- 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 information” for the purposes of this Policy is information about an identifiable individual.
- The Personal Information that CODE Collects and Maintains about Donors
The information we collect about a donor or prospective donor that may, alone or in combination, constitute personal information include 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.
- The Purposes for which CODE Collects Personal Information about Donors and the Sources of that Information
We collect 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.
In collecting the personal information on a donor list provided to us by way of exchange from another charitable organization we will ask for and obtain a representation from that organization to the effect that the individuals on its list have given their consent expressly or implicitly to the sharing of their personal information in this way. Any information – in particular, the name and address of any donor – on a list provided to CODE by another organization, through an exchange of donor lists, will be held by an independent mailing house. CODE will only be made aware of such personal information if and when the individual to whom it relates contacts CODE, in response to a communication made through the mailing house and provides the information to CODE
- The Uses of Personal Information about Donors by CODE
We 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.
- The Disclosure of Personal Information about Donors by CODE
We 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, the Canadian International Development Agency,
- 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 our instructions,
- 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 permitted under any applicable personal information protection legislation.
While we never sell or rent out our donor lists, we may provide a donor list to another reputable charitable organization pursuant to an arrangement for the exchange of donor lists with that other organization (as described in section 3 above). In that event, the only personal information about any of our donors that we will disclose on our donor list will be the names and addresses of those donors. We will not disclose any other personal information about a donor, such as the amount or level of contribution made or promised to CODE by the donor. No donor’s name or address, comprising personal information, will be included on a list of donors provided by CODE to another charitable organization without the knowledge and consent of that donor. That knowledge and consent may be implied if the donor has not:
- Marked the appropriate box on any donation form or other document (in electronic or hard copy) provided to the donor, indicating that the donor objects to the sharing of his or her personal information with any other organization for fundraising purposes, and
- Returned the form or other document, so marked, to CODE.
If a donor who has given express or implied consent to the sharing of his or her name and address with other charitable organizations for fundraising purposes wishes to have that information excluded, in future, from any donor list that CODE might exchange with another charitable organization, the donor may simply notify us in writing to that effect at CODE’s address set out at the end of this Policy, to the attention of the Executive Director.
We will act on any such notification within seven days of its receipt. If we have already exchanged a list that includes the donor’s name and address with another charitable organization at the relevant time, we may be unable to prevent the use of that information by the other organization.
- The Retention and Destruction of Personal Information about Donors
We keep personal information about donors and prospective donors for as long as required by law or to fulfill the purposes for which it was collected. We take reasonable steps to destroy, delete or erase personal information that is no longer required.
- The Security of Personal Information about Donors
We endeavour to maintain adequate physical, procedural and technical security with respect to our offices and information storage facilities so as to prevent any loss, misuse, unauthorized access, disclosure or modification of personal information about donors or prospective donors. Our employees are made aware of the importance of maintaining the confidentiality of such personal information.
- Access by Donors to their Personal Information and the Right to Correct that Information
A donor or prospective donor may make a request to us 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 us in writing to amend that information and we will make the appropriate amendment unless we are 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 the requested amendment.
- General Responsibility at CODE for Compliance with this Policy
The Executive Director 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 Executive Director of CODE at the address set out below.
- Effective Date of this Policy and Amendments to the Policy
This Policy is effective as of April 1, 2005. We 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 our Web site, the address of which is set out below.
- Contact Information
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.:
To enable people to learn by developing partnerships that provide resources for learning, promote awareness and understanding and encourage self-reliance.
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.
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.
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.
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.
CODE will promote public awareness and understanding of the organization and development issues both domestically and internationally.
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.
CODE will pursue a broad, diversified and stable financial base and will ensure sound financial oversight and management of all resources.
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.
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.
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.
• 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.
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.
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
CODE will be recognized in Canada and in countries in which it works as a leader for promoting gender equality through education.
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 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.
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.
- To ensure gender equality is integrated and adequately resourced in all aspects of our organization and our programs;
- To apply principles of equality and human rights to foster equal access to and benefit from CODE-supported programs;
- To promote gender equality in literacy and education through engaging stories, statistics, reports, presentations, mass media.
CODE is implementing its gender equality policy through all aspects of its Strategic Plan.
1 United Nations (1995). “Platform for Action”. http://www.un.org/
2 CIDA (1999). “Gender Equality: Policy and Tools”.
3 EFA (1990) Education Goals. http://www.unesco.org/
4 CODE (2005). “Organizational Policies”.
5 CODE (2010). “Five-Year Strategic Plan: 2010/11 to 2014/15”.