Personal Information Protection And Electronic Documents Act
In recognition that Southern Frontenac Community Services Corporation (SFCSC) must comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), the Board of Directors enacts the following policy.
Types and Usage of Personal Information
SFCSC collects and maintains personally identifiable information in the normal course of activities. This information includes:
Client Data: Personal information necessary to determine eligibility for services, to set up service provision by a service provider or volunteer and for billing or statistical purposes.
Volunteer and Service Provider Data: Personal information necessary to contact them to assign tasks for clients, data about what jobs the individual is willing to accept, mailing information for the purposes of reimbursement, organizational memorandums and recognition.
Employee Data: Personal information necessary for employment purposes.
Members: Personal information necessary for mailing the newsletter and corporate reports.
Donors and Fundraising Data: Personal information necessary to advise and recognize contributors.
Collection of Personal Information
SFCSC obtains this personal information directly from the individual or their legally appointed, substitute decision maker or from a referring agency.
Maintenance of Personal Information
Personal information is maintained in a combination of secure paper-based files and computer files at South Frontenac Community Services Corporation.
Data Security and Integrity
Paper-based files are kept in a lockable filing cabinet. Computer files are accessible only from the applicable staff person’s terminal. Access is limited to staff and administrative volunteers who undergo the screening process including police record checks and reference checks.
SFCSC does not disclose personal information to others except to establish service provision including referrals as authorized by the client or individual, or for collection purposes when financial, contractual obligations are not being met.
Consent to Disclose Information
Clients, volunteers, service providers, members and employees will be asked to authorize disclosure of their personal information when it is required. The authorization will normally be in writing however, in situations where a signed consent has already been obtained and a temporary alternate arrangement for service must be made, a verbal consent will be noted in the file.
How to "Opt Out" or Discontinue Services
Gathering eligibility and contact information is essential to providing services. If a client, volunteer, service provider, employee, member or donor wants to discontinue involvement with SFCSC, notification can be sent to the Privacy Officer at our Sydenham mailing or email address. Our current Privacy Officer is Kim McCaugherty, Long Term Care Services Coordinator.
How to Obtain Access and Request Corrections or Deletions to Personal Information
Individuals may request access to their personal information by applying in writing to the Executive Director or directly to the Privacy Officer. This request should identify if there are any barriers to accessing written information, for examples, the need for a sign language interpreter or conversion of the written word into a Braille format. Within 30 days an appointment with the applicable Coordinator will be scheduled to review the file with the individual or legally appointed substitute decision maker.
If, during the review of the file, inaccuracies are identified, corrections or deletions can be made if agreed to by both parties. In the event that the individual requests changes or deletions that the Coordinator does not feel will accurately reflect the situation, the Coordinator may refuse. In this situation, the Privacy Officer will hear both opinions and determine any additional action required.
In the event that the individual is not satisfied by the outcome of the appeal to the Privacy Officer, information to appeal to the Privacy Commission will be provided.
Exceptions to Disclosure Rule
It is noted that there are exceptions to the consent and access of personal information files. SFCSC must refuse an individual access to personal information if it would reveal personal information about another individual unless there is consent or a life-threatening situation or if information has been disclosed to a government institution for law enforcement or national security reasons. In these situations, SFCSC must advise the Privacy Commissioner of the refusal.
SFCSC may refuse access to personal information in situations where disclosure could harm an individual's life or security or if it was collected without the individual's knowledge or consent to ensure its availability and accuracy and the collection was required as part of an investigation of a breach of an agreement or contravention of a federal or provincial law. In these situations, the Privacy Commissioner must also be notified.
Notes taken in the course of resolving a formal dispute resolution process or confidential commercial information, if removable, can be withdrawn and the balance of the file released for review.
How to Initiate an Inquiry
If you have a question or concern about how we are handling your personal information, you may notify our Privacy Officer at Southern Frontenac Community Services, 4295 Stagecoach Rd., Box 43, Sydenham, ON, K0H 2T0 or by email at firstname.lastname@example.org. You will receive a written response with 30 days.
If a dispute relating to SFCSCs handling of personally identifiable information cannot be satisfactorily resolved, SFCSC may refer the matter to the Privacy Commissioner.
How to Contact the Privacy Commissioner of Canada
If a client, volunteer, service provider, employee, member or donor is denied access to personal information or alleges that SFCSC:
improperly collects, uses or discloses personal information or
refuses to correct inaccurate or incomplete information or
fails to provide access to personal information in an alternative format to an individual with a sensory disability or
does not use appropriate safeguards to protect personal information,
the individual may complain to the Commissioner using this contact information:
The Privacy Commissioner of Canada
112 Kent Street
Ottawa, ON K1A 1H3
This policy shall be reviewed annually by the Executive and Finance Committee with recommendations for amendments presented to the Board of Directors.