Deaf Access Simcoe Muskoka is committed to safeguarding the personal information entrusted to us by our consumers. We manage your personal information in accordance with Ontario’s Personal Health Information Protection Act (PHIPA) and other applicable laws. This policy outlines the principles and practices we follow in protecting your personal information.
This policy applies to Deaf Access Simcoe Muskoka and to any person providing services on our behalf. A copy of this policy is provided to any consumer or stakeholder upon request.
Personal information means information about an identifiable individual. This includes an individual’s name, home address and phone number, age, sex, marital or family status, an identifying number, financial information, medical information, etc.
We collect only the personal information that we need for the purposes of providing services to our clients and distributing information to our community members, including personal information needed to:
- Deliver requested products and services
- Determine eligibility for services
- Enroll a client in a program
- Send information related to the organization’s mandate (news, events, programs, workshops, etc.)
We normally collect client personal information directly from our clients. We may collect your information from other persons with your consent or as authorized by law.
We inform our clients, before or at the time of collecting personal information, of the purposes for which we are collecting the information. The only time we don’t provide this notification is when an individual volunteers information for an obvious purpose (for example, producing a credit card to pay a class fee when the information will be used only to process the payment).
We ask for consent to collect, use or disclose client personal information, except in specific circumstances where collection, use or disclosure without consent is authorized or required by law.
We may assume your consent in cases where you volunteer information for an obvious purpose.
We ask for your express consent for some purposes and may not be able to provide certain services if you are unwilling to provide consent to the collection, use or disclosure of certain personal information. Where express consent is needed, we will normally ask clients to provide their consent orally/in ASL (in person, by telephone, via Skype), or in writing (by signing a consent form).
A client may withdraw consent to the use and disclosure of personal information at any time, unless the personal information is necessary for us to fulfil our legal obligations. We will respect your decision, but we may not be able to provide you with certain products and services if we do not have the necessary personal information.
We may collect, use or disclose client personal information without consent only as authorized by law. For example, we may not request consent when the collection, use or disclosure is to determine suitability for an honour or award, or in an emergency that threatens life, health or safety.
We use and disclose client personal information only for the purpose for which the information was collected, except as authorized by law.
If we wish to use or disclose your personal information for any new purpose, we will ask for your consent.
Personal employee information is personal information about an employee or volunteer which is collected, used or disclosed solely for the purposes of establishing, managing or terminating an employment relationship or a volunteer work relationship. Personal employee information may, in some circumstances, include a Social Insurance Number, a performance review, etc.
We collect, use and disclose personal employee information to meet the following purposes:
- Determining eligibility for employment or volunteer work, including verifying qualifications and references
- Establishing training and development requirements
- Assessing performance and managing performance issues if they arise
- Administering pay and benefits (paid employees only)
- Processing employee work-related claims (e.g. benefits, workers’ compensation, insurance claims) (paid employees only)
- Complying with requirements of funding bodies (e.g. grants)
- Complying with applicable laws (e.g. Canada Income Tax Act, Ontario Employment Standards Act)
We only collect, use and disclose the amount and type of personal employee information that is reasonable to meet the above purposes. The following is a list of personal employee information that we may collect, use and disclose to meet those purposes.
- Contact information such as your name, home address, telephone number, email address
- Criminal background checks
- Employment or volunteer information such as your resume (including educational background, work history and references), reference information and interview notes, letters of offer and acceptance of employment, policy acknowledgement forms, background verification information, workplace performance evaluations, emergency contacts, etc.
- Benefit information such as forms relating to applications or changes to health and insurance benefits including medical and dental care, life insurance, short and long term disability, etc. (paid employees only)
- Financial information, such as pay cheque deposit information and tax-related information, including Social Insurance Numbers (paid employees only)
- Other personal information required for the purposes of our employment or volunteer relationship
We will inform our employees and volunteers of any new purpose for which we will collect, use, or disclose personal employee information, or we will obtain your consent, before or at the time the information is collected.
We will obtain your consent to collect, use and disclose your personal information for purposes unrelated to the employment or volunteer relationship (e.g. such as processing sales of goods or donations).
In some cases, after your employment or volunteer relationship with us ends, we will be contacted by other organizations and asked to provide a reference for you. It is our policy not to disclose personal information about our employees and volunteers to other organizations who request references without consent. We ask that those giving our name as a reference please notify us. The personal information we normally provide in a reference includes:
- Confirmation that an individual was an employee or volunteer, including the position, and date range of the employment or volunteering
- General information about an individual’s job duties and information about the employee or volunteer’s ability to perform job duties and success in the employment or volunteer relationship
We make every reasonable effort to ensure that personal information is accurate and complete. We rely on individuals to notify us if there is a change to their personal information that may affect their relationship with our organization. If you are aware of an error in our information about you, please let us know and we will correct it on request wherever possible. In some cases we may ask for a written request for correction.
We protect personal information in a manner appropriate for the sensitivity of the information. We make every reasonable effort to prevent any loss, misuse, disclosure or modification of personal information, as well as any unauthorized access to personal information.
We use appropriate security measures when destroying personal information, including shredding paper records and permanently deleting electronic records.
We retain personal information only as long as is reasonable to fulfil the purposes for which the information was collected or for legal or business purposes.
Individuals have a right to access their own personal information in a record that is in the custody or under the control of Deaf Access, subject to some exceptions. For example, organizations are required under the Personal Information Protection Act to refuse to provide access to information that would reveal personal information about another individual.
If we refuse a request in whole or in part, we will provide the reasons for the refusal. In some cases where exceptions to access apply, we may withhold that information and provide you with the remainder of the record.
You may make a request for access to your personal information in person or by writing to the Executive Director. You must provide sufficient information in your request to allow us to identify the information you are seeking.
You may also request information about our use of your personal information and any disclosure of that information to persons outside our organization. In addition, you may request a correction of an error or omission in your personal information.
We will respond to your request within 30 calendar days, unless an extension is granted. We may charge a reasonable fee to provide copies of information. We do not charge fees when the request is for personal employee information. We will advise you of any fees that may apply before beginning to process your request.
If you have a question or concern about any collection, use or disclosure of personal information by Deaf Access Simcoe Muskoka, or about a request for access to your own personal information, please contact the Executive Director. All concerns will be received and processed in accordance with the agency’s complaints process, as per our Consumer Complaint Policy.