Last Updated: February 18, 2025

Meals on Wheels (103 South Road, Paget PG03, https://mealsonwheels.bm) prepares and delivers nutritious meals to elderly or infirmed clients four days per week. “MoW”, “we”, or “us” refers to Meals on Wheels, it’s employees, volunteers and services. This Privacy Policy applies whenever you access our website or communicate with us in person, via telephone, email or written correspondence. This Privacy Policy describes:

  • What personal information is collected
  • How we use and share that information
  • How we protect that information
  • How we dispose of information that is no longer relevant

1. Designation of Privacy Officer

We have designated a Privacy Officer to ensure compliance with the Personal Information Protection Act 2016 (PIPA). You may contact our Privacy Officer at mowacctsbda@gmail.com for questions or concerns regarding this policy or your personal information.

2. Security Statement

Your privacy and security are of utmost importance to MoW. We are fully committed to safeguarding your personal information. This section discloses our information gathering and dissemination practices:

  • We conduct periodic reviews and updates to our security safeguards, proportional to the sensitivity of the information.
  • Only authorized employees have access to personal information, and they are trained in handling data responsibly
  • In the event of a security breach that is likely to adversely affect you, we will notify the Privacy Commissioner and any affected individuals promptly, as required under Section 14 of PIPA.

3. What We Collect and Store

When you enter into a client, donor or volunteer relationship with us, we may collect the following information:

  • Financial Information:
    • Banking information including credit/debit card details
    • Credit/debit card details. We do not store client credit card information, and any such information provided for the purpose of settling client accounts is destroyed immediately once the charge has gone through.
  • Personal Information:
    • Name, address, email address, phone number, birth date, gender, physical and/or mental health indicators and specific diagnoses, family relationships.
  • Family Information (Clients): Name, address, email address, phone number and relationship of close family members, or friend who may be contacted if necessary.

We may also collect non-personal information about your use of our website, such as your IP address, browser type, and access times.

4. How we use this Information

We use this information to:

  • Meet our obligation to provide meals that are compatible with specific dietary needs
  • Meet our obligation to provide a regular social check-in with our clients
  • Assess whether you or a responsible family member are able to contribute to the cost of the meals
  • Receive and record donations made via our website and acknowledge these donations.
  • Assess website usage

All donor information collected on our website is automatically deleted after six months.
Client information is retained only as long as necessary to fulfill stated purposes, unless otherwise required by law. Volunteer information is retained as long as necessary, unless otherwise required by law.

5. Sensitive Personal Information

Sensitive personal information (e.g., health, race, sexual orientation) is handled with heightened security and only used:

  • With your explicit consent
  • In compliance with a court order or legal requirements

We will not use sensitive personal information to unlawfully discriminate against you.

6. Who on Our Team Has Access

Members of our team, such as Drivers, Administrators and Finance personnel, may access:

  • Client address (for delivery of meals)
  • Client medical details (for preparation of meals that meet specific dietary restrictions)
  • Client email address and financially responsible party (for billing purposes where necessary)
  • Contact details of close family member or close friend (where necessary)

Access is limited to facilitating distribution of appropriate meals, contacting family members or close friend should client be unwell or unexpectedly absent, and collecting payment where client has agreed to be financially responsible.

7. Sharing Your Personal Information

We do not share your personal information with third parties, unless required by law. We may provide bulk statistics to benefactors when requested, including number of meals delivered and percentage of clients who receive meals at no charge. We will not share your personal information without express written permission. We ensure that third parties comply with data protection standards comparable to PIPA and require them to safeguard your information responsibly.

8. Your Rights

Under PIPA, you have the following rights:

  1. Access: Request access to your personal information and details of its use and disclosure.
  2. Correction: Request corrections to inaccuracies in your personal information.
  3. Erasure: Request the deletion of information no longer relevant for its original purpose.
  4. Object: Object to the processing of your information for marketing or other specified purposes.
  5. Complaint: Lodge complaints with our Privacy Officer or the Privacy Commissioner if your rights are violated

To exercise these rights, contact mowacctsbda@gmail.com. We will respond as soon as is reasonably possible or within 30 days, with extensions communicated as needed.

9. Retention Policy

We retain personal information only as long as necessary for:

  • Providing services and collecting payment
  • Legal compliance (e.g., tax and accounting for 7 years)

10. Children’s Privacy

We do not collect personal information from your minor children.

11. Changes to This Privacy Policy

We may update this policy periodically to reflect changes in our practices, legal obligations, or operational needs. Any updates will be prominently posted on our website, and significant changes will be communicated directly.