Privacy Policy
Effective Date: [TO BE SET ON LAUNCH] | Last Updated: [TO BE SET ON LAUNCH]
1. About This Policy
Alberta Constitution Project respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy explains what information we collect, why we collect it, how we use and protect it, and the rights you have under Canadian and Alberta law.
This Policy is governed by the Personal Information Protection Act (Alberta), S.A. 2003, c. P-6.5 ("PIPA"); the Personal Information Protection and Electronic Documents Act (Canada), S.C. 2000, c. 5 ("PIPEDA"), where applicable; the Election Finances and Contributions Disclosure Act (Alberta); and the Canada Elections Act.
2. Who We Are
Alberta Constitution Project is a citizen-led public engagement initiative dedicated to informing Albertans about the legal authority for a provincial constitution under Section 45 of the Constitution Act, 1982, and facilitating public consultation. We are not a registered political party, constituency association, or candidate, and we do not benefit from the political-entity exemptions available under PIPA. We are fully subject to PIPA.
3. Scope (Four Sites, One Database)
This Policy applies to personal information collected through four websites operated by Alberta Constitution Project: albertaconstitution.ca, albertaconstitution.org, albertacommonwealth.ca, and albertacommonwealth.org.
Important: When you submit information through any of these websites, that information is stored in a single secured database operated by Alberta Constitution Project. Your information will be accessible to our authorized personnel across all four sites. We consolidate this data so we do not contact you multiple times if you visit more than one of our properties. By submitting your information through any of these sites, you consent to this consolidation.
4. What Information We Collect
We follow the data minimization principle. When you sign up, we collect your first name and last name (required), email address (required), postal code (required, for regional engagement analysis), and phone number (optional, for contact regarding the initiative). If you sign up through our team volunteer form, phone number is also required. We derive your approximate electoral riding (provincial and federal) from your postal code for regional engagement analysis and to send you locally relevant updates. We may also automatically collect limited technical information (IP address, browser type, pages visited) for security and aggregate analysis. We do not use this technical information to identify you personally except in cases of suspected security threats.
5. Why We Collect Information
Under PIPA Section 11, we collect, use, and disclose information only for purposes a reasonable person would consider appropriate. Our purposes are: (a) to send you updates and consultation opportunities; (b) to understand the geographic distribution of public interest in aggregate; (c) to invite you to participate in consultative events; (d) to meet legal or regulatory obligations; (e) to protect our systems from abuse; (f) to connect potential volunteers with project roles matching their skills and interests; and (g) to derive electoral riding information for sending locally relevant updates and understanding regional distribution of interest.
We will never: sell your information to third parties; share your information for commercial marketing; use your information for purposes materially different from those stated without obtaining your consent.
6. Legal Basis
Under PIPA Section 7, we rely on your express consent. By submitting the signup form, you provide that consent. You may withdraw your consent at any time by emailing our Privacy Officer or using the unsubscribe link in our communications.
7. How We Share Information
We do not sell or rent your information. We share information only with: (a) trusted service providers (hosting, email delivery, database) bound by contractual obligations; (b) across our four websites as described in Section 3; (c) where legally required (court order, valid legal process); and (d) where necessary to protect against fraud, abuse, or harm. We do NOT share your information with political parties, candidates, campaigns, commercial advertisers, or data brokers.
8. Cross-Border Data Transfer
Some service providers may store or process your information outside Alberta or Canada. Where this occurs, we take reasonable steps under PIPA Section 5 to ensure your information receives comparable protection. By submitting your information, you consent to this transfer where necessary.
9. How We Protect Your Information
We use reasonable administrative, technical, and physical security measures: encrypted transmission (HTTPS/TLS), encrypted storage at rest, access controls, regular security reviews, and breach response procedures. If a breach occurs creating a real risk of significant harm, we will notify you and the Office of the Information and Privacy Commissioner of Alberta as required by PIPA Section 34.1.
We use hCaptcha to protect our signup forms against automated abuse. hCaptcha may collect certain browser and device data as part of its verification process. hCaptcha is operated by Intuition Machines, Inc., and its own privacy policy governs its processing of data. We chose hCaptcha for its privacy-focused approach and GDPR compliance.
10. Retention
Under PIPA Section 35, we retain personal information only as long as necessary or as required by law. Active engagement data is kept while you remain subscribed. Aggregated, de-identified data may be retained indefinitely. You may request deletion at any time.
11. Your Rights Under PIPA
You have the right to: (a) access the personal information we hold about you (PIPA Section 24); (b) request correction of inaccurate information (PIPA Section 25); (c) withdraw your consent at any time; (d) make a complaint to our Privacy Officer or to the Office of the Information and Privacy Commissioner of Alberta (410, 9925 - 109 Street NW, Edmonton, AB T5K 2J8; phone 780-422-6860; oipc.ab.ca).
12. Children's Privacy
Our websites are not directed at children under 14. We do not knowingly collect information from individuals under 14. For users 14 to 17, parental consent is recommended.
13. Political Nature Disclosure
In the interest of transparency: this is a public advocacy and education initiative focused on the constitutional question of whether Alberta should consider its own provincial constitution. We take positions on the legal authority for such a constitution (Section 45 of the Constitution Act, 1982; the Reference re Secession of Quebec, [1998] 2 SCR 217; and the Clarity Act, S.C. 2000, c. 26). We do not take a predetermined position on what such a constitution should contain or Alberta's future relationship with Canada. We are not affiliated with any political party, candidate, or campaign.
14. Compliance with Elections Laws
We are committed to compliance with the Election Finances and Contributions Disclosure Act (Alberta) and the Canada Elections Act. Section 9.1 of the EFCDA confirms that "transmitting political views through a non-commercial basis on the Internet" is excluded from the definition of political and election advertising; our websites operate on this non-commercial basis. If our activities ever cross the $1,000 threshold for political advertising, we will register as a Third-Party Advertiser with Elections Alberta and disclose that status on this site.
15. Changes
We may update this Policy. Material changes will be communicated by email to subscribers and by prominent notice on our sites for at least 30 days.
16. Contact
Privacy Officer: Josh Sehn, Alberta Constitution Project, Box 20118 Kensington PO, Medicine Hat, Alberta T1A 8M4. Email: privacy@albertaconstitution.org. We respond to privacy inquiries within 30 days.
