Daraja Press Privacy Policy

Foreword

This policy deals with the management and protection of information deemed confidential within Daraja Press in accordance with Quebec legislation, notably 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 very seriously. The purpose of this policy is to provide you with clear and transparent information on how we handle your personal data and to explain your rights in this respect.

The policy applies to relations between all persons: directors, donors, staff members, volunteers and clientele, partners as well as all other persons working or present on the various premises of Daraja Press.

The policy has the following objectives:

• to ensure respect for the privacy of individuals and the security of personal information held by Daraja Press;
• to establish guidelines for the exchange of information both inside and outside the organization’s premises.

If you have any questions or concerns about this policy or the way in which we manage your personal information, please contact us using the contact 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 journalism to help map a just, viable future. Our mission is to create public interest journalism by providing investigations, analysis and video content about the key social justice issues of our time, particularly the crises of racism, inequality, colonialism, and climate breakdown.

2 Definitions

For the purposes of this policy, the following terms shall have the respective meanings :

Discretion: The ability to keep confidences and private information obtained outside the workplace secret in order to preserve respect, friendship and trust.

Confidentiality: The act of limiting or prohibiting others from having access to private information obtained in the course of one’s duties.

Personal information: Any type of information that can lead to the identification of a certain person such as phone number, email address, date of birth, employment history, among others. 

Non-personal information: Any information that cannot be used to personally identify you, such as data referring to participation in our events and general demographic information. 

3 Obligations of Confidentiality

Daraja Press collects both Personal Information and Non-Personal Information. Personal Information is the focus of this policy. 

Daraja Press does not sell, trade, rent or otherwise share for marketing purposes your Personal Information with third parties without your consent. We do share Personal Information with banks, third party payroll services or financial processing systems who are performing services for Daraja Press for purposes of processing payments and honorariums. 

In general, we use Non-Personal Information to help us improve our programming and to improve our work. If our information practices change at any time in the future, we will post the policy changes to our website. We suggest that you check periodically if you are concerned about how your information is used. 

Daraja Press Media agrees to: 

• Ensure the security and confidentiality of any personal information obtained 
• Implement measures to protect confidential information 
• Ensure that complaints about confidentiality are addressed 
• Ensure the confidential treatment of complaints 
• Collect only information that is useful or necessary 
• Apply the confidentiality policy with respect to the values of Daraja Press 
• Act with respect and transparency when applying this policy, and act in compliance of the applicable laws.  

All persons within Daraja Press (employees or contractors) who obtain confidential information in the course of their duties are required to respect the confidentiality of such information. An exception is made in certain cases, where it is essential for those involved to be able to exchange certain information for the betterment of our work. In such cases, the persons concerned must also maintain the confidentiality of the information exchanged. This obligation continues even after their relationship with Daraja Press. 

4 Obligations of Discretion 

Any person who, within Daraja Press Media, has exchanges that are not related to the performance of their duties must act with discretion. 

Accordingly, they must: 

• Respect the privacy of others;
• Not divulge confidential information obtained within the organization;
• Guard the sensitive information of those who confide in 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 specific, legitimate and clearly identified purposes, and is not subsequently processed in a manner incompatible with these purposes.

In general, the Personal Information you provide to us is used to help us communicate with you, employ you or process financial forms. For example, we use Personal Information to contact users in response to questions, send relevant information regarding your submission of this information, process payments or communicate about your role if employed by the Organization. 

We may share Personal Information with outside parties if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to meet any applicable legal process or enforceable governmental request; to enforce applicable Terms of Service, including investigation of potential violations; address fraud, security or technical concerns; or to protect against harm to the rights, property, or safety of our members or the public as required or permitted by law. 

5.1. Types of Personal Information Collected 

When you interact with Daraja Press, whether as a donor, a subscriber, an employee, a user of our Website, or otherwise, we may collect various types of personal information in line with our organizational needs. 

This information may include, but is not limited to:

• Contact information: full name, mailing address, email address, phone number. 
• Identifying information: Date of birth, social insurance number (for payroll).
• Financial information: credit card number and other information linked to those transactions (for donations).
• Information on your interactions with Daraja Press: comments on the website, or received by email, website visits. 
• Any other information you choose to share with Daraja Press.  

5.2 Objectives of the collection and usage of personal information  

Daraja Press uses the information that we collect with the objective of communicating with individuals, primarily, but not exclusively, through our newsletters. 

Daraja Press uses Stripe, Paypal and GlobalPayments to process card payments and regular donations. Click here to view the Stripe and here for GlobalPayments privacy policy. Daraja Press does not store the payment card details you provide to make a payment.

Daraja Press uses Google Analytics to collect anonymized data on our website usage. This data is anonymous, meaning that online behavior cannot be traced back to the individual. 

5.3 Internet Cookies 

Daraja Press Media’s website, like most websites, uses Cookies. This section explains their usage and how they can be moderated. 

5.3.1 What are Cookies? 

Data stored in a cookie that is created by the server upon your connection. This data is labeled with an ID unique to your computer. It can be thought of as an internet user’s identification card, which indicates to a website that a user has returned to the site. 

5.3.2 How to moderate your Cookies? 

Each web browser gives users control over their cookies. Please consult aboutcookies.org, section How to manage and delete cookies in the most common browsers which details the process for each browser. 

5.3.3 Why does Daraja Press use Cookies?

Cookies allow Daraja Press to collect non-personal data and statistics about the usage of our website. This enables us to better understand the reach of our work. 

5.4 Links to external websites 

Daraja Press’s website may contain links to other websites that are outside the realm of our operations. By clicking on an external link on our website, you will be redirected there and no longer covered by Daraja Press’s privacy policy. We advise that you review the Privacy Policy of the new website in question. Daraja Press does not assume any responsibility for the privacy policies, practices or content on any third-party website. 

6 Management of Personal Information 

The person occupying the role with the highest authority within Daraja Press, is designated as the person responsible for ensuring the protection of personal information. This person may delegate this responsibility in writing by designating them in the role of Privacy Officer. The way to contact the Privacy Officer is available in the policy, as well as on Daraja Press’s website. The Privacy Officer is responsible for maintaining a registry of privacy incidents. 

The person holding the highest authority at Daraja Press is authorized to access the personal information held by the organization as necessary in the usual course of duty, with the exception of cases of conflict of interest. All other employees are authorized to access any personal information to the extent that it is necessary for the completion of their tasks. 

In accordance with Law 25, a privacy incident includes any unauthorized access, use or disclosure of personal information, as well as any loss or breach of personal information.   

The procedure to seek recourse for any breach of personal information is outlined in section 11 of this policy. 

7 Conservation of personal information

Daraja Press implements security measures designed to protect your information from unauthorized access. Your data is protected by implementing security measures including passwords, and multi-factor authentication for accessing data. However, these measures do not guarantee that your information will not be accessed, disclosed, altered or destroyed by breach of such security measures. By submitting your data, you acknowledge that you understand and agree to assume these risks. We will do our best to minimize any chance of this happening.

7.1 Exchanges of information outside Daraja Press: 

• The Board of Directors, management and employees must not discuss files, persons or decisions specific to Daraja Press, with outsiders or persons not concerned. In an exceptional situation, they must limit exchanges of information to the strict minimum. 

7.2 Exchanges of information within Daraja Press 

• Limit exchanges of information between employees to team meetings or in a secure area (e.g. office with closed door);
• Avoid discussing issues pertaining to confidential information outside of these times. If this is not possible, make sure not to use identifying information, and discuss in a place that ensures confidentiality;
• Ensure that telephone conversations dealing with confidential information are not overheard by others. 

7.3 Security measures to limit access to information 

Daraja Press does not store personal information in hard copies at our office. All personal information is stored virtually. 

• All personal information will be protected by a password 
• Personal information will be stored in the following locations; emails secured by Daraja Press, online storage platforms secured by password, and when necessary, for a short period of time on a USB key (ex: for sustainers who will be sent a gift in the mail, we might print all the labels at the print shop, requiring them to be put on a USB for the duration) 

7.3.1 Office

Daraja Press primarily works in a virtual office, and occasionally uses a physical office. The following applies to both circumstances: 

When others are present a Daraja Press employees must: 

• Lock computer screens at lunchtime or when absent;
• Change password (server, computer, voice mail or other) regularly. 

• Close office doors at lunchtime, at the end of the day, or in case of absence. 
• Lock the main office door on departure. 

7.4 Limits of confidentiality 

Daraja Press will not disclose any personal information to any outside party or to any of its affiliated entities without the person’s knowledge and consent, except to the following persons:

• an auditor related to an audit of Daraja Press 
• an organization or individual providing services to Daraja Press, if the personal information is reasonably necessary for the provision of said services. In such a case, the organization or individual must act in accordance with this Policy, and use such personal information only for the purposes of providing services to Daraja Press.
• a lawyer representing Daraja Press in a matter involving personal information.
• anyone submitting a subpoena, warrant or court order obligation.
• a government institution requesting such information, which submits its request authorization, in connection with the administration of any applicable law.
• in any other circumstance where disclosure is explicitly permitted under applicable privacy laws.

7.4 Limits of technology 

Daraja Press uses the following platforms to conduct our operations; G Suite, Zoom Pro, Slack, Active Campaign and CiviCRM. These platforms are protected by passwords. It is important to note that these are American platforms, and thus follow American laws on privacy protection. Though we do our best to maintain rigorous privacy measures for technology, there is always a risk that personal information could be compromised.  Daraja Press may integrate new software as required to perform our duties in a regular course of operations. 

8 Destruction or anonymization of personal information 

Daraja Press ensures the destruction or anonymization of personal information in accordance with the requirements of Law 25, as soon as the data is no longer required for the purposes for which it was collected.

9 Communicating personal information collected with the concerned person 

An individual has the right to request access to their personal information retained by Daraja Press. Once these information have been requested in writing, Daraja Press will communicate these informations within a delay of 30 days in accordance with provisions of Law 25. 

Accessing your personal information: 

• An individual can request a copy of their personal information to consult the information. 
• An individual has the right to make corrections to the information when they are inexact and incomplete. 

In some circumstances, the organization can legitimately refuse to give the individual access to certain parts of their personal information file if it could compromise the mission and values of the organization. 

9.1 Breach of Confidentiality 

A breach of confidentiality has occurred when a member of Daraja Press carries out one of the following actions: 

• If a member of Daraja Press discusses personal information with external parties.  
• If a member of Daraja Press gives personal information to non-authorised parties. 
• If a member of Daraja Press leaves personal information in a location where non-authorised parties could access it. 
• If a member of Daraja Press accesses personal information for their individual personal gain or interest. 

10 Failure to comply with the obligations of this policy 

Any breach of the obligations set out in this Privacy Policy will be dealt with appropriately in accordance with the remedies and sanctions provided by Law 25.

11 Recourse 

In the event that it is determined that an individual’s personal information has been used in a manner that is inconsistent with this policy or the law, that individual has the right to recourse.

The individual has the right to file a complaint here (https://forms.gle/EquqqNrpiB3erPK26 ) with the Privacy Officer. Should the complaint pertain to the Privacy Officer, the complaint will be sent to the Executive Management, or to the Board of Directors of Daraja Press Media, if the complaint concerns the general management. These complaints will be saved for a period of five years. 

The Privacy Officer will consult with the management and/or the board of directors where appropriate to determine if the incident presents a ‘risk of serious prejudice’, as outlined in article 3.5 of Law 25. Subsequently, they will define measures to reduce the risk of similar future incidents. 

Any breaches of privacy that have been determined as presenting a ‘risk of serious prejudice’ are recorded in the register of privacy incidents. The Privacy Officer will assess, based on the degree of risk of prejudice, to advise the Commission d’accès à l’information and any others potentially impacted by this breach about the incident. 

11 Terms of application 

The management of Daraja Press is responsible for the implementation and application of the privacy policy.

As soon as this policy comes into effect, directors, management, employees and volunteers must commit to complying with the policy.

In the event of non-compliance with the confidentiality policy by management, the Board of Directors must intervene.

If a director, employee or volunteer has disclosed confidential information, the competent authority will impose a sanction in accordance with Daraja Press’s policies, regulations and by-laws. The sanction may range from reprimand to exclusion. 

12 Contacting us 

If you have any questions, concerns or comments regarding this Privacy Policy or our data collection practices, please contact the at at the following address: [email protected].  

The officer responsible for privacy will answer any questions you may have questions about our Privacy Policy within 10 business days.

13 Adoption of the Policy

This policy was adopted on August 27, 2024 following its adoption by the Board of Directors. It can be modified at the opportune time after an effective analysis. Any modification must respect the values and rules of Daraja Press.

Refund policy

Our refund policy can be viewed here: https://darajapress.com/refund_returns