The Cybertip.ca website (the “Website”) is owned and operated by the Canadian Centre for Child Protection Inc. (the “Canadian Centre”). The Canadian Centre is a not-for-profit, charitable organization dedicated to the personal safety of all children. The goal of the Canadian Centre is to reduce child victimization by providing programs and services to the Canadian public. One of the Canadian Centre’s programs are the services offered through this Website, namely receiving and addressing reports of child pornography, online luring, child sex tourism, child trafficking, children exploited through prostitution, making sexually explicit material available to a child, and making an agreement or arrangement to commit a sexual offence against a child.
Federal privacy legislation in Canada, namely the Personal Information Protection and Electronic Documents Act (PIPEDA), applies to personal information that is collected, used and disclosed in the course of commercial activities. With the exception of the collection, use and disclosure of information for the purpose of processing donations made through the Website, this Website is not operated in the course of commercial activities; it is not operated for commercial purposes; and the Canadian Centre does not consider the collection, use and disclosure of personal information obtained through the Website to be a commercial activity. The Centre nonetheless believes that maintaining the privacy of your personal information is of the utmost importance and accordingly it adheres to the spirit of PIPEDA in its operation of this Website.
Definition of Personal Information:
Personal information is any identifiable information about an individual, including: name, e-mail address, mailing address, and telephone/fax number. Personal information does not include aggregated information that cannot be associated with a specific individual.
Summary of Privacy Principles
In order to observe the spirit of PIPEDA, the Canadian Centre has adopted the 10 Privacy Principles contained within the Canadian Standards Association Model Code for the Protection of Personal Information. A summary of the principles is set out below. An explanation of how these principles are applied to information collected through this Website is in the section below this summary.
Our responsibility to protect your personal information
The Canadian Centre for Child Protection Inc. is responsible for personal information under its control, and as such has designated an individual who is accountable for compliance with the following principles.
Note: See principle 10 for contact information.
Our obligation to identify the purpose for collecting personal information
The Centre will identify the purposes for which personal information is collected at or before the time of collection.
Note: See section A below, under the heading “Application of the Privacy Principles to Information Collected at Cybertip.ca”, for the purposes statement.
The requirement for knowledge and consent
The individual's knowledge and consent are required for the collection, use, or disclosure of personal information, except where inappropriate. In determining the appropriate form of consent, the Canadian Centre shall take into account the sensitivity of the information and the reasonable expectation of the individual.
Note: The following statement applies to principles 3 and 5:
In certain circumstances, personal information can be collected, used or disclosed without the knowledge and consent of the individual. For example the Canadian Centre may collect, use or disclose personal information if:
- it is clearly in the interests of the individual and consent cannot be obtained in a timely way, such as when the individual is a minor, seriously ill or mentally incapacitated; or
- it is reasonable to expect that seeking the consent of the individual might defeat the purpose of collecting the information, such as in the investigation of a breach of an agreement or a contravention of federal or provincial law.
The Canadian Centre may also use or disclose personal information without knowledge or consent in the case of an emergency where the life, health or security of an individual is threatened.
The Canadian Centre may disclose personal information without knowledge or consent to a lawyer representing the Canadian Centre, to comply with a subpoena, warrant or other court order, or as may be otherwise required by law.
Limiting information collection
The collection of personal information will be limited to that which is necessary for the purposes identified by Canadian Centre for Child Protection Inc. Information will be collected by fair and lawful means.
Limiting Use, Disclosure, and Retention of your personal information
Personal information will not be used or disclosed for purposes other than those for which it was collected, except with the consent of the individual, to comply with a government request, to protect the operations of the Canadian Centre, or as required or permitted by law. Personal information will be retained only as long as necessary for the fulfillment of those purposes. Only those employees of the Canadian Centre who require access to personal information for business reasons, or whose duties reasonably so require, are granted access to personal information.
Note: See the note to principle 3.
Accuracy of your personal information
Personal information will be as accurate, complete, and up-to-date as necessary for the purposes for which it is to be used.
Our responsibility to safeguard your personal information
The Canadian Centre for Child Protection Inc. has security safeguards in place designed to protect Personal Information against loss, theft, unauthorized access, disclosure, use or modification. Such safeguarding measures may include but are not limited to alarm systems, locked cabinets, computer passwords, firewalls and encryption.
If additional specific information about our policies and practices of personal information management are required, such information will be provided to individuals upon receiving a written request.
Your right to access your personal information
Upon request, an individual will be informed of the existence and use of his or her personal information, and will be given access to that information. An individual will be able to challenge the accuracy and completeness of their information and have it amended accordingly. In order to safeguard personal information, access requests must be in writing, and reasonable steps to verify the identity of the individual making the request will be taken before any information will be released.
Note: See section G, under the heading “Application of the Privacy Principles to Information Collected at Cybertip.ca”, regarding access to report information.
Canadian Centre for Child Protection Inc.
615 Academy Road, Winnipeg, Manitoba R3N 0E7
Application of the Privacy Principles to Information Collected at Cybertip.ca
Why Do We Collect, Use and Disclose Information?
On this Website, we collect, use and disclose personal information for the following purposes, or other purposes that may be identified to you at the time of collection:
- To carry out our role as Canada’s national tipline for the reporting of online child sexual exploitation;
- To provide the public with accessible information and resources on the issue of online child sexual exploitation and the protection of children;
- To process reports submitted by users regarding the online sexual exploitation of children for forwarding to the law enforcement and/or child welfare body with jurisdiction to investigate where applicable;
- To provide a positive user experience;
- To understand user requirements and make information readily accessible and available to users;
- To perform research on the online sexual exploitation of children or related issues; and
- To meet legal and regulatory requirements.
What Information Do We Collect?
From All Users:
All information provided by your computer during your visit is collected and used by us to help us better understand our audience and how our site is being used and accessed so we can improve it for subsequent users and deliver content in the appropriate format during your visit. It may also be used to compile statistical information about the use of the Website. Such information is aggregated and non-personally identifying, and includes information like search terms used, pages accessed, date and time of visit, referring site, operating system, web browser and other incidental matters such as screen resolution, the release of your installed Flash version and the language setting of your browser. Session cookies are used to gather some of the information, and some of the information is delivered automatically by your computer. Where a session cookie is used, it only provides information about your visit to our website.
Also, the Website is designed to initially collect and use the IP address provided by a user’s computer to gather broad, aggregated demographic information (such as geographical, domain and ISP information). Once the demographic information is obtained, the IP address information is normally deleted. However, for security purposes, to ensure that this service remains available to all users, and to protect children, we may collect, use, store and disclose an IP address in certain limited circumstances, such as where we detect an attempt to compromise the security or availability of our website, where reporting patterns indicate that the reporting process or features may be being abused; or where we have reasonable grounds to believe that a user has intentionally supplied false or misleading information; a user is or may be involved in unlawful activities involving the sexual exploitation of children; or a child or children may be at risk.
From Reporting Persons:
When a person submits a report using the report form at Cybertip.ca, the reporting person chooses the information to include within the report form. All information so provided is then collected and used by the Canadian Centre for the purpose of processing and verifying the report.
Reports may be made anonymously and users who make an anonymous report can do so without providing contact information. When a reporting person includes his/her contact information within the report, the contact information forms part of the report, along with any other information included in the report. If the report is forwarded to appropriate law enforcement and/or child welfare agencies the contact information is part of the report that is forwarded. The reason contact information is disclosed is so that the reporting person can be contacted by the appropriate law enforcement or child welfare agency for more information if needed.
If a report is provided over the phone, all information that the caller provides to the analyst is entered by the analyst into the same type of report form that a visitor to the Website would use. The phone line that is set up to receive public reports does not collect or receive caller identification information.
The Website contains a link called “Donate”. If you click on the “Donate” link on the Website, you will be redirected to a page where you can obtain information about making a donation, and make an online donation. If you choose to make an online donation on the Website, the information supplied to us through the donation process is collected, used and disclosed by us for the purpose of processing the donation and issuing a tax receipt.
From Those Who Apply to Join Our Mailing List
The Website allows a user to provide us with an email address and receive Cybertip.ca updates, media releases, etc. If a user chooses to provide their email address, the email address so provided will be used for the purpose of communicating updates to the content posted on Cybertip.ca, media releases of the Canadian Centre or others that are connected to Cybertip.ca, and other information that the Canadian Centre believes may be of interest. Your email address will not be used for any other purpose nor will it be disclosed outside of our organization. We also will not link your email address to the information we collect from all visitors (described in section B above), except under the circumstances described in the heading “IP address” in section B.
You may request removal from our email mailing list at any time by contacting us through the Contact Us page accessible from https://www.cybertip.ca/en/contact with the subject line “remove from mailing list”. Instructions for removal from the mailing list will also be set out in each email communication you receive from us.
How We Use What We Collect:
We use information provided through the reporting process as set out in section B above, and also to process and verify the information within the report, determine the appropriate law enforcement and/or child welfare agency(ies) to whom the information should be forwarded, and then forward the information where applicable.
We also use information provided through the reporting process to perform research and generate statistical reports to enable us to improve the reporting process and user experience, identify reporting trends, and help us to more effectively target public communication and awareness activities.
Knowledge and Consent
When you use this Website, it is implied that you have consented to the collection, use and disclosure of your information for the purposes identified in section A above, and in accordance with sections B, C and E herein. In addition, when you submit a report through the reporting process you also consent to the information gathered during the reporting process being used as set forth in sections B and C and shared with the appropriate law enforcement and/or child welfare agency as required and described in section E.
Who We Share Information With
Statistical information about the use of the Website and the reports submitted to the Website may be aggregated and included in public reports issued by the Canadian Centre, however personally identifying information will not be shared in any public report or research report.
We may share the information provided through the reporting process with law enforcement and child welfare agencies for any applicable investigation or follow-up. We may also provide such information to law enforcement, child welfare and emergency services in emergency situations or where required or permitted by statute or court order. In addition, for security purposes and to ensure this service remains available to all users, we may disclose information to the appropriate law enforcement or child welfare agency(ies) where we detect an attempt to compromise the security or availability of our website, where reporting patterns indicate that the reporting process may be being abused by a user; and whenever we have reasonable grounds to believe that a user has intentionally supplied false or misleading information; a user is or may be involved in unlawful activities involving the sexual exploitation of children; or a child or children may be at risk.
With respect to research activities, most research is performed internally; however on occasion external experts are engaged to assist. This occurs only after reasonable contractual and technical safeguards are put into place to protect the information from unauthorized use and disclosure and information shared is limited to that which is reasonably necessary to accomplish the research objective.
How We Protect Information
All transmitted information is protected using measures that are reasonable given the sensitivity of the information. Physical and technical security measure including firewalls and access lists are employed to protect the computer servers and databases within which information is stored. Physical or digital access to report information is restricted to those within the organization who have a need to know, as well as those members of law enforcement and/or child welfare who are involved in the investigation of information provided in a report. While secure sockets layer (SSL) technology is used to encrypt/protect the information in transit, and verify the identity of the Cybertip.ca webserver(s), users should be aware that the internet is a public network, and as such communications cannot be considered 100% secure.
Access to Information
A report number is displayed to the user once the report has been submitted and the user can record and retain that number to establish to a third party that he or she submitted a report if needed.
If a reporting person included his or her contact information within a report and thereafter contacts the Canadian Centre with a report number, the Canadian Centre may be able, after verifying the reporting person, to confirm that a report bearing that number was received and confirm the date and time that such report was received. However, to protect the integrity of the reporting process, to guard against the release of information about where illegal content may be found, and to ensure that any potential investigation into the matter reported is not jeopardized, the Canadian Centre will not divulge any other details about the report. For example, information such as what information the report contained, whether the report was forwarded to law enforcement or child welfare, or whether the website or other information reported did or did not contain illegal images is not provided to any person other than law enforcement, child welfare, or a court of competent jurisdiction that orders the release of such information. Exceptions may be made in limited circumstances upon consultation with the appropriate law enforcement or child welfare agency.
Questions and Concerns
If you have any questions or concerns about our privacy practices, please send a letter outlining your concerns to:Privacy Officer
Canadian Centre for Child Protection Inc.
615 Academy Road, Winnipeg, Manitoba R3N 0E7
You may also submit your question by contacting us through the Contact Us page accessible from https://www.protectchildren.ca/en/privacy-policy/privacy-contact/.
General Data Protection Regulation (GDPR) Acknowledgment (for Europeans only)
The vast majority of reports to Cybertip.ca pertain to online child sexual abuse material (CSAM), which is illegal to access, possess, produce, distribute and make available in Canada. The Canadian Centre does not know the identities of the individuals depicted in CSAM, and also does not know the country within which such individual(s) may reside. The Canadian Centre does not offer services to residents of Europe, either through the Cybertip.ca program or otherwise, but acknowledges that a European may be depicted in CSAM assessed by Cybertip.ca, that Europeans may from time to time visit the websites of the Canadian Centre, and that European hotlines and law enforcement may receive information from the operation of Cybertip.ca. Accordingly, to the extent any information processed through the Cybertip.ca program may be considered personal information about an individual in Europe:
- the purpose for collecting and processing such information, and sharing it with law enforcement and international hotlines when needed is to reduce and prevent the online sexual exploitation of children, and reduce the public availability of CSAM, activities that the Canadian Centre believes are not only in the interest of vulnerable and abused children but also for the purpose of legitimate interests pursued by the Canadian Centre and in the public interest.
- the information processed includes CSAM and related information such as hash values, information that may be included by a reporting person in a report submitted to Cybertip.ca, and information generated as a result of processing such report.
The Canadian Centre reserves the right to adjust this statement at any time and all adjustments will be posted here.