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.
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
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
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
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.
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
• 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.
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
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
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.
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.
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.
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.
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
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