Policies

1. CODE’s Commitment to the Protection of Personal Information

At CODE, we attach a very high value to the trust that our donors place in the organization they have chosen to support. Accordingly, so as not to abuse that trust, we will use our best efforts to limit the collection and use of personal information about our donors and to protect the confidentiality of that information. Generally speaking, “personal information¹” for the purposes of this Policy is information about an identifiable individual. The Policy will be updated periodically to maintain compliance with applicable legislation.

2. The Personal Information that CODE Collects and Maintains about Donors

The information collected about a donor or prospective donor that may, alone or in combination, constitute personal information includes name, home contact information, credit card or bank account information (for the purpose of our collecting a donation), countries, programs or projects an individual wishes to support, language preference, demographic information (such as age and gender) and future communication preferences. The personal information that we maintain about a donor or prospective donor may include any of this information that we have collected about the donor or prospective donor and the amounts and manner in which he or she has contributed or promised to contribute to CODE.

3. The Purposes for which CODE Collects Personal Information about Donors and the Sources of that Information

¹ Section 3 of the Privacy Act defines personal information as any information that identifies an individual. This includes information such as your name, address, IP address, telephone number, birth date, social insurance number, e-mail address and employment information.

CODE collects personal information about donors and prospective donors for the following purposes:

• Conducting and facilitating fundraising,
• Managing our relationship with donors, and
• Meeting any legal or regulatory requirements relating to the activities of CODE.

Any such personal information collected for these purposes, will be collected from the individual to whom it relates but may be collected from a third party with the individual’s knowledge and consent or from a publicly available source of information, such as a telephone directory.

4. The Uses of Personal Information about Donors by CODE

CODE will not use personal information that has been collected for one or more of the purposes described above for any other purpose or purposes without the knowledge or consent of the individual to whom the information relates, except as specifically permitted under any applicable personal information protection legislation.

5. The Disclosure of Personal Information about Donors by CODE

CODE will not disclose any personal information about a donor or prospective donor to anyone outside CODE or any of its affiliated entities without the knowledge or consent of that donor or prospective donor except as follows;

• To an auditor in connection with an audit of CODE conducted by its auditor or by an auditor retained by CODE’s principal funding agency, Global Affairs Canada,
• To an organization or individual providing services to CODE where the personal information is reasonably required in the performance of those services, provided that contractual or other arrangements are made to ensure that any such organization or individual acts in a manner consistent with this Policy and uses such personal information solely for the purpose of providing services to CODE or on its behalf in a manner consistent with CODE’s instructions. Contractual arrangements with organizations or individuals providing services will prohibit forward sharing of personal information,
• To a lawyer who is representing CODE in a matter to which the personal information relates,
• To comply with a subpoena, warrant or requirement under an order or rule of court,
• To a government institution that has made a request for the information, identifying its authority to do so, in connection with the administration of any law of Canada or a province, or
• In any other circumstance where disclosure is specifically required under any applicable personal information protection legislation.

6. The Retention and Destruction of Personal Information about Donors

CODE keeps personal information about donors and prospective donors for as long as required by law or to fulfill the purposes for which it was collected. CODE takes reasonable steps to destroy, delete or erase personal information that is no longer required. Information is retained in secure databases and filing cabinets and technological measures such as passwords and encryption are used.

7. The Security of Personal Information about Donors

CODE maintains adequate physical, procedural and technical security with respect to its offices and information storage facilities to prevent any loss, misuse, unauthorized access, disclosure or modification of personal information about donors or prospective donors. CODE’s employees are made aware of the legal obligations of maintaining the confidentiality of such personal information.

8. Access by Donors to their Personal Information and the Right to Correct that Information

A donor or prospective donor may make a request to CODE in writing for access to any of his or her personal information held by CODE. We will respond with due diligence and within a reasonable time by providing access to that information except in circumstances where we are entitled or required to refuse access under any applicable personal information protection legislation. A donor or prospective donor who believes that any of his or her personal information held by CODE is inaccurate or incomplete may make a request to CODE in writing to amend that information. CODE will make the appropriate amendment unless it is of the reasonable opinion that the information is not inaccurate or incomplete, in which case we will make a notation, in CODE’s records, of

9. Website Usage and Security

The www.code.ngo website is operated by CODE for the benefit of our donors/clients/ contractors and other stakeholders interested in supporting our organization’s vision and mission.

Cookies

CODE uses cookies, small files containing information to track site visits, for purposes of better understanding how its site is used, to make sure information is served correctly and to improve the performance of its site for users. CODE does not use cookies to retain personal information about users and does not sell information about traffic patterns. You can set your browser so that it does not accept cookies but note that doing so may interfere with your ability to use CODE’s website.

Analytics and logs

CODE’s public site servers log every IP address and request and store these logs in files that are available to CODE for analysis. CODE also uses analytics technologies in the browser to record traffic and usage. CODE uses this data in aggregate to analyze trends of interest to the organization.

Email Communication

You have the right to opt-out of email communications at any time by following the unsubscribe directions included in such emails.

On-line Security

CODE uses recognized industry-standard encryption software for all personal information submitted on our web site. Donations made on CODE’s web site are linked to a secure payment service for credit card transactions.

External Links

There are links on the www.code.ngo website that take you to other web sites outside of our service. Any links provided to third party web sites outside of www.code.ngo are provided solely for your convenience. The operation and content of such third-party web sites is beyond CODE’s control, and CODE does not endorse in any manner whatsoever or accept responsibility for the content or other material that may be contained on such web sites.

10. General Responsibility at CODE for Compliance and Accountability with this Policy

The Chief Executive Officer of CODE shall have overall responsibility for our compliance with this Policy and with any applicable personal information protection legislation as it applies to personal information about donors and prospective donors. Any complaints about our handling of such personal information shall be made in writing and directed to the Chief Executive Office of CODE at the address set out below.

11. Effective Date of this Policy and Amendments to the Policy

This Policy is effective as of January 30, 2025. CODE may amend this Policy from time to time and any such amendment shall apply in respect of the collection or generation of personal information about donors or prospective donors from the effective date of the amendment and in respect of personal information about donors or prospective donors then held by CODE. The latest version of this Policy will always be posted on CODE’s web site, the address of which is set out below.

12. Contact Information

Questions, concerns or complaints regarding CODE’s Donor Privacy Policy or practices should be directed to the Chief Executive Officer. Contact details are noted below.

Janice Ciavaglia
CEO
Email: Jciavaglia@code.ngo

Preamble

This Code of Ethics sets out the basic values CODE accepts and promotes in its pursuit of development objectives as stated in its Mission and Vision statements and in the Strategic Goal found in the CODE Strategic Plan.:

Our Mission
To enable people to learn by developing partnerships that provide resources for learning, promote awareness and understanding and encourage self-reliance.

Our Vision
To support a sustainable literate environment in the developing world.

Our Strategic Goal
CODE will be a self-sustaining learning organization recognized domestically and internationally as a leader in building effective and productive partnerships that create the capacity required to enhance the literacy skills of children, youth and adults, especially women and girls, so they can fully realize their personal goals and potential.

General Principles

Human Rights –CODE respects and promotes the human rights and dignity of all people in all of its deliberations, projects, programmes and operations.
Accountability – CODE is accountable to partners, staff, donors and to the Canadian public for our activities in international development and our stewardship of financial and human resources.
Transparency – CODE will communicate freely and accurately with its government funders, partners, private donors and the public.
Fairness – CODE will practice and promote impartiality, equality and justice in all its deliberations, projects, programmes and daily operations.
Sustainability –CODE will take appropriate measures to ensure the financial and human resource sustainability of the organization as well as its effective management and good governance.

CODE will ensure that the following policies are incorporated into its structure, governance, management and operations.

Results-Based Management (RBM)
RBM is integral to CODE’s management philosophy and practice. CODE focuses on results to ensure that it employs management practices that optimize value for money and the prudent use of its human and financial resources. CODE will report on its results in order to inform stakeholders of its development achievements.

Local Languages
To facilitate the literacy aspect of CODE’s mandate, CODE will promote the effective use and production of learning materials in local and national languages.  

Clear Language Communications
CODE recognizes that clear language and literacy go hand-in-hand.  People from diverse backgrounds, in Canada and abroad, should be able to access information about CODE with ease.  CODE is committed to using direct, inclusive and focused language in all print and electronic communications, as well as layout and design principles that respect the needs of readers.

Partnerships
CODE will nurture a literate environment by seeking and /or strengthening partnerships with organizations and institutions that share CODE’s values and ethics and by building the capacity of its overseas partners.

Public Engagement
CODE will promote public awareness and understanding of the organization and development issues both domestically and internationally.

Government Relations
CODE’s approach to government relations is premised on the principles of transparency and ethical practice in all dealings, formal or informal, with public agencies and their officials.  CODE believes in shared accountability in the judicious use of public funds and in sound, well documented and honest representations to government.

Financial Resources
CODE will pursue a broad, diversified and stable financial base and will ensure sound financial oversight and management of all resources.
New Technologies
CODE will actively explore the utilization of a variety of new technological formats in delivering literacy information and support materials adding value to our program in Canada and overseas.

Human Resources
CODE has a Corporate Human Resource Policy designed to ensure that the organization is properly staffed and able to effectively and efficiently carry out its mission.

Ethical Conduct & Good Governance
CODE will conduct itself ethically in all of its affairs and promote good corporate governance practices by its Board and by the Boards of its affiliates and partners.

Gender
CODE supports the development of capacities to achieve equality for girls and boys, women and men through the strengthening of partner organizations and through education programs that achieve equal learning outcomes for all.  Leading by example, CODE supports the development of gender policies and activities designed to advance norms, services, behaviours and attitudes that result in gender equality on its own Board and throughout the organization.  

Development Goal: Literacy Environments
CODE will concentrate resources to deliver programs that will make a difference on literacy in learning communities in which our partners work.

Privacy Policy
We adhere to our Privacy Policy and the protection of personal information.

CODE will:
•    Affirm the importance partnerships play in the promotion of literacy;
•    Identify organizations in Canada and overseas that share our mission and vision, with a view to establishing new partnerships;
•    Ensure trust, openness, transparency and accessibility in our relationships with our partners;
•    Accept responsibility to meet financial commitments;
•    Work to support the full needs of our partners to ensure that these relationships are mutually beneficial;
•    Make a long-term commitment to institutional development and capacity building within our partner organizations;
•    Endorse participation of appropriate partners in CODE’s strategic planning; and,
•    Recognize that all partnerships are unique.

Principles
CODE is committed to entering into partnerships with organizations in Canada and overseas that:
•    Share our mission and vision;
•    Recognize partnership as a process, not an end in itself;
•    Understand that partnerships require give and take from all parties;
•    Support the interdependent and interactive nature of partnership relationships;
•    Have effective governance structures to permit full participation in a partnership;
•    Strive to benefit from and contribute to the network of CODE partners;
•    Accept all relevant CODE policies;
•    Will work with CODE in monitoring and evaluating the achievements of these principles and policies;
•    Accept full responsibility for their financial accountability; and,
•    Will enter into a signed agreement with CODE which outlines the mutually agreed upon terms and conditions of the specific partnership.

Mandate

CODE embraces the international principles of equality and human rights designed to ensure everyone has equal opportunity for reaching their potential, irrespective of sex, age, race, colour, class, caste, religion, ethnic background, sexual orientation, health status or disability.

Consequently, CODE is committed to channeling energy, effort and resources into processes that create inclusive, equitable societies and working environments within Canada and in Partner countries. This commitment to achieve equality on the basis of human rights shapes our organization and programming.
This Gender Policy builds on previous CODE policies which are guided by:

• The Platform for Action from the United Nations 4th World Conference on Women, Beijing (1995), which states that “Empowerment of women and gender equality are prerequisites for achieving political, social, economic, cultural and environmental security among all peoples”. ¹
• CIDA’s Gender Equality objectives to 1) advance women’s equal participation with men as decision-makers in shaping the sustainable development of their societies; 2) support women and girls in the realization of their human rights; and 3) reduce gender inequalities in access to and control over the resources and benefits of development.²
• The UNESCO Education for All – Fast Track Initiative, which aims to “achieve gender equality in education by 2015, with a focus on ensuring girls’ full and equal access to and achievement in basic education of good quality”.³
• CODE’s Governing Policy, which states: “CODE will work towards the eradication of gender-based inequities in opportunity and in access to learning through addressing relevant barriers”.⁴
• CODE’s Strategic Plan, which has as its first objective: “to create capacity to enhance learning and literacy skills for girls and boys, women and men in partner countries” in part by “increas[ing] gender assessment, monitoring, implementation and management skills in all partners and CODE.⁵

Vision

CODE will be recognized in Canada and in countries in which it works as a leader for promoting gender equality through education.

Principles
The achievement of gender equality requires that gender equality is central to CODE’s governance and operations.  As a cross-cutting issue, everyone at CODE is responsible to ensure that gender issues receive specialized attention and adequate resources.  This requires on-going learning and monitoring around gender issues, clear gender indicators and accountability mechanisms.

CODE is committed to challenging and changing the attitudes and behaviours that lie at the heart of inequality.  Everyone at CODE and in CODE’s network needs to participate in fostering gender equality.
Gender equality provides an enabling environment and is a precondition for development.  It is a prerequisite for effective education programs to reach girls and boys, women and men equally.

CODE’s Role

CODE supports the development of national capacities to achieve equality for girls and boys – through the strengthening of organizations and through education programs that achieve equal learning outcomes for girls and boys. Leading by example, CODE supports the development of Partners’ gender policies and program delivery that promotes norms, services, behaviours and attitudes that promote gender equality.

Goal
Our goal is to ensure women and men, girls and boys have the capacity, tools and environment that enables them to benefit from development efforts.

Objectives

1. To ensure gender equality is integrated and adequately resourced in all aspects of our organization and our programs;
2.  To apply principles of equality and human rights to foster equal access to and benefit from CODE-supported programs;
3. To promote gender equality in literacy and education through engaging stories, statistics, reports, presentations, mass media.

Implementation
CODE is implementing its gender equality policy through all aspects of its Strategic Plan.

Policy Statement

CODE is committed to building a fair and inclusive organization which values diversity, equity, and inclusion, and fosters and sense of belonging. CODE’s work is guided by five core values: human rights, accountability, transparency, fairness and sustainability. Our beliefs and ideas are consistent with the principles outlined in the Ontario Human Rights Code (the “Code”), and the Accessibility for Ontarians with Disabilities Act (AODA). CODE recognizes the value of promoting diversity, equity, and inclusion and removing any barriers to realizing these values within our organization.

Commitment

CODE is committed to providing equal opportunity employment, creating, managing, and valuing diversity in our workforce; providing a safe work environment, and fostering a culture of belonging where all employees, volunteers and Board Members are included, treated with dignity and respect, and placed in positions to contribute to our future success.

We embrace a diverse workforce and recognize and respect qualities including gender identities, age, race, ethnicity, national origin, culture, religious or political beliefs, language, education, socioeconomic background, family or relationship status, sexual orientation, genetics, and/or disability. We also value diversity of perspective including differences in personality, life and work experience, skills, and ways of thinking and working.

CODE’s commitment to diversity, equity and inclusion extends to all areas of our organization including recruitment, compensation and benefits, performance management, training and development, retention, flexible work arrangements, policies and procedures, and succession planning.

Definitions

Diversity is the collective mixture of differences and similarities that includes individual and organizational characteristics, values, beliefs, experiences, backgrounds, preferences, and behaviors. It means respect for and appreciation of differences on the basis of prohibited ground.

Equity reflects our commitment to providing consistent and systematic fair and impartial treatment for all employees. Inclusion is the achievement of a work environment in which all individuals are treated fairly and respectfully, have equal access to opportunities and resources, and can contribute fully to the organization’s success. Without inclusive practices, a diverse environment cannot be achieved.

Belonging refers to employees’ sense that they are welcomed, accepted, valued, and empowered for their diverse backgrounds and experiences. An inclusive work environment helps foster a sense of belonging.

Scope

This policy provides a framework for new and existing diversity, equity, and inclusion related initiatives and polices across CODE.

This policy applies to Board Members, employees, and volunteers. The principles of diversity, equity and inclusion guide our decision making in relation to selection of partners, contractors, and subcontractors. It covers all aspects of employment including, but not limited to, recruitment, hiring, promotion, employee benefits, conditions of employment, compensation, discipline, training, work environment, and termination of employment.

Policy Details

CODE is committed to building diversity, equity and inclusion in our organization and will advance this standard by the following components and activities:

Safe Work Environment: We provide training to all employees to improve their understanding of behaviors that can be perceived as discriminatory, exclusionary, and/or harassing. We provide safe avenues for employees to report such behaviors. We implement best practices and comply with legal requirements.

Diversity Initiatives in People Management: Create and execute diversity and inclusion strategies for the underrepresented groups in recruitment, advancement, and retention with a goal of being more reflective of the workforce profile.

Diversity Initiatives in Programs: Consider equity, diversity and inclusion in reviewing existing programs and when creating new programs.

Diversity Initiatives in Policy: Consider equity, diversity and inclusion when setting policies and in conducting oversight of operations.

Diversity Initiatives in Governance: Consider diversity and inclusion when recruiting new Board Members and assigning responsibilities to various committees.

Compliance and Monitoring

The Executive Director and Senior Management Team (SMT) will ensure the principles guiding this policy are upheld. A committee which includes representatives of Staff, SMT and Board of Directors will be established to promote the implementation of this policy.

Metrics on diversity, equity and inclusion initiatives will be developed and will be reported yearly to the Board of Directors and shared with staff.

This policy will be entrenched in the Staff Handbook and shared with all staff and Board Members. It will be included in the induction process when joining CODE.

The Executive Director and the Senior Management Team take responsibility for modeling appropriate behaviour, using inclusive language, avoiding bias, and setting the tone for the organization.

Related Policies and Procedures

• Code AODA Policy
• Respect in the Workplace

This policy will be reviewed at least every three years.

Document Control

Document Status: Approved by CODE Board

Effective Date: March 20, 2023

¹ United Nations (1995). “Platform for Action”. http://www.un.org/womenwatch/daw/beijing/platform/plat1.htm Accessed 11/03/11.

² CIDA (1999). “Gender Equality: Policy and Tools”.

³ EFA (1990) Education Goals. http://www.unesco.org/new/en/education/themes/leading-the-international-agenda/education-for-all/efa-goals/. Accessed 11/03/11.

⁴ CODE (2005). “Organizational Policies”.

⁵ CODE (2010). “Five-Year Strategic Plan: 2010/11 to 2014/15”.

Purpose

To provide external stakeholders with a simple, meaningful way to express their complaints, while providing CODE opportunities to improve its operations and mitigate risk to its reputation.

Scope

This policy applies to all CODE representatives.

Definitions

Complaints: Are accusations or expressions of a problem or difficulty. Complaints can include perceived or actual failure to observe CODE’S mission, policies, procedures, and other agreed upon actions, or an unreasonable action or statement by CODE representatives. For this Policy, complaints will include concerns.

Concerns: Are expressions on matters that are of interest or importance to the complainant, and thereby affect their welfare or happiness.

Representatives: All CODE employees, volunteers, members of the Board of Directors.

Stakeholders: Anyone who has been impacted directly or indirectly or has an interest in CODE and its activities.

Policy Statements

1. External stakeholders can learn about CODE’s complaint policy on its website (www.code.ngo/policies).
2. External stakeholders can lodge a complaint about CODE’s programs, activities, or representatives by emailing the info@code.ngo account or calling to speak to the Donor Relations and Database Coordinator at 613.894.3643.
3. Written complaints are escalated as required by the Donor Relations and Database Coordinator and are replied to within seven business days.
4. All stakeholders are dealt with in a respectful manner that informs them of CODE’s complaints process and addresses the stakeholder’s concerns by:
   • Apologizing and/or correcting an error.
   • Informing them of the relevant policy and/or the organization’s position by referring to answers to common concerns on CODE’s FAQ sheet.
5. The applicable Senior Management Team member is copied on complaints.
6. The Board of Directors is provided, on an annual basis, a summary report on the number, type, and disposition of complaints.

Responsibilities

Donor Relations and Database Coordinator: Responds to complaints regardless of how they are received (e.g. phone calls, email). They escalate complaints as may be required and compile a list to be submitted to the Board annually.

Individual Giving and Marketing Manager: Maintains the platform (webpage) that informs external stakeholders of CODE’s Complaints Policy.

CODE’s Complaints Policy is effective January 30, 2025 and will be reviewed every three years.