Policy Statement
To ensure donor retention and stewardship are well maintained and that we have consistent donor interaction and management.
Purpose
To ensure compliance with Imagine Canada’s Ethical Fundraising and Financial Accountability Code.
Donor Disclosure
Covenant House shall honor donors’ requests to remain anonymous in respect to:
- Being publicly identified as a supporter of the organization and/or
- Having the amount of their contribution publicly disclosed
Expressed consent is needed for donor recognition. Covenant House Toronto will not publicly recognize any donor unless they have given consent. Any donor who has not given consent for recognition will be asked annually. If no response is received, they will be assumed to be anonymous. Online donors can select the “Anonymous” box when donating for recognition purposes.
Donors who make donations through direct mail can always contact Covenant House Toronto to have their donations remain anonymous at any time. Covenant House Toronto will contact donors by phone, email, and mail who have donated $1,000+ and have not specified whether they want to be recognized, asking if they would like to be recognized. Covenant House Toronto will assume the donor wants to be anonymous if no contact is made.
Information about donors who want to remain anonymous will be recorded in the Raiser’s Edge database.
Solicitation
Covenant House Toronto solicitors will treat donors and prospective donors with respect. Every effort shall be made to honor donors' requests to:
- Limit the frequency of solicitations;
- Not be solicited by telephone or other technology;
- Receive printed material concerning the charity;
- Discontinue solicitations where they are indicated to be unwanted or a nuisance.
Complaints Procedure
Covenant House is committed to providing an open and transparent process for handling allegations of breaches of privacy or non-compliance with the Imagine Canada Ethical Code program (complaints).
Covenant House has appointed a Privacy Officer who will receive and respond to complaints and recommend policy, procedural, and practice changes as needed.
Covenant House will investigate all complaints. If a complaint is found to be justified, Covenant House will take appropriate measures, including, if necessary, amending its policies, procedures, and practices. All complaints will be handled with sensitivity, respect, and in a timely manner.
Procedure
- An individual inquiring about Covenant House's complaints procedure will be offered a copy of the privacy policy or Imagine Canada Ethical Code Guidelines, as appropriate, and a copy of this procedure.
- Complaints will be directed to the Privacy Officer of Covenant House.
- An individual may make a written or verbal complaint by:
- Telephone: (416) 598-4898
- Fax: (416) 204-7030
- E-mail: privacyofficer@covenanthouse.ca
In order for a complaint to be investigated, complainants must provide:
- Sufficient detail to permit investigation, including, but not limited to, the situation leading to the complaint, the nature of the alleged breach or non-compliance, and individuals involved
- Contact information for communication with the complainant, including full name, address, phone number, and email address
- Appropriate proof of identity
Details of the complaint will be disclosed only to the Privacy Officer and to those individuals required to adequately investigate the complaint.
The Privacy Officer provides the Board of Directors with an annual report on the number and general nature of complaints made, and the disposition of these complaints.
First Level of Review
4. Upon receipt of a complaint, the Privacy Officer will send an acknowledgment to the complainant that the complaint has been received. The Privacy Officer will explain the complaint process and include a copy of the relevant policies, guidelines, and processes. The officer will then clarify Covenant House's understanding of the nature and extent of the complaint.
5. The Privacy Officer investigates and responds to the complaint by:
- Maintaining a log of activities related to the investigation and preparation of a response to the complainant
- Advising appropriate Directors and other relevant parties that a complaint has been received
- Reviewing information provided to determine whether Covenant House has complied with its policies, principles, and practices in relation to the complaint
- Working closely with the complainant to seek resolution
- Providing a written response, which summarizes the nature and findings of the investigation and, when appropriate, outlines the measures that Covenant House is taking in response to the complaint, which may include amending its policies, procedures, and practices.
Second Level of Review
6. If the complainant is not satisfied with the results of the first level review, the Privacy Officer will forward the full details of the complaint to the Executive Director and the Senior Management Team. Covenant House will determine which groups/individuals are appropriate to review the complaint.
7. They will:
- Review the report of the Privacy Officer
- Determine what further action, if any, is required
- Provide a written response to the complainant with a copy to the Privacy Officer as appropriate, summarizing the nature and findings of the investigation and, when appropriate, outlining the measures that Covenant House is taking, which may include amending its policies, procedures, and practices.
At any point during the course of an investigation, where the Privacy Officer believes that a serious breach of Covenant House's Privacy Policy or the Imagine Canada Ethical Code guidelines has occurred, the Privacy Officer will immediately inform the Executive Director and the senior management team of Covenant House. In consultation with them, the Privacy Officer will inform the relevant Privacy Commissioner, or Imagine Canada, as appropriate.
Where a complaint puts the Privacy Officer in conflict or perceived conflict of interest, the Privacy Officer will disclose the matter immediately to the Executive Director, who will appoint someone to follow up on the complaint.
In the case of complaints with regard to the Imagine Canada Ethical Code, where a complaint has not been resolved at the end of the second level review, Covenant House will refer the complaint to Imagine Canada to be handled using the Protocol for Complaints available on the Imagine Canada Ethical Code website (www.imaginecanada.ca/en/ethicalcode).