EU Safety Information
Publisher: Daraja Press
PO BOX 541 Wakefield, QC J0X 0C2, Canada
[email protected]
EU Authorized GPSR Representative: Easy Access System Europe
Mustamäe tee 50, 10621 Tallinn, Estonia
[email protected]
For EU product safety concerns, please contact us at [email protected].
Foreword
This Privacy Policy governs the management and protection of confidential information within Daraja Press in accordance with Quebec legislation, including the Act respecting the protection of personal information in the private sector (Law 25).
Daraja Press is committed to respecting and protecting your privacy. We take the security and confidentiality of your personal information seriously. The purpose of this policy is to explain how we collect, use, store, and protect your personal data, and to outline your rights regarding that information.
This policy applies to directors, donors, staff members, volunteers, clients, partners, contractors, and any other individuals working with or present within Daraja Press operations.
The objectives of this policy are to:
- Ensure respect for individuals’ privacy and the security of personal information held by Daraja Press;
- Establish guidelines for the exchange of information inside and outside the organization.
If you have questions or concerns regarding this policy or our handling of personal information, please contact us using the information provided at the end of this policy.
1. Organizational Mission & Values
Daraja Press is a non-profit national organization and independent media outlet producing critical publications to help map a just and viable future. Our mission is to create public-interest publications through investigations, analysis, and video content addressing social justice issues, including racism, inequality, colonialism, and climate breakdown.
2. Definitions
Discretion
The ability to keep confidences and private information obtained outside the workplace confidential in order to preserve trust and respect.
Confidentiality
The act of limiting or prohibiting access to private information obtained in the course of one’s duties.
Personal Information
Any information that can identify an individual, including phone numbers, email addresses, dates of birth, employment history, and similar information.
Non-Personal Information
Information that cannot be used to personally identify an individual, such as aggregate demographic data or anonymized participation statistics.
3. Obligations of Confidentiality
Daraja Press collects both Personal Information and Non-Personal Information. Personal Information is the primary focus of this policy.
Daraja Press does not sell, trade, rent, or otherwise share your Personal Information with third parties for marketing purposes without your consent.
We may share Personal Information with financial institutions, payroll providers, and payment processing services strictly for operational purposes such as processing donations, payments, and honorariums.
We use Non-Personal Information to improve our programming, communications, and organizational operations.
Daraja Press agrees to:
- Ensure the security and confidentiality of personal information;
- Implement measures to protect confidential information;
- Address complaints regarding confidentiality;
- Ensure the confidential treatment of complaints;
- Collect only information that is necessary and relevant;
- Apply this policy in accordance with Daraja Press values and applicable laws.
All employees, volunteers, contractors, and representatives who obtain confidential information in the course of their duties are required to maintain confidentiality, including after their relationship with Daraja Press ends.
4. Obligations of Discretion
Anyone associated with Daraja Press must act with discretion regarding information unrelated to their duties.
Accordingly, individuals must:
- Respect the privacy of others;
- Avoid disclosing confidential information;
- Protect sensitive information shared with them;
- Act in accordance with the organization’s values.
5. Collection and Use of Personal Information
Daraja Press collects and uses personal information in compliance with Law 25.
Personal information is collected only for legitimate, clearly identified purposes and is not processed in ways incompatible with those purposes.
We generally use personal information to:
- Communicate with you;
- Process donations and payments;
- Administer employment or volunteer relationships;
- Respond to inquiries;
- Send newsletters and organizational updates.
We may disclose personal information where required by law or where reasonably necessary to:
- Comply with legal obligations;
- Investigate fraud or security concerns;
- Enforce agreements or policies;
- Protect the rights, safety, or property of individuals or the public.
5.1 Types of Personal Information Collected
We may collect:
- Full name;
- Mailing address;
- Email address;
- Phone number;
- Date of birth;
- Social insurance number (for payroll purposes);
- Donation and payment information;
- Website interaction data;
- Comments submitted through our website or email;
- Any other information voluntarily provided to Daraja Press.
5.2 Purpose of Collection and Use
Daraja Press primarily uses collected information to communicate with individuals, including through newsletters and updates.
We use the following third-party payment processors:
Daraja Press does not store payment card details submitted during payment processing.
We also use Google Analytics to collect anonymized website usage data that cannot be traced back to individual users.
6. Management of Personal Information
The individual holding the highest authority within Daraja Press is responsible for ensuring the protection of personal information and may designate a Privacy Officer in writing.
The Privacy Officer is responsible for maintaining a registry of privacy incidents.
Employees and authorized personnel may access personal information only to the extent necessary to perform their duties.
Under Law 25, a privacy incident includes unauthorized access, use, disclosure, loss, or breach of personal information.
7. Conservation and Security of Personal Information
Daraja Press implements reasonable safeguards to protect personal information from unauthorized access, disclosure, alteration, or destruction.
Security measures include:
- Password-protected systems;
- Multi-factor authentication;
- Restricted access to sensitive information.
While we take reasonable steps to protect information, no security system can guarantee absolute protection.
7.1 Information Sharing Outside Daraja Press
Board members, management, employees, and volunteers must not discuss confidential matters with unauthorized individuals.
In exceptional circumstances, information sharing must be limited to the minimum necessary.
7.2 Information Sharing Within Daraja Press
Employees should:
- Discuss confidential information only in secure settings;
- Avoid discussing confidential matters in public or unsecured spaces;
- Ensure telephone or virtual conversations cannot be overheard.
7.3 Storage Practices
Daraja Press does not normally store personal information in physical files.
Personal information may be stored through:
- Secured email systems;
- Password-protected online storage;
- Temporary secure storage devices where operationally necessary.
7.4 Limits of Confidentiality
Daraja Press may disclose personal information without additional consent where permitted or required by law, including to:
- Auditors;
- Service providers;
- Legal counsel;
- Courts or government authorities;
- Other parties authorized under applicable privacy legislation.
7.5 Third-Party Technology Platforms
Daraja Press uses various third-party platforms to conduct operations, including:
These services may store or process information outside Canada and may therefore be subject to foreign laws, including U.S. privacy laws.
8. Retention, Destruction, and Anonymization
Daraja Press destroys or anonymizes personal information once it is no longer required for the purposes for which it was collected, in accordance with Law 25.
9. Access and Correction Rights
Individuals have the right to request access to their personal information held by Daraja Press.
Requests must be submitted in writing, and Daraja Press will respond within 30 days in accordance with Law 25.
Individuals may:
- Request a copy of their personal information;
- Request corrections to inaccurate or incomplete information.
In limited circumstances, access may be restricted where disclosure could compromise the mission, legal obligations, or operations of the organization.
10. Privacy Breaches and Non-Compliance
A privacy breach may occur if a member of Daraja Press:
- Shares personal information with unauthorized individuals;
- Leaves personal information accessible to unauthorized persons;
- Uses personal information for personal benefit;
- Discusses confidential matters externally without authorization.
Any breach of this policy may result in corrective action or sanctions in accordance with applicable laws and organizational policies.
11. Complaints and Recourse
If an individual believes their personal information has been handled inconsistently with this policy or applicable law, they may file a complaint with the Privacy Officer.
Complaint form:
Privacy Complaint Form
Complaints involving the Privacy Officer may be directed to executive management or the Board of Directors.
Privacy incidents presenting a “risk of serious prejudice” under Law 25 may be reported to the Commission d’accès à l’information and affected individuals where required.
12. Contact Information
For questions or concerns regarding this Privacy Policy or Daraja Press’s data practices, please contact:
The Privacy Officer will respond to inquiries within 10 business days.
13. Policy Adoption
This Privacy Policy was adopted on August 27, 2024, following approval by the Board of Directors of Daraja Press.
Daraja Press may update this policy from time to time to reflect legal, operational, or organizational changes.