Privacy Policy
Updated May 19, 2026
1. Introduction
At Safe Pathways, trust is important to us. This privacy policy (hereinafter the “Policy”) sets out how Safe Pathways Canada Inc. and its affiliated companies (hereinafter “Safe Pathways”, “us”, “we” and “our”) collect, hold, use or disclose to third parties Personal Information (as defined below) of our Clients (as defined below), their Volunteers, and other users of our services or other individuals (hereinafter individually referred to as “you” and “your”), other than our employees or contracted staff, which are addressed separately.
Safe Pathways operates a web-based application and related digital tools, including safepathways.com (the “Website”) and app.safepathways.com (the “Web App”), designed to assist subscribing organizations with screening, delivering safeguarding training, implementing abuse prevention protocols, conducting background checks, tracking compliance, and maintaining records relating to the supervision of children, youth, and vulnerable adults (hereinafter collectively the “Services”). We are committed to treating any Personal Information we collect, hold, use or disclose with care, within the limits of this Policy and applicable law, and Safe Pathways is responsible for such Personal Information under this Policy.
In this Policy, a “Client” means any organization that subscribes to and uses the Services for its internal organizational purposes pursuant to a services agreement with Safe Pathways, including without limitation for the purposes of screening, volunteer training, safeguarding Client policy implementation and general compliance tracking. A “Volunteer” includes:
(a) An "Authorized Adult", meaning a status conferred by the Client upon an adult who:
(i) Has been approved by the Client to supervise children, youth or vulnerable adults or who is being screened by the Client for such purpose; and
(ii) Meets and once approved continues to meet, the requirements established by the Client from time to time and at any time, in its sole and unfettered discretion; and
(b) Any other individual acting as a volunteer with the Client.
For the avoidance of doubt, this Policy only covers Safe Pathways’ own privacy practices. Each Client is an independent organization responsible for its own collection, use, and disclosure of Personal Information. Volunteers and other individuals should contact their Client directly to inquire about its privacy practices.
Please read this Policy carefully as it applies to all visitors and users of the Services. By accessing and using the Services, you acknowledge that you have read and understood this Policy. If you do not agree with any or all of the provisions of this Policy, please do not access or use our Services.
2. Types of Personal Information
This Policy applies to Personal Information regardless of the type of medium or the form in which it is accessible: written, graphic, audio, visual, taped, filmed, computerized, or otherwise recorded.
We define “Personal Information” as any information about an identifiable individual, or that, alone or in combination with other information, allows an individual to be identified. By way of illustration, Personal Information may include, but is not limited to:
first and last name;
date of birth;
phone number, home address, and email address;
preferred language;
time zone;
financial, credit, billing, and account information;
authentication credentials and account identifiers, where applicable;
details about the use of a website obtained by means of cookies or similar tools;
Internet Protocol (IP) address, browser type, locale preferences, mobile carrier; and
any other Personal Information provided.
3. Purposes for which we Collect Personal Information
We collect Personal Information for the following purposes:
to provide, operate, maintain, and improve our Services and business operations;
to create, manage, and administer user accounts;
to process transactions and deliver platform functionality, including safeguarding training, background checks, compliance monitoring, and audit reporting;
as a core part of the Services, to maintain and retain Safeguarding Records in support of safeguarding and child protection purposes;
to communicate with you regarding the Services, your account, transactions, updates, and support matters, and to respond to your requests;
where permitted by law, to send marketing and promotional communications;
to analyze usage of the Services for analytics, statistical, product development, and service improvement purposes;
to protect the security and integrity of the Services, including detecting and preventing fraud, misuse, and unauthorized activity;
to comply with legal, regulatory, and risk management obligations;
to evaluate employment applications, where applicable;
for any purpose permitted or required by applicable law; and
for any other purpose to which you have consented.
For the purposes of this Policy, “Safeguarding Records” means the records maintained as part of the Services relating to volunteer safeguarding, including background check results, reference check information and responses, tenure confirmation and internal administrative notes (including notes relating to complaints or incidents).
4. Means by which we Collect Personal Information
We primarily collect Personal Information directly from you or from your Client when you create an account, use the Services, communicate with us, or submit information through our Website or Web App, including when you complete forms, request support, or participate in features of the Services. This includes without limitation information provided by Clients when creating Volunteer accounts, uploading personal information, assigning training pathways, initiating background checks, or otherwise interacting with the functionalities of the Services.
We may also collect Personal Information from third-party sources such as service providers, partners, or publicly available sources, where such collection is permitted by law and consistent with this Policy.
We also collect certain Personal Information automatically through cookies and similar technologies when you visit our Website or use our Web App. Cookies are small text files or strings that a website can send to your device to identify your web browser and collect information about how you use the Website or Web App and interact with its features, including IP address, type of operating system, pages visited, requests made, and dates and times of connections. The use of cookies does not allow us or our service providers to identify you specifically, nor does it give us access to your device or any information other than the data you choose to share with us. Cookies help us improve our Website and Web App.
We use both strictly necessary cookies, which are required for the Website and Web App to function properly, and optional cookies, such as analytics and marketing cookies, including those provided by third-party analytics or service providers, which help us understand usage of the Services and improve functionality. Where required by applicable law, optional cookies or similar technologies are used only with your consent. You may accept or refuse such cookies through the cookie banner displayed when entering our Website or Web App, or adjust your browser settings to manage or delete cookies at any time. Please note that if you choose not to accept certain cookies, you may not be able to access or fully experience certain features of our Website or Web App.
5. Outsourcing, Storage and Transfers of Personal Information
We may disclose the Personal Information we have collected to third parties in the following circumstances:
to service providers in connection with our Services and business, including hosting, cloud storage, data processing, payment processing, analytics, marketing, and customer support;
to a Client and their designated administrators, where this is inherent to the functionality of the Services or based on the applicable Client’s administration of its account;
to affiliates or partners in connection with the Services or our business;
to third-party platforms for marketing or content distribution, in accordance with applicable law;
to comply with legal obligations or lawful requests;
to protect rights, safety, or security;
in connection with a business transaction such as a merger, acquisition, financing, or sale of all or part of our assets; and
any other circumstances to which you have consented or as permitted by applicable law.
Personal Information processed through the Services is primarily stored and hosted in Canada. In limited circumstances, certain service providers may access, process, or store Personal Information outside of Canada where necessary to support the operation of the Services.
Where required by applicable law, including Québec privacy legislation, we conduct privacy impact assessments prior to the transfer of Personal Information outside of Québec or Canada, and implement appropriate contractual, technical, and organizational safeguards to ensure that the Personal Information receives a level of protection consistent with applicable Canadian data protection laws. This may include the use of standard contractual clauses or other recognized mechanisms, where appropriate.
Where Personal Information is processed outside of Canada, it may be subject to the laws of the foreign jurisdiction, including lawful access by courts, law enforcement, or governmental authorities in that jurisdiction.
6. Your Consent under this Policy
We will not collect, hold, use or disclose your Personal Information without your consent unless it is authorized or required to do so by applicable law. By using our Services, or by otherwise submitting your Personal Information to us, you acknowledge and agree that your Personal Information will be collected, used, and disclosed in accordance with this Policy and as required or permitted by applicable law.
If you provide Personal Information concerning another individual to us, you represent that, prior to submitting such Personal Information, you have obtained the necessary consent or authority to permit us to collect, use and disclose such Personal Information for the purposes set out in this Policy, or that such collection, use and disclosure are permitted by applicable law. In particular, each Client represents and warrants that it has obtained all necessary consents and authority from each actual or prospective Volunteer prior to uploading their Personal Information to the Web App or assigning any training pathway to such individual.
You may vary or withdraw your consent to the use and disclosure of your Personal Information, or opt out of certain uses and disclosures, subject to legal and contractual restrictions as well as to applicable law. Please note that the withdrawal of your consent may prevent us from providing or continuing to provide our Services or access to our Website or Web App.
Email marketing communications. We may send to users of our Services marketing and promotional communications, including emails, SMS, or other electronic messages, in accordance with applicable law, including Canada’s Anti-Spam Legislation (“CASL”), where applicable. We will obtain express consent before sending commercial electronic messages unless implied consent applies under CASL (for example, where an existing business relationship exists). If a user no longer wants to receive such communications, they may click on the “unsubscribe” link in such communications to opt out of future marketing messages.
If you require any assistance in understanding the scope of the consent being sought or to vary or withdraw your consent, please contact our Privacy Officer using the contact information in Section 12.
7. Your Rights
Depending on your jurisdiction of residence and the applicable privacy laws, you may have certain rights regarding your Personal Information. The rights described in this Section are not exhaustive and may be supplemented by other rights available under applicable law.
We may request certain Personal Information for the purpose of verifying the identity of the person seeking to exercise their rights.
If you are a resident of Canada, or if Canadian privacy laws otherwise apply to you, the collection, use, and disclosure of your Personal Information are governed by applicable Canadian privacy laws, including the federal Personal Information Protection and Electronic Documents Act (commonly referred to as “PIPEDA”),, and applicable provincial privacy legislation, including the Quebec Act respecting the protection of Personal Information in the private sector (commonly referred to as “Law 25”), the Alberta Personal Information Protection Act, and the British Columbia Personal Information Protection Act, and any other provincial laws applicable to Safe Pathways’ operations. This Policy is intended to comply with and is subject to the requirements of applicable Canadian federal and provincial privacy laws.
You have the following rights regarding your Personal Information, subject to certain limitations and exceptions provided by applicable law:
to access and obtain a copy of the Personal Information we hold about you, and, where applicable, to request that such information be communicated to you in a structured, commonly used technological format or transferred directly to another organization, where technically feasible and subject to applicable law;
to have the Personal Information we have about you rectified, amended and updated if it is incomplete, ambiguous, out of date or inaccurate;
to request the deletion of your Personal Information when: i) the retention of the information is no longer justified for the purpose for which it was collected; and/or, if you are a Quebec resident, ii) the information was not collected in a lawful manner; and/or iii) it is obsolete; and
to withdraw or change your consent to our processing of your Personal Information, subject to applicable legal and contractual restrictions. In some instances, withdrawing your consent may result in us no longer being able to provide our Services or access to our Website or Web App.
We may request certain Personal Information for the purpose of verifying the identity of the person seeking to exercise their rights.
8. How we Safeguard Personal Information
In order to protect the Personal Information that is in our possession, we employ administrative, physical, and technological safeguards which are appropriate to the sensitivity of the Personal Information provided. These safeguards also prevent the accidental or unlawful destruction, loss, unauthorized alteration or disclosure, access, or misuse of the Personal Information in our possession. We follow generally accepted industry standards to protect the information that is provided during its submission and once it has been received. These include measures to deal with any suspected data breach.
Once communicated, the Personal Information is kept in an electronic file within our document management system or third-party technologies used by us, or both. Only those personnel who reasonably require the Personal Information to perform their duties are granted access to the information and they are bound by a duty of confidentiality. In the event of a data breach involving your Personal Information, Safe Pathways will notify affected individuals and relevant authorities in accordance with applicable laws.
It is important to note that, despite our best efforts to protect your Personal Information, there is a risk associated with the communication, exchange and storage of information, as no form of electronic transmission or storage is perfectly secure.
9. Links to Third-party Websites
Our Website and Web App may contain links to third-party websites or services that are not owned or controlled by Safe Pathways. This Policy only applies to information collected by us for the purposes mentioned in Section 3 above.
We have no control over these third-party websites, and your use of third-party websites and features are subject to the privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third-party websites linked to our Website or Web App.
10. Personal Information of Children and Minors
Given the nature of Safe Pathways’ Services, which are designed to facilitate the safeguarding and supervision of children, youth, and vulnerable adults, we collect and process Personal Information relating to minors. Where required by applicable law, the use of the Services by minors is subject to the involvement and consent of a parent or legal guardian.
We require verifiable parental or legal guardian consent before collecting, using, or disclosing Personal Information relating to users under the applicable age of digital consent in their jurisdiction, including individuals under 14 years of age in Québec and individuals under 13 years of age in other Canadian jurisdictions, where applicable.
Without limiting any other provisions of this Policy, for individuals under the applicable age threshold, a parent or guardian must:
review and accept this Privacy Policy and any applicable terms; and
be able to exercise applicable rights in respect of the minor’s Personal Information, including requesting access to and correction of such information, in accordance with applicable law.
Each Client is solely responsible for ensuring that it has obtained valid consent from the parent or legal guardian of any minor, or other lawful authority as required under applicable law, prior to uploading such individual’s Personal Information to the Web App or assigning any training pathway to such individual.
If you are a parent or guardian and believe that Personal Information relating to a minor has been provided without the required consent, or if you wish to exercise your rights in respect of such information, please contact us using the information provided in Section 12. Upon verification, we will take appropriate steps in accordance with applicable law, which may include deleting the information.
11. Retention and Destruction of Personal Information
The Personal Information we collect is retained for varying periods of time depending on the type of information in question and the purposes for which it is collected and used. Subject to a retention period provided for by applicable law, the Personal Information we hold is destroyed or anonymized once it is no longer necessary for the purposes for which it was collected or used, or for any subsequent compatible purpose.
For example, account and billing information may be retained for the duration of the business relationship and for a reasonable period thereafter to comply with legal, accounting, tax, audit, or regulatory requirements. Safeguarding Records may be retained for longer periods where necessary to fulfill safeguarding and child protection purposes, which constitute a core component of the Services.
We may de-identify or aggregate Personal Information so that it no longer identifies you. To the extent permitted by applicable law, we may use and disclose such de-identified or aggregated information for legitimate business purposes, including analytics, service improvement, the development of new features or services and statistical reporting.
12. How to Contact Us
In order to obtain more information on the Policy or the use of your Personal Information, to exercise your rights or to file a complaint, please contact our Privacy Officer at the following coordinates:
Safe Pathways Canada Inc.
ATTN: Privacy Officer
62 Dogwood Crescent
Toronto, ON, M1P 3N6
privacyofficer@safepathways.com
13. Changes to this Policy
We may update this Policy from time to time to reflect changes to our privacy practices or for other operational, legal, or regulatory reasons. Changes will take effect immediately upon posting on the Website or Web App or by otherwise notifying you. Where required, we will obtain your consent to material changes. Otherwise, your continued use of our Services or provision of Personal Information after such changes take effect constitutes your acknowledgment of the updated Policy. We encourage you to review this Policy periodically.