Last updated · 2026-07-14
Privacy Policy
This policy explains what personal information Northern Headwaters ("we", "us") collects when you take action through this platform (placing a phone call to your Member of Parliament, writing and sending a message, or making a donation), why we collect it, who we share it with, and how you can access or delete it. It is written to align with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA).
This is a standard template provided with the platform. The final wording should be reviewed by legal counsel before publication; nothing here is legal advice.
1. What we collect and why
We only collect the information needed to deliver the action you chose to take:
- Postal code → MP routing. We use your postal code to determine your federal electoral district and the correct Member of Parliament (or minister) to contact. We do not need your street address.
- Call bridging. When you place a call, we collect your phone number to connect you to your representative's office through our telephony provider. Call recording is optional and only happens if you explicitly opt in (see section 3).
- Message drafting and sending. When you write a message, we collect your name, email address, and the points you want to make so we can help draft the message and send or hand it off to your representative.
- Donations. If you choose to donate, payment is processed by our payment provider; we do not store your full card number.
- Optional CRM sync. If a campaign you support uses a mailing list, your name and email may be added to that campaign's list so they can keep you updated. This is described at the point of collection and you can unsubscribe at any time.
2. Consent (PIPEDA)
We collect your personal information with your consent, obtained at the point of collection. By entering your details and submitting an action, you consent to us using that information for the purpose described above. We do not use your information for any purpose you were not told about, and we do not sell your personal information. You may withdraw your consent at any time by contacting us (see section 8); withdrawing consent may mean we can no longer complete an action on your behalf.
3. Call-recording consent
Recording a call is opt-in. We do not record your call unless you explicitly choose to have it recorded before the call is placed. If you do opt in, the recording is used only to confirm and improve the action you took, is accessible only through a time-limited secure link, and is deleted in line with our retention schedule (section 4). You can ask us to delete a recording at any time.
4. Data retention and deletion
We keep your personal information only as long as needed to deliver the action, meet operational and legal requirements, and provide campaign reporting, after which it is deleted or anonymized. Call recordings are retained for a limited period and then removed. Per-visit site-analytics data (section 7) is kept at most 90 days, after which it is reduced to anonymous aggregate counts.
How to request deletion
You can ask us to access, correct, or delete the personal information we hold about you at any time. Email us at privacy@northernheadwaters.ca and we will respond within a reasonable time. To protect your information, we may need to confirm your identity before acting on a request.
5. Third parties we work with
To deliver the platform we rely on the following service providers, who process data on our behalf and only for the purposes above:
- Twilio: placing and bridging phone calls, and (if you opt in) call recording.
- OpenAI: assisting with drafting your message from the points you provide.
- Stripe: processing donations securely.
- Mailchimp: managing campaign mailing lists where a campaign uses one.
Some of these providers may process data outside Canada. We share only what is necessary for each provider to perform its function.
6. How we protect your information
We use technical and organizational safeguards appropriate to the sensitivity of the information, including encrypted transport, access controls, and short-lived signed links for any recording media. No method of transmission is perfectly secure, but we take reasonable steps to protect your information.
7. Site analytics and how we measure performance
To understand how well this page helps people take action, and to fix it when it doesn't, we record information about how the page is used: which steps people reach (looking up their MP, starting a message) and where they run into errors. This uses a temporary, random identifier stored in your browser tab only for the length of your visit. It is not a tracking cookie and is discarded when you close the tab.
If you complete an action (a call or a message), we may connect that visit to the action you took so we can understand the full journey, including across more than one of our campaigns.
We honour Global Privacy Control and Do-Not-Track: if your browser sends one of these signals, we keep only anonymous aggregate counts and do not link the visit to you. You can ask us to delete this information at any time (sections 4 and 8).
8. Contact for privacy requests
For any privacy question or request (access, correction, deletion, or to withdraw consent) contact our privacy contact at privacy@northernheadwaters.ca. If you are not satisfied with our response, you may contact the Office of the Privacy Commissioner of Canada.