Privacy Policy Statement

Privacy

Community Support Centre-NW is committed to protecting the privacy rights of clients, staff, consultants, volunteers, donors and business associates. The Agency bases its privacy practices on the requirements of the federal Personal Health Information Protection and Electronic Documents Act (PIPEDA) and the provincial Personal Health Information Protection Act (PHIPA). The Agency is committed to meeting the highest standards of ethics with respect to the collection, use, security and disclosure of personal information.

Defining Personal Information

Personal information is any information that can be used to distinguish, identify or contact a specific individual. It includes information that identifies an individual or for which it is reasonably foreseeable in the circumstances that it could be utilized, either alone or with other information, to identify an individual. This information can include an individual’s opinions or beliefs, as well as facts about or related to an individual. Business contact information and certain publicly available information (e.g. names, addresses and telephone numbers as published in telephone directories) are not considered personal information.

Collecting Information

The types of information collected by the Agency may vary depending upon the individuals involved and the nature of their relationship to the Agency.

For clients, the Agency collects personal information that may include name, address, date of birth, health, personal and family information related to assessment, counseling and service provision. When a client chooses not to provide the Agency with permission to collect, use, store or disclose personal information, the Agency may not have sufficient information to provide services.

For staff, volunteers and consultants, the Agency collects personal information that may include name, address, Social Insurance Number, proof of professional education and criminal record check information. When an employee, volunteer or candidate for employment chooses not to provide the Agency with permission to collect, use, store or disclose personal information, the Agency may not be able to employ or place the individual.

To acknowledge donations and for accounting purposes, the Agency collects names and addresses of specific donors.

The use of information may vary depending on the individuals involved and the nature of their relationship with the Agency.

For clients, personal information may be used:

• to provide assessment, counseling and clinical intervention
• to refer clients to other services
• for quality assurance purposes , including feedback on how effective our services have been
• to comply with legal and regulatory requirements
• to comply with the accreditation programs

For staff, students and volunteers, personal information may be used:

• to process payroll
• to administer group insurance programs, leaves of absence and Workplace Safety and Insurance Board claims
• to administer expense claims
• to comply with legal and regulatory requirements

For donors, personal information may be used:

• to issue charitable tax receipts
• to acknowledge donations
• to comply with legal and regulatory requirements

Disclosing Information

Unless otherwise required by law, Community Support Centre - NW does not disclose personal information without specific, informed consent.

The Agency shall only disclose information to other agencies, professionals and schools who are involved with the client when:

• the client (age 16 and over) provides consent
• the parent/guardian (children under the age of 16) provides consent

In the following circumstances, the Agency will disclose information without consent:

• complying with a summons, order or similar requirement issued in a proceeding by a person having jurisdiction to compel the production of information (i.e. search warrant, subpoena)
• notification of children’s aid societies in situations of suspected abuse or neglect
• notification of authorities in situations where staff believe on reasonable grounds that disclosure is necessary for the purpose of eliminating or reducing a significant risk of serious bodily harm to a person or group of persons
• disclosure required by our funding bodies

The Agency does not release personal-related information without the consent of the employee. The only exceptions are those that are required in the course of conducting regular business practices such as:

• payroll administrations
• benefits administration
• compliance with legal and regulatory requirements

The Agency does not sell or release personal information of its donors or volunteers without their consent.

Safeguarding Personal Information

All agents of Community Support Centre - NW including staff, directors, volunteers and accreditors are bound by a Statement of Confidentiality with respect to personal information obtained during the course of their work with the Agency. This statement of confidentiality is taken upon the start of their involvement with the Agency and continues indefinitely upon their departure.

Personal information may only be stored in paper or electronic format. All information is protected by physical and electronic security measures appropriate to the nature of the information, and accessible only by authorized personnel on a need-to-know basis.

Retaining Personal Information

The Agency keeps personal information only as long as needed to meet the purpose for which it was collected, as required by law or specific Agency policy. When personal information is destroyed, Community Support Centre - NW uses safeguards to prevent unauthorized parties from gaining access to personal information during the process.

Ensuring Accuracy of Personal Information

The Agency makes every effort to ensure that information is recorded completely and accurately. From time to time individuals may be asked to update their personal information. The Agency relies on the client/staff to advise of any changes to their personal information. Individuals are entitled to challenge the accuracy and completeness of their information that is held by the Agency, and to request that it be amended as appropriate. In the event that a challenge is upheld, changes will be made to ensure the accuracy and completeness of the information. In the event that a challenge is denied, the challenge will be noted in the individual’s information, and the reason for the denial will also be noted.

Accessing and Openness

Community Support Centre - NW will provide information to individuals about policies and procedures related to the management of personal information that has been collected by the Agency.

On written request, the Agency will inform an individual of the existence, use and disclosure of their personal information that has been collected, and give the individual access to that information subject to limited exceptions.

General

The Agency has appointed a Privacy Officer who is responsible for the implementation of the Privacy Policy. Individuals with questions about privacy at Community Support Centre - NW may contact:

Debbie Dokuchie

Executive Director

53 Arthur Street

Dryden, Ontario

P8N 1J7

807-223-5995

For more information on privacy, contact:

Privacy Commissioner of Canada at www.privcom.qc.ca

Information and Privacy Commissioner/Ontario at commissioner@ipc.on.ca

PROCEDURE

The duties of the Privacy Officer include:

• ensuring that periodic information privacy audits and compliance monitoring activities occur and advise management of issues that arise;
• ensuring that policies and procedures are in place to obtain necessary consents for the collection and use of information;
• ensuring that there are systems in place for the development, implementation and review of policies and procedures;
• ensuring that there are systems in place for the security of hard copy and electronic records;
• receiving, investigating and making determinations on all Challenges related to the Agency’s information privacy practices.