ADM # 3
|ADM Approved by||Executive Director|
|Date of Adoption||June 3, 2014|
|Reviewed||July 14, 2017|
|Revised||Dec 28, 2020|
|Next Review Date||Dec 28, 2023|
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.
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:
For staff, students and volunteers, personal information may be used:
For donors, personal information may be used:
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:
In the following circumstances, the Agency will disclose information without consent:
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:
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.
53 Arthur Street
For more information on privacy, contact:
Privacy Commissioner of Canada at www.privcom.qc.ca
Information and Privacy Commissioner/Ontario at firstname.lastname@example.org
The duties of the Privacy Officer include: