Electronic Access Policy
This Electronic Access Policy was last updated June 27, 2019.
This Electronic Access Policy complements the Canadian Human Trafficking Hotline’s Privacy Policy and is provided as a separate document for ease of access. The undertakings in the Privacy Policy are meant to be read into this policy where applicable.
Organization Background
The operations, services, and website of the Canadian Human Trafficking Hotline (the “Hotline”), www.canadianhumantraffickinghotline.ca, are part of The Canadian Centre to End Human Trafficking (“The Centre”), a not-for-profit, registered charity. More information about The Centre can be found at its website, www.ccteht.ca.
The Hotline is a confidential, multilingual service, operating 24/7/365 to connect victims and survivors with social services, law enforcement, and emergency services. It also receives tips from the public and provides information resources to callers. Callers can both provide and receive information anonymously if they wish.
Purpose of the Electronic Access Policy
This Electronic Access Policy addresses how the Hotline receives and uses information from visitors’ access to its website. Because the internet is public, with numerous third party companies potentially tracking or interfacing with a computer (or other electronic device) user’s use and access of websites, it is important that the Hotline indicate its policies, as well as limitations, in regard to the privacy of website visitor information.
Should a website visitor, or other individual, wish to inquire about the Hotline’s Electronic Access Policy, please contact us by mail at:
Privacy Officer
Canadian Human Trafficking Hotline
P.O. Box 19647 Manulife P.O.
Toronto, ON M4W 3T9
General Statement about the Hotline Website’s User Information
The Hotline does not engage in commercial activity. In all circumstances, access to and use of its website’s visitor information is non-commercial in nature, with protection of that information being paramount. For clarity, the Hotline does not sell, trade or otherwise provide or make available any personal information it has in its possession related to email subscribers, website visitors, donors or others. This assurance refers to names, email addresses, phone numbers, addresses, organization affiliations, or other personally identifying information.
Use of Cookies and Web Analytics
Use of the internet and browsing of websites introduces the likely probability that the browsing behaviour of the user is tracked to some extent or other. It is common that websites, software applications, and social media platforms typically collect browsing experience information.
Cookies are small text files, sent to a user’s computer (or other electronic device such as smartphone) when the user visits a website, which track the user’s access to and use of that website. Websites use that information to recognize a repeat user and enhance that user’s browsing experience and to ease ongoing access through “recall” of past browsing activity and behaviour.
User information collected by cookies may include, but is not limited to:
- Computer network location
- IP (Internet Protocol) address
- Browser used
- Date and time of website access
- Length of browsing session
- Pages accessed
- Documents downloaded
- Links clicked
- Language preference
Cookies can only be read and used by the website that created them; therefore, servers other than the one(s) used by the website do not have access to the information collected by the cookie. Most importantly, cookies can only collect personal information that a user provides (e.g. language preference, credit card information, etc.). All other information is non-identifying such as browser used, time of visit, and so forth.
Users of websites have the ability to control the access of cookies to their browsing experience. Most browsers allow users to control from which websites they accept cookies. Browsers also indicate cookie history and various settings to limit cookie access if desired.
Web analytics software, such as Google Analytics, collects and categorizes website user information and allows analysis of this information to understand user behaviour. As with cookies, users may choose to limit the type and amount of personal information shared with websites and thereby reduce the utility of analytics software in regard to their profiles.
The Hotline’s Use of Cookies and Web Analytics
If a user clicks on an advertisement or third-party link on the Hotline’s website, the Hotline cannot control the use of cookies by those parties.
The Hotline does use cookies to enhance the user experience of its website and to understand how it can maintain and design the website to be of most use to its audiences. Information tracked is of a non-personal nature and is aggregated to determine patterns of use. The Hotline deletes cookie data regularly and, in no case keeps it longer than eighteen months.
The Hotline makes use of Google Analytics to examine the type of data described above in the Cookie section. Also, the Hotline uses this software to analyze traffic source data to determine how users arrive at the Hotline’s website. Source origination points could include search engines, referrals from other websites as links, social media postings, and marketing campaign advertisements. The Hotline believes it is important to understand users’ origination points in order to extend and modify its awareness messages and campaigns to reach individuals who may need the services of the Hotline. In all cases, the Hotline aggregates and anonymizes data to examine patterns, trends, and information clusters. The Hotline deletes user analytics data regularly and, in no case keeps it longer than eighteen months.
Google Analytics is a cloud-based software service; consequently, cookie-generated information is transmitted to Google’s servers with user IP addresses truncated to ensure anonymity. Data transmitted outside of Canadian jurisdiction may be subject to the laws of other jurisdictions. For users wishing to opt out of having their browsing data analyzed through Google Analytics, there exists an opt-out browser add-on found at: https://tools.google.com/dlpage/gaoptout .
Email Subscription
As described in the Organization Background section above, the Hotline is operated by The Canadian Centre to End Human Trafficking (“The Centre”). The Centre’s website, www.ccteht.ca, provides an opportunity to join its mailing list, with the subscription sign-up found at the bottom of each webpage. The Hotline may use this mailing list as part of its outreach for information updates, media releases, marketing campaigns, and surveys. A user may unsubscribe at any time.
As stated above, the Hotline does not sell, trade or otherwise provide or make available any personal information it has in its possession related to email subscribers. This assurance refers to names, email addresses, phone numbers, addresses, organization affiliations, or other personally identifying information.
Donor Information
The Centre’s website provides an opportunity for donors to make a donation to The Centre which may be used to benefit the Hotline. The Hotline does not have a separate donation method on its website. The Centre uses a donation form on its website for a user to complete pertinent information. The form and donation are processed by CanadaHelps.org, a third party charity which links charities and donors. The Hotline does not solicit donors to The Centre and does not make use of any personal information provided by the donor to The Centre or CanadaHelps.org. The privacy policy of CanadaHelps thoroughly discusses and discloses its collection, processing, and use of personal donor information at CanadaHelps.org.
Social Media Platforms
The Hotline disseminates information through The Centre’s LinkedIn, Twitter and Facebook accounts. The Hotline cannot offer any assurances of privacy related to users’ presence on and use of these third party social media platforms beyond the control of the Hotline and The Centre. If users have concerns related to privacy of their personal information or data through their use of these social media platforms, users may wish to inquire with LinkedIn, Twitter or Facebook.
Links to Other Websites
The Hotline’s website provides links to other websites as sources of information. The Hotline cannot offer any assurances of privacy related to use of these third party websites and users should expect to make their own determinations about privacy on these websites.
