Privacy and confidentiality are extremely important to Community Living Wallaceburg. Information regarding the confidential manner in which personal information is collected and stored is outlined in the Association’s PIPEDA policy.
POLICY STATEMENT
This policy is written in accordance with the Federal Personal Information Privacy and Electronic Documents Act (PIPEDA) and is a companion policy to the agency’s policy on Confidentiality, Access to, and Disclosure of Information.
PRIVACY OFFICER AND ACCOUNTABILITY
The person designated as the organization’s Privacy Officer for the purposes of this policy and applicable legislation will be the Executive Director. All employees of Community Living Wallaceburg will be accountable to the Executive Director for protecting the confidentiality and security of all personal information they come in contact with.
PERSONAL INFORMATION
The agency will identify the purposes for which personal information is collected and used at the time of, or before the collection of the personal information. Information is collected for the following purposes:
- Receiving applications for service and support, membership, employment or volunteering.
- Assessing eligibility for association membership.
- Providing a person with assistance, establishing and maintaining communication with the person and responding to inquiries.
- Assessing the adequacy and quality of assistance provided.
- Meeting legal and regulatory requirements.
- Confirming employment or volunteer status and maintaining communications.
- To meet Community Living Wallaceburg’s obligations as an employer, the agency will need to share information with other corporations such as, but not limited to, insurance providers, direct deposit bank, government agencies, and the official employee bargaining agent. A Social Insurance Number (S.I.N.) is required for many of these obligations and will be shared only when required.
- To establish emergency contact with family and/or others as designated.
- To communicate for the purposes of fund development, information sharing and agency activities.
CONSENT
We will only collect, use and disclose consentual personal information except where otherwise required or permitted by law. With the exception of membership mailing addresses provided to Community Living Ontario, we will not share, sell, trade or rent personal information. Individuals already receiving support, employees and volunteers will be provided with a copy of this policy to be signed and returned.
COLLECTION OF INFORMATION
The collection of personal information shall be limited to information which is necessary for the purposes identified by the organization and shall be collected by fair and lawful means only.
USE, DISCLOSURE AND RETENTION OF INFORMATION
Personal information shall not be used or disclosed for purposes other than those purposes for which it was collected except with the consent of the individual or as required by law. When information is no longer required to be kept, Community Living Wallaceburg will destroy paper files and purge electronic files in a secure way that will eliminate the possibility of information contained in such files being accessible to anyone else.
ACCURACY
Personal information collected shall be accurate, complete and up-to-date as is necessary for the purposes for which it is to be used. A person has the right to challenge the accuracy and completeness of personal information in writing to the Privacy Officer and/or his designate.
SAFEGUARDS
Files containing personal information of those receiving support, volunteers and employees alike, both paper and electronic, will be stored in a manner which only authorized personnel have access. The storage area and filing cabinets will be locked and computer files protected by passwords. Electronically transmitted information via public internet is not 100% secure. Therefore, we cannot ensure the security of any information transmitted electronically via public internet. All volunteers and employees of Community Living Wallaceburg sign an “Oath of Confidentiality” at the time of hire in which they acknowledge their duties subject to this policy, the agency’s Confidentiality, Access to, and Disclosure of Information Policy and related legislation.
OPENNESS
This policy is publicly posted and accessible via Community Living Wallaceburg’s website and paper copies are available by request to the Privacy Officer.
INDIVIDUAL ACCESSS
In accordance with current policy and procedure, individuals receiving support, volunteers and staff may view the paper and electronic files maintained by Community Living Wallaceburg with their own information. They may comment on accuracy, identify information that may not be correct or current and make specific suggestions for revision. They have the right to a copy of all documents contained in the files subject to agency policy and procedure and any legal restrictions. A nominal fee may be imposed for photocopies.
COMPLIANCE
Individuals receiving support, volunteers and employees alike may contact the Privacy Officer with questions, suggestions or opinions with regards to compliance with this policy and relevant legislation. The Privacy Officer is responsible for monitoring applicable legislation and taking such steps as required ensuring that Community Living Wallaceburg is in compliance. This responsibility will include suggesting draft revisions of this policy for Board of Directors consideration and adoption at the appropriate times.