QUAD COUNTY SUPPORT SERVICES

Personal Information Protection and Electronic Documents Act (PIPEDA) Policy

Policy Statement:

Quad County Support Services will comply with the Federal Personal Information Protection

and Electronic Documents Act (PIPEDA) as well as the Provincial Health Information Protection

Act, Bill 31 and any other Federal, Provincial and Municipal Privacy Laws.

Procedures

Quad County Support Services will follow the Canadian Standards Association’s Model Code

for the protection of personal information.

The 10 principals are as follows:

1. Accountability: Quad County Support Services is responsible for personal information

under its control and shall designate an individual or individuals who are accountable for

compliance with the following principles.

2. Identifying Purposes: The purposes for which personal information is collected shall be

identified by Quad County Support Services at or before the time the information is

collected.

3. Consent: The knowledge and consent of the individual are required for the collection,

use or disclosure of personal information, except when inappropriate.

4. Limiting Collection: The collection of personal information shall be limited to that

which is necessary for the purposes identified by Quad County Support Services.

Information shall be collected by fair and lawful means.

5. Limited Use, Disclosure, and Retention: Personal information shall not be used or

disclosed for purposes other than those for which it was collected, except with the

consent of the individual or as required by law. Personal information shall be retained

only as long as necessary for fulfillment of those purposes or as an Act(s) deems to be

required.

6. Accuracy: Personal information shall be accurate, complete, and up to date as is

necessary for the purposes for which it is to be used.

7. Safeguards: Personal information shall be protected by security safeguards appropriate

to the sensitivity of the information.

8. Openness: Quad County Support Services shall make readily available to individuals

specific information about its policies and practices relating to the management of

personal information.

9. Individual Access: Upon request, an individual shall be informed of the existence, use

and disclosure of his or her personal information and shall be given access to that

information. An individual shall be able to challenge the accuracy and completeness of

the information and have it amended as appropriate.

10. Challenging Compliance: An individual shall be able to address a challenge concerning

compliance with the above principles to the designated individual or individuals for Quad

County Support Services compliance.

Procedures

1. Privacy Officer

The person designated as the organization’s Privacy Officer for the purposes of this

policy and applicable legislation (Canada’s federal Personal Information Privacy and

Electronic Documents Act) will be the Administration Assistant. The Privacy Officer is

responsible for ensuring compliance with this policy and such legislation.

2. Personal Information

Personal Information provided to Quad County Support Services by both those

individuals receiving service and all employees will only be used for the following

purposes:

• To confirm the identity of the individuals receiving service and staff members

• To determine the qualifications and eligibility of individuals to receive service and be

• To fulfill legislated reporting requirements (such as but not limited to, ODSP, CPP,

• To protect Quad County Support Services, the individuals receiving service and the

• To provide a high quality of service for those individuals receiving service from Quad

offered employment EI, Income Tax) employees from any illegal activity County Support

Services’ staff having knowledge of the individual’s goals, wants and desires.

3. Consent

Quad County Support Services obtains the consent from those persons about to receive

services and new employees about to begin their employment (to collect, store, use and

exchange or disclose personal information for the above stated purposes) at the time the

individual first joins Quad County Support Services through the acceptance of the service

or hiring agreement. Those individuals already receiving service or are an employee will

grant this consent through the publication, distribution and acceptance of this privacy

policy.

4. Collection of Information

Quad County Support Services collects only that personal information necessary to

achieve the purposes set out above, from and about individuals receiving service or about

to receive service and prospective or present employees using only open, fair and lawful

means.

5. Use, Disclosure and Retention of Information

Quad County Support Services only uses the individual’s personal information (those

receiving service and employees) for the above stated purposes unless, if for another

separate purpose, separate explicit consent is obtained from the individual or unless

required or allowed by law. If an individual’s personal information is disclosed or

exchanged with another party, such as another service provider, Quad County Support

Services assumes that such party accepts and will comply with the provisions of PIPEDA

and other relevant governing legislation. Quad County Support Services will retain an

individual’s personal information as long as necessary to achieve the stated purposes

and to comply with legislation and regulations regarding records retention. When

information is no longer required to be kept, Quad County Support Services will destroy

paper files and purge electronic files in a secure way that will eliminate the possibility of

information contained in such files ever being accessible to anyone else.

6. Accuracy

Quad County Support Services will undertake its best efforts to maintain the accuracy

and currency of all personal information contained in its files and will update such

information promptly when advised by the individual of a change, or when Quad County

Support Services otherwise learns of change.

7. Safeguards

Quad County Support Services will store the personal information for files of those

receiving service and employees alike, both paper and electronic; in files which only

authorized personnel have access. The storage area will be locked filing cabinets and

computer files protected by passwords. All employees of Quad County Support Services

sign a letter of offer gaining employment in which they acknowledge their duties to abide

by all Quad County Support Services’ policies and related legislation. This signed

acknowledgment includes a confidentiality statement to the effect that all information

acquired during the course of performing one’s duties is strictly confidential and

breech of confidentiality can result in termination of employment. All members

of the Board of Directors also must sign a confidentiality agreement yearly.

8. Openness

This policy is publicly posted and accessible via Quad County Support Services’ Policy

and Procedure’s manuals located at all programs, and copies are available on request to

the Privacy Officer.

9. Individual Access

Upon the receipt of reasonable notice, both individuals receiving service and employees

alike may view the paper and electronic files maintained by Quad County Support

Services with their own personal information. The individual may review the

information contained in such files and comment of its accuracy, identify items of

information not correct or not current and make specific suggestion or request for their

proper revision. The individual has the right to a copy of all documents contained in the

files at their expense, except where prohibited by law.

10. Compliance

Those receiving service and employees alike may contact the Privacy Officer with

questions, suggestions or opinion with regard to Quad County Support Services’

compliance with this policy and relevant legislation. The Privacy Officer may be

contacted at 519-693-4812, or at 195 Wellington Street, Wardsville, Ontario between the

hours of 8:00 a.m. to 4:00 p.m., Monday to Friday. The Privacy Officer is responsible

for monitoring applicable legislation and taking such steps as required to ensure that

Quad County Support Services and this policy and its related practices, procedures

and safeguards remain in compliance. This responsibility will include suggesting

draft revisions of this policy for Board of Directors consideration and adoption at the

appropriate times.

Appendix to the Personal Information Protection and Electronic Documents Act (PIPEDA) Policy

Ministry of Community and Social Services Division

1. Authorization for Release and Exchange of Information

Ministry of Training Colleges and Universities Sector Division

1. Authority to Communicate Information

2. Consent to Collect Confidential Information (Centre for Lifelong Learning)

3. Consent to Collect Confidential Information (London Training Centre)

4. Consent to Collect Confidential Information (WIL Employment Connections)

5. Consent to Collect Confidential Information (Small Business Centre)

6. Release of Social Insurance Number Consent

7. DAYA Counselling Centre Release Form

_{Date of Implementation: May, 2009}

_{Date of Revision:}

_{Approved by Board: May 20, 2009}