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Policies

Venture for Canada: Privacy Policy: Last updated, March 3rd, 2021

Venture for Canada Gift Acceptance Policy (To follow): Last updated, March 3rd, 2021

Venture for Canada Program Participant  Harassment Policy: Last updated, December 1st, 2023

Venture for Canada Events Liability: Last updated, November 7, 2022

 

PRIVACY POLICY 

Venture for Canada (VFC) is committed to the privacy of our clients, employees, and website visitors. This policy specifies how we collect and use your data.

Data We Collect: We collect the following data: Your identity (name, email, phone, and title); Your company and title; other information provided in forms; Your IP address. 

How we collect your data: We collect and process data when you: Voluntarily complete a customer survey or provide feedback via our contact form; Use or view our website via your browser’s cookies. We may receive your data indirectly via the following sources: Referrals sent via email or phone. 

How we use data: We collect data to perform the following: Process, manage and fulfil contracts; Email and/or SMS exclusive offers on products and services; Enhance our services, website, and products. 

  • Our company does not share your data with partner companies.
  • Our company will use third parties to process data. In these cases, only the required information is shared.

How we store data: We store your data on secure cloud platforms that we review.

Marketing: VFC would like to send you information about products and services that we think you may like. If you have agreed to receive e-mail marketing, you may opt-out at any time. VFC uses online advertising via Google Ads. You can review Google Ads privacy brief, Google Ads Privacy Policy, and your Google Ads Settings for more details. 

Data protection rights: VFC would like to ensure you are aware of your data protection rights.

The right to access: You have the right to request VFC for copies of your personal data. We may charge a small fee for this service.

The right to rectification: You have the right to request that VFC correct any information you believe is inaccurate. You also have the right to request VFC complete information you believe is incomplete.

The right to erasure : You have the right to request that VFC erase your personal data, under certain conditions.

The right to restrict processing: You have the right to object to VFC’s processing of your personal data, under certain conditions.

The right to object to processing: You have the right to object to VFC’s processing of your personal data, under certain conditions.

The right to data portability: You have the right to request that VFC transfer the data that we have collected to another organization, or directly to you, under certain conditions. If you make a request, we have 30 business days to respond to you. If you would like to exercise any of these rights, please contact us at:

Email: privacy@ventureforcanada.ca Write: Venture for Canada, 720 Bathurst Street, Toronto, ON M5S 2R4

Cookies: Cookies are text files placed on your computer to collect standard Internet log information and visitor behaviour information. When you visit our websites, we may collect information from you automatically through cookies or similar technology. For further information, visit allaboutcookies.org.

VFC uses cookies to improve your experience on our website, including Keeping you signed in; Understanding how you use our website.

Cookies we use: We use two different types of cookies: Functionality – VFC uses these cookies to recognize you on our website and remember previously selected preferences. These can include your location, language, and cookie preferences. A mix of third-party cookies is used. Advertising – VFC uses these cookies to collect information about your visit to our website, the content you viewed, and the links you followed. These cookies also provide information about your browser, device, and your IP address. We may share online data collected through cookies with our advertising partners. This means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

Manage your cookies: You can set your browser not to accept cookies, and the above website tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Privacy collection policies of other websites: VFC’s website contains links to other websites. Our privacy policy applies only to our website. If you click on a link to another site, you should read their privacy policy.

Changes to our policy: VFC keeps its privacy policy under regular review and places any updates on this web page. This policy was last updated on January 28, 2021.

Contact us: If you have questions about this policy, the data we hold on you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.​

Email: privacy@ventureforcanada.ca, Write: Venture for Canada, 720 Bathurst Street, Toronto, ON M5S 2R4

 

GIFT ACCEPTANCE POLICY

Last updated: March 3rd, 2021

Venture for Canada Fellowship Institute referred to as “Venture for Canada” or “VFC” is a registered Canadian charity that has the mission of fostering entrepreneurial skills and mindset in young Canadians. As such, we welcome the gifts of individuals, corporations, and foundations to help us achieve our mission.

Scope: This policy applies to donations received through all fundraising activities of VFC, including general donations, annual giving, planned gifts, special fundraising initiatives and campaigns.

Gift Eligibility For VFC Charitable Tax Receipts: The following gifts are deemed eligible for VFC charitable tax receipts:

  • Cash: Venture for Canada accepts cash, credit card payments, direct debit payments and cheques or money orders made payable to “Venture for Canada Fellowship Institute.”
  • Testamentary bequests and trusts: A testamentary trust is a trust that is established in accordance with the instructions contained in a last will and testament. Bequests made to VFC may qualify as a charitable gift if the terms and conditions of the bequest are acceptable under VFC’s gift acceptance policies. Official receipts will be issued to the estate of the deceased. VFC requires a copy of documents naming VFC as a beneficiary for our files, prior to a tax receipt being issued.
  • Beneficiary designations under life insurance policies: VFC will accept a life insurance policy as a gift if it is named as beneficiary or is both the irrevocable owner and beneficiary. The tax receiptable amount will be determined according to CRA Guidelines. Any premiums due are the responsibility of the donor. If the insurance policy lapses for non-payment prior to maturity because a donor fails to provide for remium payments, VFC may:
    • Continue to pay the premiums,
    • Convert the policy to paid-up insurance,
    • Surrender the policy for its current cash value.
    • When a life insurance policy is absolutely assigned to VFC, any consent that is required by provincial regulations to change a beneficiary must be signed before the transfer represents a valid charitable donation.
    • Beneficiary designations under retirement funds: VFC will accept the proceeds of a retirement fund as a gift if VFC is named as beneficiary. The tax receiptable amount will be determine according to CRA Guidelines
    • Publicly traded securities: As a general rule, VFC will only accept gifts of securities that are publicly traded stocks and bonds. The value and the tax receiptable amount of such a donation is determined by the value of trading on the date of receipt of donation. All stocks and securities VFC receives from donors will be sold upon completion of the stock transfer without exception.
    • Gifts of real estate: Gifts of real estate will be reviewed with special care to ensure that acceptance will not involve financial commitments in excess of budgeted items or other obligations disproportionate to the use or value of the gift.
    • All gifts of real-estate must receive an independent external appraisal.
    • All gifts of real-estate must be approved by the VFC Finance and Risk Committee.
  • In-kind gifts are ineligible for VFC charitable tax receipts: VFC may accept and record in-kind gifts pursuant to the In-Kind Contribution Policy included in the VFC Financial Controls.

Principle:

As a matter of principle, we engage in the following practices:

  1. VFC will not accept gifts that are not recognized by CRA, or violate federal, provincial or municipal laws.
  2. VFC will not accept gifts, enter into partnerships, or accept support that will compromise its commitment to its mission and essential values as articulated in VFC’s values.
  3. VFC values will protect its integrity, autonomy and funding freedom, and VFC will not accept gifts when a condition of such acceptance would compromise these fundamental principles.
  4. VFC reserves the right to accept or decline any gift. The final decision to decline a gift rests with the CEO.
  5. Ownership of all gifts directed to VFC vests in VFC, whether said gifts are for the benefit of VFC generally or for some specific purpose in it.

Procedures:

We are committed to the following procedures in accepting donations:

  1. Designated gifts will be used for the purposes for which they are provided.
  2. Undesignated gifts will be used for the most-needed initiatives as determined by the CEO in conjunction with the Board of Directors.
  3. Accountability to donors must be of the highest calibre, through appropriate acknowledgment, and accurate and timely reporting by the relevant VFC staff.
  4. Where appropriate, gift agreements will be recorded between donors and VFC and these will be adhered to by VFC.
  5. All donations will be recorded and receipted in accordance with the rules and regulations set out by the CRA. VFC will issue an official receipt for donations of $20 or more that qualify as charitable gifts, in accordance with CRA guidelines. Receipts for donations of less than $20 will be issued only when requested by the donor
  6. Anonymity will be granted to any donor who makes this request.
  7. If, following internal consultations, uncertainty remains as to whether a donation qualifies as a charitable gift, a ruling may be sought from VFC’s legal counsel, auditor and/or the CRA.

PROGRAM PARTICIPANT HARASSMENT POLICY 

Enacted December 1st, 2023

Venture for Canada Fellowship Institute (“Venture for Canada”) is a registered charity, which promotes entrepreneurship amongst Canadian youth through experiential learning.

Venture for Canada is committed to providing an environment in which all employees, volunteers and Program Participants are treated with respect and dignity. Harassment will not be tolerated from any person working at, or engaging with, Venture for Canada.

Program Participants are encouraged to understand their rights and obligations with respect to harassment as set out below. If you believe you have witnessed or experienced harassment, Venture for Canada encourages you to report this following the procedures outlined below.

1. Application
This policy applies to all prospective, current and former Program Participants in any program which Venture for Canada operates.

For clarity, Program Participants are not considered employees of Venture for Canada. Through Venture for Canada’s programs, Program Participants are connected to employment with Canadian small and medium sized enterprises (“SMEs”). This policy does not relate to incidents that take place during a Program Participant’s employment with an SME. If a Program Participant wishes to bring a complaint of harassment against their SME employer, they should reach out to the appropriate individual at their employer for further information. Additionally, should an employee of an SME wish to bring a complaint about a Program Participant working in their enterprise, they should reach out to the appropriate individual at their SME for further information.

2. Definitions
Harassment means engaging in a course of vexatious comment or conduct against a Venture for Canada employee, volunteer, or Program Participant, which is known or ought reasonably to be known to be unwelcome or sexual harassment.

Sexual Harassment means:
● engaging in a course of vexatious comment or conduct against a Venture for Canada employee, volunteer, or Program Participant because of sex, sexual orientation, gender identity or gender expression, where the course of comment or conduct is known or ought reasonably to be known to be unwelcome; or,
● making a sexual solicitation or advance where the person making the solicitation or advance is in a position to confer, grant or deny a benefit or advancement to the participant and the person knows or ought reasonably to know that the solicitation or advance is unwelcome.

Reasonable action taken by Venture for Canada or a supervisor relating to the management and direction of Program Participants is not harassment.

Examples of harassment and/or sexual harassment can include but are not limited to:
● Demeaning remarks, jokes or innuendoes, either directly to the individual or in the presence of others;
● Inappropriate electronic communications;
● Displaying pornographic, racist, derogatory or offensive pictures, graffiti or materials;
● Unwelcome sexual advances or comments;
● Sexual assault;
● Making gestures that seek to intimidate;
● Using words that seek to intimidate;
● Hostile, aggressive or intimidating behavior;
● Discrediting or spreading rumors about the individual; and
● Persistent unwanted contact or attention after the end of a consensual relationship.

Harassment and sexual harassment do not include:
● Legitimate and proper exercise of Venture for Canada’s right to supervise or manage Program Participants and programs;
● Routine interaction between people including inter-personal conflicts or difficulties from time to time, short of disrespectful behavior or harassment as defined; or,
● Occasional curtness or lack of friendliness, unless the curtness or lack of friendliness is so persistent or intense and individualized that it creates an uncomfortable, hostile and/or intimidating environment.

Program Participant means any individual who is participating in any of Venture for Canada’s educational programs. This includes individuals who have applied for and are undertaking the application process regardless of whether they have been approved or denied entrance into the programs.

3. Responsibilities and Expectations
 Venture for Canada is responsible for and committed to providing all employees, volunteers and Program Participants with a harassment-free environment.

The Governance & HR Committee and the CEO are responsible for:
● The administration of this policy;
● Reviewing this policy annually, or as required; and,
● Making necessary adjustments to ensure that this policy meets the needs of the organization.

The Chief Programs Officer is responsible for:
● Ensuring that all Program Participants are made aware of and understand this policy when they enter the program;
● Ensuring this policy is applied in a timely, consistent and confidential manner; and,
● Determining appropriate follow-up action after any investigation as appropriate.

The VFC Leadership Team is responsible for:
● Fostering a harassment-free environment and setting an example about appropriate behaviour while taking part in Venture for Canada programs;
● Communicating the process for reporting, investigating and resolving harassment complaints as appropriate;
● Responding to situations of harassment as soon as reasonably possible when same are brought to their attention;
● Escalating complaints as appropriate in alignment with reporting obligations in the policy;
● Ensuring all complaints or incidents of harassment are investigated in a fair and timely manner; and,
● Ensuring situations are dealt with in a sensitive and confidential manner, to the extent possible.

Program Participants are responsible for:
● Treating others with dignity and respect while engaging in Venture for Canada programs;
● Reporting harassment to the appropriate individuals as set out below; and,
● Cooperating with a harassment investigation and respecting the confidentiality related to the investigation process.

Program Participants are expected to adhere to this policy and to not engage in any comment or conduct which meets the definitions of harassment or sexual harassment. Program Participants will be held responsible by Venture for Canada for any breach of the policy and such conduct could result in penalty up to and including removal from the program.

Program Participants will not be penalized or disciplined for reporting an incident or participating in an investigation involving harassment where such reports and participation are done in good faith.

4. Reporting Harassment
Informal Resolution
Any Program Participant who feels they have been subjected to harassment, or sexual harassment is encouraged (but not required) to indicate to the individual that their comment(s) or behavior is unwelcome, that it makes them feel uncomfortable and that the comment(s) or behavior must stop. If the comment(s) or behavior persists, or the person feels it is inappropriate or uncomfortable to approach the individual, it is the responsibility of the person to report the incident to the Senior Manager of Admissions and Client Support or the Director of Training and Skills Development.

Formal Complaint Process
If the informal resolution process did not result in a satisfactory resolution, or the Program Participant was not comfortable engaging in that process, they should make a formal complaint to the Director of People Operations and Finance. If the Director of People Operations and Finance is the subject of the complaint, or the Program Participant does not feel comfortable going to Director of People Operations and Finance for any reason, they should bring their complaint to the CEO.

Complaints can be made verbally or in writing. If the initial complaint is made verbally, the person to whom the incident is reported will record the details provided by the Program Participant. Written complaints can be made using the Venture for Canada Harassment Complaint Form.

Venture for Canada encourages Program Participants to bring forward complaints as soon as they are able but no later than one (1) year from the last incident of alleged 4 harassment, unless there are circumstances that prevent the Program Participant from doing so. Making a timely complaint can assist in facilitating an investigation.

In making a report, the Program Participant should be prepared to provide details including:
● the name of the individual who has allegedly experienced harassment (the “complainant”) and their contact information;
● the name of the individual(s) who have allegedly engaged in harassment, and their role within the organization (if any), and contact information (the “respondent”);
● names of any potential witnesses or other individuals who the Program Participant believes may have relevant information regarding the alleged incident(s);
● Details of the incident(s) including dates, frequency, and location of the alleged events; and,
● A list of documents the Program Participants feels are relevant and whether they are in their position (if so, they may be asked to provide copies of these documents).

5. Investigation
Venture for Canada takes all complaints seriously. Every effort will be made to resolve a complaint of harassment in a manner that is appropriate in the circumstances and in a timely fashion.

Venture for Canada will evaluate and determine whether interim measures are required in the circumstances of any given situation. If so, the organization will take appropriate steps. This can include, but is not limited to, temporarily removing an individual from the program.

Investigations will be handled by the Director of People Operations and Finance In some cases, and where appropriate, an external third-party investigator may be engaged to undertake the investigation.

In either case the investigator will at a minimum, complete the following:
● Interview the complainant;
● Interview the respondent(s) so long as they are a Program Participant, or Venture for Canada employee. In all cases the investigator will make reasonable efforts to interview the respondent(s);
● Interview any witnesses the investigator deems appropriate in the circumstances. This may (or may not) include individuals identified by the complainant and/or respondent;
● If new allegations come to light following the first round of interviews, the investigator will engage in a reasonable process to ensure such allegations are put to the appropriate individual for response;
● The investigator will take statements during the interviews and the interviewees will be given the opportunity to review their own statements, as recorded to ensure accuracy;
● Review all relevant documents provided during the course of the investigation; and,
● Prepare a report as set out in further detail below.

6. Report
Following the conclusion of the investigation, the investigator will prepare a written report. This report will summarize:
● The complaint;
● The investigation process;
● The information provided by the complainant;
● Any response from the respondent;
● The information provided by any witnesses interviewed; and,
● Any additional evidence received and reviewed.

The report will also provide a finding of fact and come to a conclusion about whether the complaint has been substantiated.

7. Results of the Investigation
Following receipt of the report, Venture for Canada will review the report and make an appropriate determination on what if any action the organization will take as a result of the report.

If a complaint under this policy has been substantiated, Venture for Canada will decide what action is appropriate. Remedies for a Program Participant who has experienced harassment may include, but is not limited to, an apology. Corrective action for a Program Participant, volunteer or employee found to have breached the policy may include but is not limited to corrective action such as additional training, a reprimand, a transfer or removal from the program or termination of employment as applicable.

If a complaint is determined to be unfounded, Venture for Canada will review the report and determine what if any appropriate action should be taken in the circumstances.

Within 10 days of Venture for Canada’s receipt of the report, it will make a determination with respect to the appropriate outcome. This timeframe may be extended where extenuating circumstances warrant such an extension. It will then promptly notify the complainant and respondent (where the respondent participated in the investigation) in writing of the results of the investigation and any corrective action that has been or will be taken by Venture for Canada to address harassment.

8. No Reprisal
Program Participants are encouraged to make good faith complaints under this policy. Where a complaint is made in good faith but is found to be unsubstantiated, no corrective action will be taken against the complainant.

This policy prohibits reprisal against Program Participants who have made a good faith complaint(s) or have provided information regarding a complaint or incident under this policy. Program Participants, employees, and volunteers who engage in reprisal may be disciplined up to and including termination from the program or employment as appropriate.

Where a Program Participant abuses this policy or makes a complaint in bad faith, Venture for Canada will determine what if any action is appropriate in the circumstances. Corrective action may be taken against Program Participants who make bad faith complaints, including but not limited to additional training, a reprimand, or removal from the program.

9. Confidentiality
Information about complaints and incidents shall be kept confidential to the extent possible. Information obtained about an incident or complaint of harassment, including identifying information about any individuals involved, will not be disclosed unless disclosure is necessary to protect Program Participants, to investigate the complaint or incident, to take corrective action or otherwise as required by law.

While the investigation is on-going, the Complainant, the Respondent(s) and any witnesses should not to discuss the incident or complaint or the investigation with anyone unless necessary to obtain advice about their rights. The investigator may discuss the investigation and disclose the incident or complaint-related information only as necessary to conduct the investigation or as required by law.

All records of the investigation, including the investigation report, will be kept confidential.

10. Record Keeping

The organization will keep records of the investigation including:
● A copy of the complaint or details about the incident;
● a record of the investigation including notes;
● a copy of the investigation report;
● a summary of the results of the investigation that was provided to the complainant and respondent (if they participated in the investigation); and,
● a copy of any corrective action taken to address the complaint or incident of harassment.

All records of the investigation will be kept confidential. The investigation documents, including the investigation report should not be disclosed unless necessary to investigate an incident or complaint of harassment, take corrective action or otherwise as required by law.

Records will be kept for a reasonable time and in any case for at least one (1) year.

11. Review
Venture for Canada is committed to reviewing this policy and procedures as often as is reasonable and necessary to ensure it remains effective and, in any case, at least annually.

EVENTS ATTENDANCE AND PARTICIPATION LIABILITY:

LIABILITY

In organizing, promoting, hosting and facilitating conferences, in-person events, and community gatherings, Venture for Canada will use best efforts to create and contribute to an environment that is accessible, respectful, productive, and professional for speakers, volunteers, attendees and participants in compliance with the provisions of the Code of Conduct. However, Venture for Canada disclaims legal liability for any physical, psychological, emotional or any other damages, losses or injury incurred by the speakers, attendees, volunteers, and participants due to the conduct of said parties that is outside Venture for Canada’s reasonable control.