| 1.0 Privacy Policy
The following privacy policy has been approved by the Mutual Support Admin Team in response to PIPEDA and other federal and provincial privacy legislation. The policy follows the 10 principals laid out in PIPEDA, FIPPA and the Electronic Service Delivery Privacy Standard – Ontario.
Mutual Support has developed this policy to ensure that the privacy of information relating to employees and children in the program is protected and respected.
Terms:
PIPEDA: Personal Information Privacy and Electronic Documents Act
Federal Legislation effective January 01, 2004.
Health Information Protection Act: Ontario Provincial Legislation, 2003
FIPPA: Freedom of Information and Protection of Privacy Act
Ontario Provincial Legislation
Personal Information: Under PIPEDA, personal information means information about an identifiable individual, excluding the name, title or business address or telephone number of an employee or organization.
1.1 Accountability
The role of Privacy Officer has been assigned by the Administrative Team to the Executive Director. The Privacy Officer will conduct an annual compliance review to ensure that agency policy and procedures are adequate and up to date with current standards and regulations. The annual compliance review will be submitted to the Administrative Team for review and appropriate measures will be taken to ensure compliance.
1.2 Identifying Purposes
This section describes the purpose for collection, use & disclosure of personal information at Mutual Support.
1.2.1 Employee Information
Personal information about employees is collected and used strictly for the purpose of administering the employment relationship. As such this information is only disclosed where absolutely necessary in fulfilling our obligations as employer.
An inventory of personal record systems is maintained by Mutual Support and is available on request. This inventory details the types of information that are maintained on individual employees. Limited personal information on employees is provided to the following;
Equitable Life: application form completed by employee. Contact and employment status information is updated regularly by Mutual Support.
ADP: Payroll information, including employee contact information, banking information for direct deposit, employment status information, pay and benefit rates, hours worked and salary information.
Carruthers Insurance and Lombard Insurance: Contact and drivers license information for fleet vehicle coverage. A drivers questionnaire is completed by the employee before driving privileges are extended. This questionnaire must be updated upon request.
Lidkea, Stob, Venema and Associates: Basic employee contact information is provided for verification purposes relating to access to our Employee Assistance Program. When working with children LSV are acting as agents of Mutual Support and have full access to file information.
Crawford, Smith and Swallow: Auditors for the corporation, information required to support the audit process, including though not limited to payroll and expense account records.
Daniel, Black, Hill, Tiidus, DeLorenzo, Sheddon, Donahue & Sheppard LLP: solicitors for the corporation, information only as needed for the purpose of administering the employment relationship
By law, all information is available to the Ministry of Children and Youth Services, to the Children’s Aid Society, to the Police, and to the Canada Customs and Revenue Agency.
1.2.2 Child Information
A significant amount of personal information pertaining to children in our care is kept on file. This information is collected and used in the care and treatment planning process. Personal information on children must not be disclosed outside of the program without the consent of the child’s legal guardian.
An inventory of personal record systems is maintained by Mutual Support and is available on request.
When working with children, our clinical consultants Lidkea, Stob, Venema and Associates are acting as agents of Mutual Support and have full access to file information.
By law, all information is available to the Ministry of Children’s Services, to the Children’s Aid Society and to the Police.
1.3 Consent
Mutual Support only collects, uses and discloses personal information with the individual or their legal guardian’s consent, except where otherwise required or permitted by law. Mutual Support does not sell, trade or rent personal information to any organization for any purpose.
It is an individual’s right to choose not to provide some or all of their personal information. They may even deny or withdraw consent to the use or disclosure of personal information for certain purposes. However, given that employee information is obtained and used for the purpose of administering the employment relationship, denial or withdrawal of consent to the use of this information may be cause for termination of employment. In the same way, denial or withdrawal of consent by a child’s legal guardian may result in the termination of a placement.
1.4 Limiting Collection
Collection of personal information will be limited to only those details that are necessary for the purposes identified.
1.5 Limiting Use, Disclosure & Retention
Personal information will only be used for the purposes for which it was collected, unless the individual or legal guardian consents otherwise, or when it is required or permitted by law. Personal information will only be retained for the time necessary to fulfill the purposes for which it was collected, and to meet any legal or regulatory requirements.
1.6 Accuracy
Personal information will be kept as accurate, complete and up to date as possible to fulfill the purposes for which it was collected. Individuals have the right to challenge the accuracy and completeness of personal information and have it amended as necessary.
1.7 Safeguards
Our systems and procedures are designed to prevent loss, misuse, unauthorized access, disclosure, alteration or destruction of personal information. Only authorized personnel have access to personal information. Our commitment to security extends to the contracts and agreements we sign with external suppliers and service providers. All personnel, whether employed or on contract, are required to sign an agreement of confidentiality.
1.8 Openness
It is the policy of Mutual Support to make information about our policies and procedures relating to the management of personal information readily available.
An inventory of personal information is provided to employees at hiring, and consent is required regarding the collection, uses and disclosure of that information. Policies related to this are contained in the Policy and Procedures Manual, and the Human Resources Manual, and made available to all employees.
An inventory of personal information is provided to the child or their legal guardian at placement. Policies related to this are contained in the Policy and Procedures Manual and are also made available.
1.9 Individual Access
Individuals desiring access to their personal information must make a formal request in writing to the Privacy Officer. The request will be reviewed and arrangements for granting access will be made within 30 days of receipt of the request.
1.10 Challenging Compliance
Any questions, concerns or suggestions regarding Mutual Support’s privacy policy should be directed to the Privacy Officer.
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