BrightStart Caledon Family Centre is committed to protecting the privacy of the personal information of its service recipients, members, clients, donors, staff, volunteers, and other stakeholders. All personal information is dealt with according to the principles of transparency and accountability. All personal information that is collected is carefully protected and any use of this information is subject to consent.
Definitions:
- Personal information is defined as any information that could be used to distinguish identity or contact a specific individual, exceptions are business contact information and publicly available information such as numbers published in a phone directory.
- Transparency is the conveniently accessible provision of clear and understandable information about an organization’s privacy policies and practices to all its stakeholders.
- Accountability is the responsible control of all personal information that an organization possesses, including appropriate use of consent and utilization of stringent security procedures.
Accountability
BrightStart Caledon Family Centre is committed to protecting all personal information it holds or transfers to other organizations in compliance with its privacy policy and related procedures.
BrightStart Caledon Family Centre will create and maintain the position of Chief Privacy Officer for its organization.
The Chief Privacy Officer will be the Program Manager of BrightStart Caledon Family Centre.
Duties:
- Provide leadership for BrightStart Caledon Family Centre privacy program
- Facilitate the development and implementation of a formal privacy policy and related procedures
- Ensure that privacy risk assessments and audits are conducted on an as needed basis
- Monitor organizational compliance with all privacy legislation
- Ensure resolution of non-compliance with all privacy allegations
- Ensure all staff/volunteers are familiar with the content and implementation process of the privacy policy and provide appropriate training to comply with the requirements in the spirit of PIPEDA
- Manage public perception of data protection and privacy practices for the organization
- Maintain current knowledge of federal and provincial privacy
Identifying Purposes
BrightStart Caledon Family Centre will clearly identify to its clients and stakeholders the purpose of collecting personal information and how it is protected through its privacy policy and related procedures. The following statement will be communicated to its stakeholders at any sites through which BrightStart Caledon Family Centre provides services:
“BrightStart Caledon Family Centre respects your privacy. We endeavour to protect your personal information and adhere to all legislative requirements with respect to protecting privacy. The personal information which you provide to us will be used by us for very specific purposes: delivery of services; provision of updates and ongoing communications regarding our organization, services provided by other related organizations, upcoming events, and/or training sessions; enrolment in training events; volunteer/staff recruitment; and/or fundraising by our organization. We do not rent, sell, or trade our mailing lists.
Individuals may choose to have their personal information removed from BrightStart Caledon Family Centre records. This request may affect access to programs and services offered by BrightStart Caledon Family Centre.
If at any time you wish to be removed from any of our contact lists, please communicate with us by phone at 905-857-0090 or by email at info@brightstartcaledon.com and we will gladly accommodate your request.”
Communicating the Purpose Statement:
This statement will be made available to stakeholders as follows:
- Posted on BrightStart Caledon Family Centre website
- Posted at all sites where services are delivered, both permanent and temporary
- Published in all BrightStart Caledon Family Centre communications materials
- Added to all consent forms
Consent
BrightStart Caledon Family Centre is committed to obtaining meaningful and voluntary consent from all individuals with respect to the collection and utilization of personal information.
Consent Process:
- Every program/service will utilize a specific consent process.
- Consent may be in written or verbal format.
- Consent will be updated annually.
- Every effort will be made to ensure that the consent process is conducted in a manner which ensures comprehension on the part of the stakeholder including language accessibility and the use of plain language.
- When personal information is to be utilized for new purposes, new consent is required.
- Consent may be withdrawn at any time, subject to legal restrictions and reasonable notice. Every program/service will ensure that a consent withdrawal process is established and communicated to stakeholders.
Definition:
Meaningful consent is defined as consent that is:
- Informed: the individual is made aware of what information is being collected, how it is to be used (including any disclosures), and why the collection of the information is necessary. The individual receives accurate and complete information.
- Voluntary: the individual consents without threat of physical harm or without the use of physical/pharmacological restraints.
- Legal: the person who consents has the legal authority to do so, on behalf of him/herself or another individual.
Managing Personal Information
BrightStart Caledon Family Centre will ensure that personal information is collected solely for the purposes identified and is done so by fair and lawful means.
Process:
- The collection of personal information will be restricted to the following purposes:
- program registration and participation
- volunteer screening and placement
- ongoing client/volunteer contact, communications and correspondence
- All forms will clearly state the identified purpose for the collection of personal information.
- Personal information will be collected within ethical and legal parameters.
Limiting Collection of Personal Information:
BrightStart Caledon Family Centre will collect only the information necessary to fulfill the purposes identified by the specific program/service.
Limiting Retention of Personal Information:
Personal information that is no longer required will be destroyed, erased, or made anonymous.
Accuracy:
Personal information should be accurate and up-to-date to facilitate the most effective provision of services.
Safeguards:
BrightStart Caledon Family Centre will ensure that all personal information in its possession is protected from theft, unauthorized utilization, or loss.
- All reasonable physical measures should be used (i.e. locked filing cabinets, restricted access to offices, keeping files in secure areas.)
•All available technological measures should be used including passwords, encryption, “need to know” access, and security clearances.
Individual Access to Personal Information:
BrightStart Caledon Family Centre will inform all individuals about the existence, use, and disclosure of their personal information. These individuals will be informed that they have the right to access their personal information and to challenge its accuracy.
- Requests for access should be responded to within 15 days and at minimal or no cost to the individual.
- Individuals may correct inaccuracies in their own personal information.
- Exceptions to access may be established. These exceptions should be limited, specific, and reasonable (i.e. references to other individuals or information that cannot be disclosed for safety, legal or security reasons.)
Openness
BrightStart Caledon Family Centre is committed to ensuring that its privacy policy and related procedures are communicated in an easily accessible manner and format to all stakeholders.
Process:
- The privacy policy will be posted at all sites where services are delivered, both permanent and temporary. This includes both physical and virtual sites.
- The name and contact information of the Chief Privacy Officer will be posted at all sites where services are delivered, both permanent and temporary. This includes both physical and virtual sites.
- Stakeholder sheets providing basic information regarding the privacy procedures of each service will be available at sites where services are delivered, both permanent and temporary. This includes both physical and virtual sites.
- Stakeholder sheets will include the privacy policy, the name and contact information of the Chief Privacy Officer, and how stakeholders can access the specific privacy procedures for each service.
- The complaint procedure will be posted at all sites where services are delivered, both permanent and temporary. This includes both physical and virtual sites.
- A mechanism will be established whereby the above information could be made available in languages other than English when required.
Complaint Procedure
Any stakeholder has the right to challenge the compliance of BrightStart Caledon Family Centre with legislative requirements related to privacy, including the Personal Information Protection and Electronic Documents Act.
A notice including this right and the following process will be posted at all physical locations where BrightStart Caledon Family Centre provides services, including temporary locations.
Process:
- The individual contacts the supervisory staff member of the specific service to express his/her concerns.
- If these concerns are not dealt with to the satisfaction of the individual, the individual contacts the Chief Privacy Officer at the phone number 905-857-0090 or email address, ailsa@brightstartcaledon.com.
- The Chief Privacy Officer decides what specific actions will be taken regarding the concerns.
- The Chief Privacy Officer must convey his/her decision in writing to the complainant within 2 weeks.
- The decision of the Chief Privacy Officer is final.