PRIVACY POLICY

A.INTRODUCTION

Community Care for South Hastings (hereafter referred to as “CCSH”) is a not-for-profit and volunteer-based agency that directs its services to assisting seniors and adults with physical disabilities. We provide programs and services that assist our clients to reside in their own homes and improve their quality of life by assisting them in utilizing appropriate community resources. Our services are varied and include Meals on Wheels and Diners’ Club programs, Transportation Services, Friendly Visiting, Social and Recreational Programs and Home Maintenance and Homemaking. Our services are directed to the Municipalities of Belleville and Thurlow, Desoronto and Tyendinaga.

At CCSH, we take your privacy very seriously. In addition to our established policy of dealing with personal health and other information in a sensitive manner, we are required by law to ensure that our Collection, use, retention and Disclosure of Personal Information is carried out in accordance with established principles and requirements of law, including Ontario's Personal Health Information Protection Act (“PHIPA”).

BY DISCLOSING YOUR PERSONAL INFORMATION TO CCSH OR TO ITS AGENTS AND ACCEPTING THE TERMS OF THIS PERSONAL INFORMATION PROTECTION POLICY, YOU AGREE THAT CCSH MAY COLLECT, USE, RETAIN, DISCLOSE AND DISPOSE OF YOUR PERSONAL INFORMATION IN ACCORDANCE WITH THE TERMS OF THIS POLICY.

This Policy deals with the following:
(a) our accountability for our privacy practices;
(b) the purposes for which we collect Personal Information and the sorts of Personal Information that we collect;
(c) the manner in which we obtain Consent for our dealings with Personal Information;
(d) the manner in which we use and Disclose Personal Information;
(e) our security, retention and disposal processes relating to Personal Information;
(f) your right to access your Personal Information;
(g) how you can get answers to questions or raise concerns about our dealings with your Personal Information and/or our compliance with this Policy; and
(h) our right to amend this Policy.

B.SCOPE
This Policy applies to all Personal Information that is held by, or is under the control of, CCSH and is designed to ensure that Personal Information is protected during its collection, use, Disclosure, storage and destruction in accordance with the applicable legislative requirements.

C.DEFINITIONS
The following definitions have been created to explain terms that are used extensively in this Policy:
"Collect" or "Collection" means the act of gathering, receiving or obtaining Personal Information from you or from third parties, by any means.
"Consent" means your voluntary agreement with what is being done or proposed, is knowledgeable and relates to the Personal Information. In appropriate circumstances, Consent may be implied as more fully detailed below. Consent can also be given by an authorized representative, such as a legal guardian, power of attorney or a substitute decision-maker, in certain circumstances.
"Disclose" or "Disclosure" means to make your Personal Information available or to release it to another person.
"Personal Information" means information about an identifiable individual including information that relates to the physical or mental health of an individual and a person's medical history and plan of treatment and it includes an individual's health number.

ARTICLE 1 – ACCOUNTABILITY
1.1 The Contact Person below is responsible for facilitating CCSH's compliance with this Personal Information Protection Policy and may be contacted at:
55 South Pinnacle Street, Belleville, ON K8N 3A1
Attention: Privacy Officer
613-969-0130 (Telephone)
613-969-1719 (Fax)
ccsh@ccsh.ca (e-mail)

While the Privacy Officer is primarily responsible for our Policy, other CCSH personnel may be assigned responsibility for the day to day collection and processing of Personal Information or for acting on behalf of the Privacy Officer from time to time.

1.2 All CCSH employees and persons associated with CCSH in the Collection, use and Disclosure of Personal Information (in oral or recorded form) are responsible for the Personal Information that is obtained, handled or viewed in the course of the operation and services of CCSH. CCSH has adopted policies and procedures in the workplace designed to enhance the protection of Personal Information and ensure that the confidentiality of your records is of primary importance. Any service provider that CCSH may engage to process or to otherwise deal with Personal Information on our behalf is not permitted to use, retain or Disclose Personal Information transferred to it by us except in accordance with the terms of its agreement with us. Depending on the circumstances, we may require a contractual commitment with that third party to protect your Personal Information. The unauthorized use or Disclosure of Personal Information shall, in the case of employees, result in disciplinary action, up to and including termination of employment.

1.3 CCSH has implemented policies and practices to give effect to our privacy commitment to you, including:
(a) Personal Information security processes (see Article 7 below); and

(b) access, complaint and correction procedures (see Articles 9 and 10 below).


ARTICLE 2 - PURPOSES FOR COLLECTING, USING AND DISCLOSING PERSONAL INFORMATION
2.1 When you first make application to receive services from CCSH, you will meet with a Program Coordinator who will gather Personal Information that is relevant to the program you are qualified for or otherwise apply to. At this time CCSH may receive personal medical information that is relevant to developing a client service plan. All of the information CCSH collects during the process is strictly on a need-to-know basis and any relevant information is recorded in your file. This information will be updated from time to time after the commencement of service delivery.

2.2 In addition to the Personal Information that we collect directly from you, CCSH may also collect health information about you in the course of providing you services indirectly. For example, we may receive information from former health care providers, physicians or from other community service agencies, such as Community Care Access Centres and from family members.

2.3 We collect the personal information referred to above in order to provide services to you. More particularly, this information is used by a variety of CCSH employees on a “need to know” basis to make appropriate decisions regarding your services.

2.4 If Personal Information that has been previously collected is to be used or Disclosed for a purpose not previously identified, we will, subject to our legal rights and obligations, identify that new purpose to you prior to the relevant use or Disclosure and, where appropriate, we will seek your Consent to this collection prior to its occurrence.

2.5 We endeavour to ensure that persons collecting Personal Information directly on our behalf are able to adequately explain to you the purposes for which your Personal Information is being collected.

ARTICLE 3 – CONSENT
3.1Subject to our legal rights and obligations, CCSH obtains an appropriate form of Consent for the collection, uses and Disclosures of Personal Information contemplated in Article 2 above. Where CCSH receives Personal Information about a client for the purpose of providing health care or other services, CCSH is entitled to assume that it has Consent to Collect, use and Disclose the information for the purposes identified in this policy, unless we are advised that you have expressly withheld or have withdrawn Consent.

3.2 You may withdraw your Consent to our collection, use or Disclosure of your Personal Information at any time, subject to legal or contractual restrictions and reasonable notice. To exercise this right, please contact the Privacy Officer at the co-ordinates detailed in Article 1 above. Please note that a failure to provide Consent to the use of certain forms of Personal Information may limit CCSH’s ability to provide proper services to you or your family member. The Personal Information of clients of CCSH is an essential tool used in the design and delivery of effective services.

ARTICLE 4 - LIMITING COLLECTION
4.1 We will collect only that personal information that we require to achieve the purposes for the collection. CCSH will not collect, use or disclose more personal information than is reasonably necessary to meet the purposes of the collection, use or disclosure, unless such use or disclosure is required by law. Further, CCSH will not collect, use or disclose personal health information if other non-health information will serve the purpose.

ARTICLE 5 - LIMITING USE, DISCLOSURE AND RETENTION
5.1 Personal Information is used by a limited number of our personnel, on a "need to know" basis, while they are performing their functions and to ensure that proper services are provided to you or your family member.

CONT'D

5.2 From time to time, we Disclose or transfer Personal Information to other parties. Except as required or permitted by law, we will not Disclose your Personal Information without your Consent to other parties. For example CCSH may Disclose your Personal Information to some or all of the following third parties in the course of providing services to you: the Community Care Access Centre, Emergency Contacts, Department of Veteran Affairs and the Ontario Disability Support Program where relevant to the program delivery. Prior to disclosing your Personal Information to these organizations, we will secure your written Consent.

5.3 Where Personal Information is transferred by us to outside service providers that process Personal Information for us, reasonable steps will be taken to ensure that any such provider has personal information privacy procedures and policies in place that are at least comparable to those implemented by CCSH if the circumstances are available to do so. We will further seek to ensure that any Personal Information that is transferred to such a third party is returned or destroyed at the end of the processing relationship.

5.4 Your Personal Information is not available to members of the public or staff or volunteers of CCSH who are not directly involved in your service delivery. Personal Information that has been used to make a decision about you or your family member shall be retained for a reasonable period in order to permit you to access that Personal Information after the decision and to comply with all record retention requirements imposed on CCSH from time to time.

ARTICLE 6 – ACCURACY
6.1 We will not routinely update Personal Information, unless it is necessary to fulfil the purposes for which the personal information was collected. However, we will take reasonable steps to ensure that the information is as accurate, complete and up to date as is necessary for the purposes of the Disclosure that are known to CCSH at the time. Clients of CCSH also have an obligation to ensure the information we have collected is accurate and should identify any errors or inaccurate information when they become aware of it and bring it to the attention of the Privacy Officer identified above.

ARTICLE 7 - SAFEGUARDS
7.1 We protect Personal Information under our control with safeguards that are appropriate to the sensitivity of that information. These safeguards are designed to protect Personal Information in all formats against theft, loss and unauthorized use or Disclosure and to ensure that the records containing the information are protected against unauthorized copying, modification or disposal. These safeguards deal with more than just the physical storage of records, but also deal with appropriate password and other protections for any medical information that is stored electronically. In the event CCSH discovers that Personal Information in its custody or under its control has been stolen, lost or accessed by an unauthorized person, it will notify the affected individual at the first reasonable opportunity.

ARTICLE 8 - OPENNESS
8.1 Information about our privacy-related policies and procedures is available upon request. This policy is one example of how we deal with Personal Information. If there is a specific question regarding an incidence of the Collection, use or Disclosure of Personal Information, please contact the Privacy Officer above who will respond fully to any questions you may have regarding the treatment of your Personal Information.

ARTICLE 9 - INDIVIDUAL ACCESS
9.1 An individual has a right of access to a record of Personal Information that is in the possession of CCSH, unless there is a valid legal right to refuse an individual to allow access. This information is your information and it is not the practice of CCSH to refuse access to your own records.

9.2 Subject to its legal rights and obligations, CCSH will, upon receipt by our Privacy Officer of a written request for access, inform you about our Collection, use or Disclosure of your Personal Information, if any, and permit you to access that Personal Information if it is held or controlled by us. If you request such information or access, you must provide sufficient information with your request to permit us to locate the record with reasonable efforts. Any Personal Information provided by us to you as a result of a request for access shall be in a generally understandable form.

9.3 We will respond to a request as soon as possible in the circumstances and in any event within thirty (30) days of receipt of the request. We may extend this response deadline for up to an additional thirty (30) days if replying within thirty (30) days would unreasonably interfere with our operations, or if the time required to undertake any consultations necessary to respond to the request would make it impractical to meet that time limit. When necessary, we may also extend the response deadline for as long a period as is necessary to permit conversion of the Personal Information at issue into an alternative format that would allow a person with a sensory disability to read or listen to that Personal Information. We will provide written notice to you of any response period extension within thirty (30) days of your request. We will endeavour to respond to a request for access at no cost. However, CCSH may charge a fee in appropriate circumstances to process a request and will provide an estimate of that fee at the time the request is received.

9.4 In the event CCSH is entitled to refuse the request for access to the Personal Information, it will inform you of the reasons in writing unless it is otherwise precluded from doing so by law. If the information requested is not available you will be informed promptly in writing. If CCSH refuses the request for access it will advise of the right to make further inquiry with the appropriate governmental authority.

9.5 If you demonstrate to our satisfaction that your Personal Information that is held or controlled by us is inaccurate or incomplete, and give us the information necessary to correct the record, we will make appropriate amendments. These amendments may involve the correction, deletion, or addition of Personal Information.

ARTICLE 10 - COMPLAINTS PROCEDURE
10.1 In the event that you wish to enquire or complain about our Personal Information practices or our compliance with this Privacy Policy, a written enquiry or complaint should be sent to the attention of the Privacy Officer at the co­ordinates provided in Article 1 above. The Privacy Officer will investigate all complaints and respond to all written enquiries. If a complaint is found to be justified by the Privacy Officer, we will take all reasonable steps to amend our relevant privacy-related policies or procedures.

10.2 In addition to the rights that are provided to you in this Policy, if you believe that your Personal Information has been inappropriately dealt with in any respect, you have a right to bring a formal complaint to Ontario’s Information and Privacy Commissioner. You may contact this office toll-free at 1-800-387-0073.

D. CHANGES TO THIS POLICY
CCSH reserves the right to modify or supplement this Policy from time to time to respond to legislative or other changes.

FORMS & APPLICATIONS