptions through a church body, from the church with which they are associated. Donation and submitter information is obtained voluntarily and directly from donors or submitters.
C. How Information Is Used
CMPS uses subscriber information to deliver magazine subscriptions to subscribers by postal mail or electronic mail, as well as correspond about matters relating to their subscription (such as welcome, renewal or cancellation letters and correspondence regarding subscription payments). CMPS provides current subscriber lists and contact information for church list subscribers to their respective congregations for list updates, including subscription additions, updates and cancellations. This is typically done yearly. CMPS staff and board members use subscriber and donor information to send information about the magazine and to request donations; to send receipts and donation confirmations; and to communicate regarding donations, including payment processing and to express our thanks. Donation requests go to both former donors and current subscribers who are not donors. CMPS uses article or artwork submitter information to correspond about their submission for publication and to pay for the use of published material.
D. Information Access by Third-Parties
Unless otherwise provided in this policy, CMPS-held information is only accessed by CMPS staff and board members. Anyone can access, correct errors in or ask that CMPS remove information about themselves. CMPS will not provide members of the public contact information about someone they have read about or who has had something published in the magazine without getting that person’s permission first. CMPS will also provide current subscriber mailing list information to third-parties under the following conditions: CMPS’s mailing and publishing business partners (such as our printer or mailing agency) are provided this information under terms that they use it only for CMPS-authorized purposes and not retain it afterwards. CMPS will provide author contact information to other publications or web sites seeking reprint rights unless the author has requested otherwise.
E. Limited Use and Retention
Subscriber and donors will not have their information used other than described in this document, except with the consent of the individual or as required by law. If a subscriber directly cancels their subscription or indicates they do not wish any further contact from the magazine, they will receive no further contact from Canadian Mennonite after we send them a confirmation of their request. Personal information will be retained only so long as there is a reason related to their subscription type to keep this information.
- Individual personal subscribers will have their personally identifiable information (name and address) removed six months after their cancellation confirmation message has been sent.
- If cancelling subscribers were subscribed through a group- or church-sponsored subscription plan, their personally identifiable information will be kept for 18 months to ensure this information is included in upcoming subscription reports to their subscription plan administrator, and then will be removed.
- If a subscriber does not cancel their subscription but is unreachable for 18 months, their personally identifiable information will be removed after that time as well.
In all cases, personally identifiable information will be kept if it needs to be retained by law for the duration specified in law (for example, our financial records, including donation records, must be kept for the time required by Canada Revenue Agency regulations).
F. Privacy Compliance
CMPS is committed to the adhering to the principles established by the Personal Information Protection and Electronic Documents Act (PIPEDA) in the collection, use, disclosure and storage of personal information. A summary of the ten principles established by PIPEDA is attached to this document as Appendix A.
G. Privacy Officer
If an individual has concerns about the collection, use, disclosure or storage of personal information by CMPS, he or she may contact the Editor/Publisher, who is the designated privacy officer for CMPS. Last reviewed and approved by Canadian Mennonite Publishing Service Board in March 2009
APPENDIX A: PIPEDA PRINCIPLES
Principle 1 - Accountability: An organization is responsible for personal information under its control and shall designate an individual or individuals who are accountable for the organization's compliance with the following principles. Principle 2 - Identifying Purposes: The purposes for which personal information is collected shall be identified by the organization at or before the time information is collected. Principle 3 - Consent: The knowledge and consent of the individual are required for the collection, use, or disclosure of personal information, except where inappropriate. Principle 4 - Limiting Collection: The collection of personal information shall be limited to that which is necessary for the purposes identified by the organization. Information shall be collected by fair and lawful means. Principle 5 - Limiting Use, Disclosure, and Retention: Personal information shall not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual or as required by law. Personal information shall be retained only as long as necessary for the fulfilment of those purposes. Principle 6 - Accuracy: Personal information shall be as accurate, complete, and up-to-date as is necessary for the purposes for which it is to be used. Principle 7 - Safeguards: Personal information shall be protected by security safeguards appropriate to the sensitivity of the information. Principle 8 - Openness: An organization shall make readily available to individuals specific information about its policies and practices relating to the management of personal information. Principle 9 - Individual Access: Upon request, an individual shall be informed of the existence, use, and disclosure of his or her personal information and shall be given access to that information. An individual shall be able to challenge the accuracy and completeness of the information and have it amended as appropriate. Principle 10 - Challenging Compliance: An individual shall be able to address a challenge concerning compliance with the above principles to the designated individual or individuals accountable for the organization's compliance.
STORIES AND ARTICLES PUBLISHED ONLINE
Canadian Mennonite generally does not delete what it publishes online—what is known as "unpublishing." Basing our policy on one drafted by the Toronto Star (http://bit.ly/cm-pub-unpub), "Canadian Mennonite does not unpublish content from our websites or archives, except in some 'rare circumstances.' Those 'rare circumstances' are generally legal reasons and always demand consultation with CM's editor, managing editor, web editor and lawyer. Our unpublishing policy is rooted in the view that the website—our digital archive of what's been published—is a matter of public record and that it is unethical to make content simply disappear because someone does not want to see an article or photo in which he/she is named turn up in a Google search."