Privacy Policy

Compass Seniors' Services o/a Connections for Seniors

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Last updated: October 6, 2026

Compass Seniors' Services, operating as Connections for Seniors (“CFS,” “we,” “us,” or “our”), respects your privacy. This policy explains how we handle personal information collected through connectionsforseniors.ca and seniorszone.ca, related online forms, and communications arising from those websites.

Our Chief Operations Officer is the Privacy Officer responsible for this policy. For privacy questions or requests, email frontdesk@connectionsforseniors.ca or call 709-699-0006.

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1. Scope and applicable privacy requirements

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Both websites are operated by CFS. This policy covers website inquiries, registrations, volunteer applications, newsletter subscriptions, donations, and related online interactions. It does not replace any separate privacy notice, consent form, or legal requirements for detailed client intake, health care, residential care, employment, or other program records.

We follow applicable Canadian and Newfoundland and Labrador privacy requirements. The Personal Information Protection and Electronic Documents Act (PIPEDA) applies when personal information is handled in the course of commercial activities; non-profit status does not itself determine whether an activity is covered. We also use its fair information principles as a privacy standard for our website practices.

Where Newfoundland and Labrador’s Personal Health Information Act (PHIA) applies to a particular service or record, its requirements govern. This website policy does not reduce your rights under applicable law.

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2. What personal information means

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Personal information is information about an identifiable individual. It can include contact details, application information, messages, and technical identifiers or browsing information that can identify someone alone or together with other information. Information about requesting a service may be sensitive even when a form asks only for basic contact details.

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3. Information you provide

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Depending on the form or service, we may collect your name, email address, telephone number, address, age or date of birth, and information you choose to include in correspondence. Volunteer applications may include emergency contact details and information about interests or availability.

We also receive event and program registration details, newsletter subscription details, donation records, and initial inquiries about housing, food security, newcomer seniors programs, or other services. Recruitment generally takes place through Indeed; if you email a résumé, we use it to assess and respond to your application.

Public website inquiry forms are not intended to collect MCP numbers, detailed medical or disability information, income records, immigration documents, or criminal record check documentation. Do not include these in a general form or ordinary email. If needed for a program, ask staff how to provide them through an appropriate intake process.

When providing information about someone else, such as an emergency contact or a person you support, ensure you have their permission or another lawful authority to do so. We collect only information reasonably needed for the stated purpose.

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4. How we use information

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• Respond to inquiries and direct requests to the appropriate staff or program.
• Assess volunteer applications, coordinate volunteer participation, register participants, and administer requested programs or events.
• Manage donations, receipts and payment records; assess applications received by email; and maintain related administrative records.
• Send subscribed communications, maintain website functionality and security, and understand which content and outreach are useful.
• Meet applicable legal obligations and legitimate record-keeping, audit, funding or insurance requirements, using de-identified information where sufficient.

5. Consent and your choices

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We explain why information is requested and seek meaningful consent where required. A request for a reply normally permits us to use the supplied information to respond. It does not automatically authorize newsletter subscriptions, unrelated marketing, or advertising tracking.

Express consent is generally appropriate for sensitive information or unexpected uses. Where the law permits collection, use or disclosure without consent, we limit it to the permitted purpose. We seek additional consent when required for a materially different purpose.

You may withdraw consent by contacting the Privacy Officer, subject to legal or contractual restrictions and reasonable notice. We will explain any effect on a requested service; declining optional marketing does not itself prevent access to our programs.

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6. Newsletters and electronic communications

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We collect names and email addresses for subscriptions and use email services such as Mailchimp to send newsletters, event information and announcements. Where Canada’s Anti-Spam Legislation (CASL) applies, we send commercial electronic messages only with a lawful basis, identify the sender, and provide a working unsubscribe mechanism.

Use the unsubscribe link or contact us to stop optional email communications. Requests to stop commercial electronic messages are implemented without delay and no later than 10 business days. A minimum suppression record may be kept to respect your choice. Essential responses or service messages may still be sent where permitted by law; adding promotional content can change the applicable rules.

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7. Third-party platforms and processing

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Our websites link to or embed services used to administer the following activities. The service used depends on the page and activity.

• Forms and volunteer participation: Microsoft Forms; VolunteerLocal
• Newsletters and events: Mailchimp; Eventbrite
• Donations and payment pages: CanadaHelps; Zeffy; Squarespace-hosted payment pages
• Administration and records: Microsoft 365, including SharePoint and Outlook; iCarol; website databases and related hosting services

When a provider processes information on our behalf, CFS remains responsible for information under its control. We require appropriate protection through contractual or other arrangements and limit processing to authorized purposes. Providers may also act independently for certain activities, including account administration, payment security and their own legal obligations; those activities are addressed in their privacy policies.

Review the notice displayed on a third-party form or service before submitting information. If a provider link raises a concern, contact us about available alternatives. A link to an independent website does not give CFS control over that website’s privacy practices.

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8. Donations and payments

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Payment details are entered through the applicable donation or payment provider. CFS may receive donor contact details, donation amounts, receipt information, transaction references and payment status to administer the transaction and maintain required records. Do not send payment card details through a general contact form or email. Providers explain their own payment processing and information-handling practices.

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9. Technical information, cookies and analytics

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When you visit our websites, hosting services, analytics tools and embedded providers may receive technical information automatically. This can include IP addresses, browser and device details, cookie or device identifiers, referring pages, pages viewed, approximate location, timestamps, and interactions such as clicks or video views. The exact information depends on the tool and its configuration.

Cookies are small files stored by your browser. Pixels, tags and similar tools may send information to a provider when a page loads or an interaction occurs. Some serve website functionality or security; others measure usage or support advertising. Technical data is not necessarily anonymous simply because it does not include your name.

Our website setup includes Google Analytics 4 for usage measurement, Google Tag Manager to manage website tags, and the Meta/Facebook Pixel for outreach and campaign measurement. Tag Manager can load other tools, depending on its configuration. Analytics helps us assess traffic and useful content. Meta may receive page and event information and, depending on configuration and your account settings, connect interactions with a Meta account or use them for advertising purposes.

Tracking on a page about a particular service can reveal or suggest personal circumstances. We treat these implications as relevant to consent and restrict collection and disclosure as required by applicable law. This policy is not permission to send form contents, client intake details, or sensitive program information to advertising or analytics providers.

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10. Embedded content and social-media features

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Pages may contain YouTube videos, Facebook or Instagram content, Google Maps, Microsoft Forms, external calendars, social-media sharing features, and Zeffy campaigns. Providers may receive device or browsing information when content loads, even before you interact with it, and may recognize you if you are signed into their services. Their own notices describe their handling of that information.

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11. Your tracking choices

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Current controls: As of the date of this draft, the websites do not provide an Accept / Reject / Manage Cookies banner. Depending on configuration, analytics, advertising tags or embedded content may load automatically. This policy does not mean that optional tracking is blocked until consent is given.

You can block or clear cookies and limit third-party tracking in your browser. Google offers an Analytics opt-out browser add-on for supported browsers; Meta’s privacy and ad settings provide additional controls. These measures do not necessarily prevent every technical transmission, and some embedded features may stop working. Where website preference controls are introduced, their operation will be explained here.

Contact us if you need help or prefer to make an inquiry by telephone. Reading this policy or merely browsing is not, by itself, express consent to optional tracking. We must obtain any consent required by applicable law through an appropriate mechanism.

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12. When we share information

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We do not sell, rent or trade personal information or donor or contact lists. This does not mean that no data is transmitted to technology providers: website tracking and embedded-content transmissions are described above.

We may share the minimum necessary information with authorized staff, volunteers and service providers to handle your request, registration, donation or application. Referrals to an independent organization require consent unless another lawful authority applies. Requesting help does not automatically authorize sharing your full record with every partner.

Disclosures for audits, funding or insurance must have an appropriate legal basis or consent; those requirements alone do not authorize unrestricted sharing. We may disclose information when required by law or when a lawful exception applies, including a permitted response to a serious safety risk. We assess the authority and scope of requests from courts, regulators or law-enforcement bodies.

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13. Storage and processing outside Canada

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Depending on the activity, information may be held in Microsoft 365, SharePoint, Outlook, iCarol, VolunteerLocal, website databases, and the registration, email, donation or payment platforms identified in this policy. iCarol may be used for internal program records; our public websites do not directly link visitors to an iCarol intake form.

Cloud providers and their support or processing services may handle information outside Newfoundland and Labrador or Canada, including in the United States or other countries. Information processed abroad may be accessible to courts, governments or law-enforcement authorities under that jurisdiction’s laws. Contractual safeguards cannot override those laws. CFS remains accountable for information processed on its behalf and uses contractual or other measures to require appropriate protection. Contact the Privacy Officer for available information about a provider used for your interaction and its processing arrangements.

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14. Safeguards

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We use administrative, technical and physical safeguards appropriate to the information’s sensitivity. We limit access to people who need it for authorized work, protect accounts and records, and require appropriate confidentiality from staff and volunteers. We assess service-provider protection and respond to security concerns. No method of transmission or storage guarantees absolute security; ordinary email may be unsuitable for sensitive records.

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15. Retention and disposal

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We retain information only as long as needed for its identified purpose and applicable legal, contractual or legitimate operational requirements. Periods vary by record type, including program, volunteer, donation, accounting and consent records. Records needed for a legal hold or unresolved request may be retained longer.

When information is no longer needed, we securely delete, destroy or de-identify it as appropriate. Removal from backups may follow a separate backup cycle. An unsubscribe or deletion request may not require removal of records we must lawfully retain. Ask the Privacy Officer about the retention approach for your record.

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16. Access, correction and privacy complaints

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You may ask what information we hold about you, how it has been used or disclosed, and request access or correction. Submit your request to the Privacy Officer; staff can help you prepare it. We may verify identity or a representative’s authority using only information reasonably necessary for that purpose.

We aim to respond within 30 days. Where PIPEDA applies, we respond to a written access request within its 30-day limit unless a permitted extension applies, and provide the required notice. Other applicable laws may set different procedures. Access is provided at minimal or no cost; we explain any lawful charge before proceeding.

Access may be restricted only on grounds permitted by applicable law, such as protecting another person’s information or legal privilege. We explain a refusal and available complaint options unless the law prevents this. We correct demonstrated factual errors as appropriate; if a correction remains disputed, we record the concern where required.

You may raise a complaint with the Privacy Officer or contact the Office of the Privacy Commissioner of Canada where PIPEDA applies. For matters within PHIA or another law it administers, contact Newfoundland and Labrador’s Office of the Information and Privacy Commissioner. The appropriate authority depends on the activity and law; this policy does not make every CFS interaction subject to either office’s jurisdiction.

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17. Children and people needing consent support

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Our websites are public, and young people may take part in some activities. Consent processes must reflect age, capacity and sensitivity. For children under 13, we generally require consent from a parent or legal guardian; for older youth, the ability to understand the collection and its consequences matters. Where another person cannot provide meaningful consent, we seek consent from a legally authorized representative as applicable. Contact us if information was submitted without appropriate authority.

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18. Privacy incidents and policy changes

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We assess suspected incidents, contain them, investigate and take corrective steps. We keep incident records and notify affected people, regulators or other parties where required by applicable law. Where PIPEDA applies, a breach creating a real risk of significant harm must be reported to the federal Privacy Commissioner and affected individuals notified as soon as feasible; applicable breach records are kept for at least 24 months.

We update this policy when practices change, post the revised date, and give appropriate notice of material changes. We seek renewed consent where required before using information for new purposes. Posting a revised policy does not itself supply that consent.

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19. Contact the Privacy Officer

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Chief Operations Officer / Privacy Officer
Compass Seniors' Services o/a Connections for Seniors
107 Lemarchant Road, St. John’s, Newfoundland and Labrador, Canada
Email: frontdesk@connectionsforseniors.ca
Phone: 709-699-0006

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