Data Retention Policy

This policy applies to information collected, stored, or managed by HHFFND in connection with:

• participation in programs or support groups
• volunteer, host, or Board involvement
• safeguarding, safety, or incident reporting
• governance and organizational operations
• communications related to HHFFND services

This policy applies to Board members, volunteers, and anyone acting on behalf of HHFFND.

HHFFND follows these principles when retaining information:

• Information is retained only for legitimate organizational purposes
• Retention is proportionate to the reason the information was collected
• Information is not kept indefinitely without justification
• Safeguarding, safety, and legal obligations are prioritized
• Privacy, dignity, and trust guide all retention decisions

Depending on the activity or program, HHFFND may retain limited information related to:

• symptom report submissions
• program registration, participation, and attendance
• participant feedback
• volunteer applications, onboarding, and training
• safeguarding concerns, complaints, or incident reports
• donor and financial transactions
• newsletter and mailing list subscriptions
• governance and corporate records
• communications related to HHFFND services

HHFFND does not retain personal information longer than necessary for the purpose for which it was collected, unless a longer period is required or justified.

HHFFND uses the following retention periods based on the type of information and the reason it was collected.

Symptom Report submissions
Submissions created through the HHFFND Symptom Report tool are stored on the website for up to 30 days and are then automatically deleted. HHFFND does not receive an emailed copy of the completed report.

Participant intake and agreement records
If an individual does not participate in a program or support group, their intake and agreement information is retained for up to 12 months after submission or last contact. If they participate, their records are retained for the duration of their participation plus 2 years.

Attendance and routine program records
Identifiable attendance and routine program administration records are retained for the duration of participation plus 2 years. Anonymous aggregate information, such as overall attendance or participation statistics, may be retained for longer-term program evaluation and reporting.

Participant feedback
Anonymous feedback may be retained for ongoing program evaluation and improvement. If a participant voluntarily provides identifying information for follow-up, that identifying information is removed when it is no longer required. Information relating to a complaint, incident, or safeguarding concern is managed under the applicable retention period below.

Volunteer records
Applications that do not proceed are retained for up to 12 months after application or last contact. Records for active volunteers are retained for the duration of the volunteer relationship plus 2 years.

Complaints, incidents, and safeguarding records
These records are generally retained for 7 years after the matter is closed. Records may be retained longer where necessary because of an ongoing legal, regulatory, insurance, safeguarding, or other legitimate requirement.

Donor and financial records
Financial and transaction records are generally retained for 6 years after the end of the fiscal year to which they relate, or longer where required.

Newsletter and mailing list information
Active subscriber information is retained while the individual remains subscribed. Unconfirmed subscriptions are retained for up to 90 days. When someone unsubscribes, they are removed from active communications, although limited information may be retained as necessary to record and respect the unsubscribe request.

Governance and corporate records
Core governance and corporate records, including articles, bylaws and amendments, board and member meeting minutes and resolutions, and required corporate registers, are retained for the life of the organization, and longer where required by law.

General communications
General inquiries and correspondence that do not form part of another HHFFND record are retained for up to 2 years after the communication or last contact, then securely deleted when no longer required. Communications that form part of a participant, volunteer, complaint, safeguarding, financial, or other organizational record follow the retention period for that record category.

HHFFND periodically reviews retained information and securely deletes, destroys, or anonymizes information when it is no longer required.

Records related to safeguarding, safety concerns, or reported incidents may be retained for extended periods when necessary to protect participants, volunteers, and the organization.

These records are handled with heightened confidentiality and access is strictly limited to those with appropriate responsibility.

HHFFND takes reasonable and appropriate steps to protect retained information, which may include:

• secure digital storage systems
• password-protected platforms and accounts
• limited access based on role and responsibility
• confidentiality expectations for Board members and volunteers

Information is stored in a manner consistent with its sensitivity and intended use.

When information is no longer required, HHFFND ensures it is disposed of securely and responsibly.

This may include:

• permanent deletion of digital records
• removal of access permissions
• secure destruction of physical records, where applicable

Disposal practices are designed to prevent unauthorized access, recovery, or misuse.

Individuals may contact HHFFND to ask what personal information is retained about them, how long it is retained, or to request correction or deletion of their personal information.

Requests for deletion are considered subject to applicable legal, financial, safeguarding, operational, or other legitimate retention requirements.

Requests may be directed to:

operations@healinghorizonsfnd.ca

This Data Retention Policy is reviewed periodically and updated as needed to reflect organizational growth, evolving practices, or changes in legal or governance requirements.