PRIVACY AND CONFIDENTIALITY OF INFORMATION


POLICY:

The Community Oak Park (TCOP) is committed to maintaining confidentiality and protecting the privacy of the personal information it collects, uses or discloses on behalf of its members, volunteers or other individuals who interact with TCQP through its family network services.

Everyone within the TCOP organization who is granted access to personal and/or confidential information about an individual must collect, use, disclose and protect the information in a manner that is both compliant with TCOP's policy and procedure and the relevant privacy legislation.

Individuals whose information is collected by TCOP shall have the right to access their personal information (subject to any legal obligations which may prevent disclosure) and, if necessary, to request corrections to any personal information retained in TCOP's files.

Definitions:

Person: An individual whose personal information is collected by TCOP, including but not limited to members of TCOP, individuals who are engaging services or supports through TCOP, a volunteer, a consultant, or others we engage with as part of TCOP's family network business.

Personal Information: Personal information means information about an identifiable person. It includes but is not limited to name, home address, telephone numbers, email, age, sex, marital or family status, identifying numbers such as social insurance number, drivers licence, race, national or ethnic origin, colour, religious or political beliefs or associations, educational history, medical history, disabilities, blood type, employment history, financial history, criminal history, and name, address and phone number of parent, guardian, spouse or next of kin.

Consent: The knowledge and consent of a person is required for the collection, use or disclosure of personal information about them. This consent may be express or implied. For consent to be valid, it must be informed, knowledgeable, must be freely given, and must specifically relate to the information that will be collected used or disclosed.

Third Party: Third party means individuals or organizations other than the subject of the records or representatives of TCOP.

PROCEDURE:

Vicki McCallum and Karen Alexander are designated as privacy officers and as such are responsible for:

  • receiving and responding to questions/complaints regarding privacy

  • monitoring internal compliance with applicable policies and legislation

  • developing an internal policy for the collection, use and disclosure of personal information and other confidential data

  • ensuring that appropriate consents are obtained for the collection, use and disclosure of personal information and third party disclosure requests

  • ensuring that systems and procedures are in place to ensure records are kept private

  • ensuring that the policy and procedures regarding collection, use and disclosure of personal information are consistently adhered to

  • ensuring that unnecessary files/information are disposed of properly as per policy

  • ensuring that disclosure of personal information to a third party is only done with the prior written approval of the person (unless in a circumstance where the law permits disclosure without an individual's consent)

  • ensuring that the privacy and confidentiality policy is explained to individuals we support, their families and others

  • responding to requests from persons to access their files

  • investigating complaints or breaches of policy

Volunteers are responsible for:

  • understanding and following the policy and procedure regarding personal, privileged and/or confidential information

  • keeping their own volunteer file current regarding their personal information, including consent to disclose

  • immediately reporting any breaches of confidentiality to Vicki Mccallum or Karen Alexander

  • keeping passwords private and access to personal information confidential

  • explaining this policy to the people we support, their families and others

  • returning to Vicki McCallum or Karen Alexander any personal, privileged and/or confidential information in their possession upon request, or before or immediately upon termination of volunteer service

Purposes of Collection and Use of Information by TCOP

Whenever possible, personal information will be collected by TCOP from persons directly. The purpose for which personal information is collected will be identified when the information is collected. All personal information shall only be collected or used for one or more of the following purposes:

  • to communicate with the person, respond to inquiries from the person

  • to register membership or participation in TCOP programs and events

  • to provide information about meetings, workshops, program and services, volunteer opportunities or participation in special interest groups

  • to provide the person with information on services and supports

  • to fulfil the legal and business requirements of TCOP

  • in the course of offering a person, a volunteer or independent contractor engagement

  • to support research, analysis and overall management of services and supports

Third Party Disclosure

From time to time personal information may be shared with third party vendors, suppliers, data processors and other providers responsible for administering supports or services on behalf of the person. Any such third party will be required to have policies in place regarding the collection and use of personal information that are consistent with this policy, and persons will be notified and provided with the opportunity to give consent to the disclosure of their personal information to such third parties.

Consent

Meaningful consent is required for the collection, use or disclosure of personal information. Consent is obtained from the person or the new volunteer, to collect, store, use and exchange or disclose personal information for the purposes stated herein.

Written consent will be obtained from a person for the use of their personal information at the beginning of their relationship with TCOP and shall be updated as needed.

For a person's consent to be valid, it must be informed and meaningful. This means that the person understands how their information will be collected, used, and disclosed, and that they understand the reasonably foreseeable consequence of consenting to this treatment of their personal information. Individuals will be given a clear opportunity to agree or refuse to provide consent.

If a person is not capable of giving consent, consent for the use, collection, and disclosure can be obtained from their substitute decision maker.

Limited Collection, Use, Disclosure, and Retention

Personal information collected shall be limited to what is necessary to achieve this information's identified purpose. The collection of information will be accomplished only through transparent, fair and lawful means. The method of collection may include, but is not limited to, directly from the person, in person, over the telephone, or by correspondence via mail or e-mail or on the internet through our website or by any other means.

The collection, use, and retention of information is limited to what meets the identified purpose(s). A separate explicit consent must be obtained from the person prior to disclosing the information for any other purpose, unless such disclosure is required or allowed by law.

If a person's personal information is disclosed or exchanged with a third party, TCOP will take reasonable steps to ensure that such party agrees to comply with the relevant privacy legislation.

An individual's personal information will be retained only as long as necessary to achieve the stated purposes. When information is no longer required TCOP will store and dispose of records in a secure manner.

All efforts will be taken to maintain the accuracy and currency of all personal information in TCOP's possession from unauthorized access, disclosure, copying, use, error, loss or modification. Documented personal information, both paper and electronic will be stored in files to which only authorized volunteers shall have access. Files will be locked and computer files protected by passwords. All volunteers will be required to sign a Statement of Confidentiality in which they acknowledge their duties subject to this policy.

Access to Records

All persons shall have access to the paper and electronic files containing their personal information to review for accuracy, errors and omissions. Review of files will be scheduled with and supervised by either Vicki McCallum or Karen Alexander.

Transparency and Accountability

A copy of TCOP's policy regarding the privacy and confidentiality of information shall be posted on the website and also available to anyone who requests a copy.

Any complaints concerning the privacy and confidentiality of information will be taken seriously and investigated.