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Privacy Policy

Purpose

Caledon Community Services (CCS) strives to ensure that the privacy of all CCS clients, staff, volunteers, program/student placements, donors and other stakeholders is respected and protected.

Your privacy is very important to us. Accordingly, we have developed this Policy in order for you to understand how we collect, use, communicate and disclose and make use of personal information. The following outlines our privacy policy.

Before or at the time of collecting personal information, we will identify the purposes for which information is being collected.

We will collect and use of personal information solely with the objective of fulfilling those purposes specified by us and for other compatible purposes, unless we obtain the consent of the individual concerned or as required by law.

We will only retain personal information as long as necessary for the fulfillment of those purposes.

We will collect personal information by lawful and fair means and, where appropriate, with the knowledge or consent of the individual concerned.

Personal data should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes, should be accurate, complete, and up-to-date.

We will protect personal information by reasonable security safeguards against loss or theft, as well as unauthorized access, disclosure, copying, use or modification.

We will make readily available to customers information about our policies and practices relating to the management of personal information.

We are committed to conducting our business in accordance with these principles in order to ensure that the confidentiality of personal information is protected and maintained.

Policy

CCS is committed to developing, implementing and maintaining systems and procedures in order to protect the personal information of all of its stakeholders in accordance with provincial privacy legislation. All CCS staff, volunteers, and program/student placements shall be expected to strictly adhere to CCS privacy policies and procedures. CCS privacy policies and procedures shall serve to protect the privacy of personal information belonging to the following parties:

Clients, Student/Program Placements, Staff, Donors, Volunteers, CCS website users

Clients

CCS collects personal health information about the client directly from the client, or from the person acting on behalf of the client in compliance with the Personal Health Information Protection Act (PHIPA). The personal health information that CCS may collect includes:

Client’s name, Date of birth, Address Phone number, E-mail address, Health history, Records of visits and other interactions with CCS, Emergency Contact Information.

If required, CCS collects personal health information about the client from other sources where we have obtained the client’s consent to do so or where the law permits.

CCS uses and discloses clients’ personal and/or personal health information to:

  • Provide services for the client such as personal care giving, transportation; counseling and care coordination, employment assistance for individuals needing accommodations due to a disability, etc;
  • Plan, administer and manage our internal operations;
  • Conduct risk management and quality improvement activities;
  • Ask clients for feedback about the services they have already received as part of our quality assurance commitment;
  • Compile statistics;
  • Comply with legal and regulatory requirements
  • Fulfill other purposes permitted or required by law;

Client Rights

Under Ontario law clients have every right to:

  • Know how CCS collects, uses, discloses and stores their personal health information;
  • Expect that any personal health information held by CCS remains accurate, confidential and secure;
  • Expect that their personal health information remains private. CCS will not share personal information with others without client consent unless we are permitted or required to by law;
  • Look at or receive a copy of their personal health information and ask CCS to correct their personal health information record. Kindly make these requests in writing to Caledon Community Services;
  • Ask questions or make a complaint to our Privacy Officer about our privacy practices;
  • Withdraw their consent (if the law allows) for some of the above uses and disclosures by contacting CCS in writing;

Staff/Volunteers/Student/Program Placements

CCS will inform its staff (or applicants for employment), volunteers, student and program placements of why and how we collect, use and disclose their personal information, obtain their consent where required, and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.

Unless the purposes for collecting personal information are obvious and the applicant, staff, volunteer, student or program placement voluntarily provides their personal information for those purposes, CCS will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection. We will only collect applicant/staff/volunteer/student/program placement information that is necessary to fulfill the following purposes;

  • To assess suitability for employment or volunteer/student/program placement;
  • To verify identity;
  • To verify credentials;
  • To check for relevant criminal records;
  • To send out information;
  • To meet regulatory requirements (i.e. Canada Revenue Agency (CRA) requirements) (for paid staff/program placements);
  • To process payroll and/or benefits (for paid staff/program placements);
  • To assess eligibility for benefits (for paid staff);To substantiate and/or arrange for accommodations in accordance with the Ontario Human Rights Code (OHRC);

In order for Caledon Community Services to employ (or continue to employ) staff members and to look after their well-being and to provide quality services, CCS collects and uses certain Staff Personal Information, that may include:

  • Home address and telephone number;
  • Date of Birth;
  • Gender;
  • Social Insurance Number (for Canada Revenue Agency requirements)
  • Marital status;
  • Photograph (for I.D. badges);
  • Bank account number (for direct deposit of pay);
  • Earnings
  • Driving record history (abstract);
  • Driver’s license copy/number;
  • Criminal Records Check (Vulnerable Sector);
  • Functional Abilities Information (for sick leave/ STD/LTD/WSIB claims or accommodation for a disability);
  • Limited information about spouses/partners/dependants for benefits or RRSP;
  • Personal and professional references;
  • Attendance records;
  • Performance summaries and ratings;
  • Career goals and objectives.

Donors

The privacy and security of donors’ personal information is important to Caledon Community Services. Caledon Community Services (CCS) respectsits donors’ right to privacy and is committed to protecting the personal information that donors provide to the agency.

The information collected is used:

  • To facilitate donation collection and processing
  • To provide tax receipts
  • To communicate relevant news and updates

CCS does not trade, license, rent or sell our donors’ personal information in any manner.

CCS Website Users

Individuals can browse our website without disclosing their personal data. Any personal information that site visitors voluntarily choose to provide in order to complete any of our online application forms, set up a profile with our Jobs Caledon on-line job board, make donations or request information, etc IS NOT shared with third parties unless stated otherwise. CCS will ensure all personal information is secured and remains confidential.

CCS’s Use of Cookies: A cookie is a small text file containing a unique identification number that is transferred from a website to the hard drive of your computer so that the website may identify separate visitors to the site and track users’ activities on the website. A cookie will not let a website know any personally identifiable information about website visitors, such as their real name and address. CCS uses cookies only to keep track of how many people visited the website and how frequently each page is visited. Each individual movement of any user cannot be tracked while on CCS’s site. Cookies are only used to track page popularity for statistical purposes and to improve the quality of the site and meet website user needs.

Links on our Website: CCS wants our website users’ experience to be informational and resourceful; therefore our website also provides a number of links to third party sites. CCS assumes no responsibility for the information practices of sites that our users are able to access through our site. We encourage our website users to review each site's privacy policy before disclosing any personally identifiable information.

Safeguards

CCS employs a number of safeguards to protect your personal information against loss or theft, as well as unauthorized access, disclosure, copying, use, or modification. Such safeguards include physical measures, for example locked filing cabinets, restricted access to offices, and limiting access on a “need to know” basis, and use of passwords and encryption.

Exceptions

Caledon Community Services does not disclose any private information regarding individuals without informed consent, unless it is required or permitted by law.

Raising Concerns or Complaints about Compliance to this Policy

If, for any reason, you are concerned about our compliance with our Privacy Policy, you may contact our Privacy Officer in writing, by mail or by email. CCS has policies and procedures to receive, investigate and respond to individuals’ complaints and questions. If you are not satisfied with the way CCS has responded to a complaint, you can contact the Privacy Commissioner of Canada. This Privacy Policy may be updated from time to time and will be posted on our website.

Contact Information for the CCS' Privacy Officer:

Nancy Kopriva, Manager, Human Resources

Privacy Officer

18 King Street East, Bolton, ON L7E 1E8

E-mail: email hidden; JavaScript is required

References

CCS Policies and Forms:

Complaint/Satisfaction Form

Privacy and Confidentiality Agreement

Incident Investigation Report

Personnel Records Policy –Staff and Program Placements

Personnel Records Policy –Volunteers and Student Placements

CCS Donor Bill of Rights

Privacy Complaint Investigation Procedure

Legislation:

Employment Standards Act of Ontario

PIPEDA –Personal Information and Electronic Documents Act

PHIPA –Personal Health Information Protection Act

PIPA –Personal Information Protection Act

FIPPA-Freedom of Information and Protection of Privacy Act

Health Services Operational Policies –Personal Health Information Privacy

Date Developed: February 26, 2016

Date Approved: March 2016

Date Reviewed: September 2017, September 2018, September 2019,

Web Site Terms and Conditions of Use

1. Terms

By accessing this web site, you are agreeing to be bound by these web site Terms and Conditions of Use, all applicable laws and regulations, and agree that you are responsible for compliance with any applicable local laws. If you do not agree with any of these terms, you are prohibited from using or accessing this site. The materials contained in this web site are protected by applicable copyright and trademark law.

2. Use License

Permission is granted to temporarily download one copy of the materials (information or software) on Caledon Community Services’ web site for personal, non-commercial transitory viewing only. This is the grant of a license, not a transfer of title, and under this license you may not:

  • modify or copy the materials;
  • use the materials for any commercial purpose, or for any public display (commercial or non-commercial);
  • attempt to decompile or reverse engineer any software contained on Caledon Community Services’ website;
  • remove any copyright or other proprietary notations from the materials; or transfer the materials to another person or “mirror” the materials on any other server.

This license shall automatically terminate if you violate any of these restrictions and may be terminated by Caledon Community Services at any time. Upon terminating your viewing of these materials or upon the termination of this license, you must destroy any downloaded materials in your possession whether in electronic or printed format.

3. Disclaimer

The materials on Caledon Community Services’ web site are provided “as is”. Caledon Community Services makes no warranties, expressed or implied, and hereby disclaims and negates all other warranties, including without limitation, implied warranties or conditions of merchantability, fitness for a particular purpose, or non-infringement of intellectual property or other violation of rights. Further, Caledon Community Services does not warrant or make any representations concerning the accuracy, likely results, or reliability of the use of the materials on its Internet web site or otherwise relating to such materials or on any sites linked to this site.

4. Limitations

In no event shall Caledon Community Services or its suppliers be liable for any damages (including, without limitation, damages for loss of data or profit, or due to business interruption,) arising out of the use or inability to use the materials on Caledon Community Services’ Internet site, even if Caledon Community Services or a Caledon Community Services authorized representative has been notified orally or in writing of the possibility of such damage. Because some jurisdictions do not allow limitations on implied warranties, or limitations of liability for consequential or incidental damages, these limitations may not apply to you.

5. Revisions and Errata

The materials appearing on Caledon Community Services’ web site could include technical, typographical, or photographic errors. Caledon Community Services does not warrant that any of the materials on its web site are accurate, complete, or current. Caledon Community Services may make changes to the materials contained on its web site at any time without notice. Caledon Community Services does not, however, make any commitment to update the materials.

6. Links

Caledon Community Services has not reviewed all of the sites linked to its Internet web site and is not responsible for the contents of any such linked site. The inclusion of any link does not imply endorsement by Caledon Community Services of the site. Use of any such linked web site is at the user’s own risk.

7. Site Terms of Use Modifications

Caledon Community Services may revise these terms of use for its web site at any time without notice. By using this web site you are agreeing to be bound by the then current version of these Terms and Conditions of Use.

8. Governing Law

Any claim relating to Caledon Community Services’ web site shall be governed by the laws of the Province of Ontario without regard to its conflict of law provisions.

General Terms and Conditions applicable to Use of a Web Site.

COMPLAINTS

Purpose

Caledon Community Services (CCS) has a responsibility to respond promptly and effectively to any complaint made by persons served, their family member, member of the community. CCS commits to reviewing all complaints in a fair, transparent, confidential and timely manner. CCS recognizes that complainants have the right to appeal the results of CCS’ decision.

Policy

CCS’ complaints policy sets forth conditions that will be upheld, and outlines a procedure for dealing with complaints.

CCS recognizes that any effective conflict resolution process is based on principals and rights of administrative fairness. These include:

  • Individuals have a right to fair and equitable service;
  • The complaints process is an integral component of overall quality assurance.
  • The need for and the benefit of accountability to our clients, families and to the general public;
  • The complaints process must be accessible to all persons
  • The use of plain language when it will help the person served communicate more effectively;
  • Forms used in the complaints process are to be in a simple, straightforward format;
  • A person who has a disability or is from any ethnic or racial minority may bring an interpreter/translator and can rely on their services at any stage throughout the complaints process;
  • Any meetings or hearings forming part of the complaints process shall be held in a place that is accessible to those who are mobility restricted
  • Complainants have the right to be accompanied at all stages in the complaints process by an advocate or support person;
  • Complainants have a right to complain as recipients of services. They should not fear reprisals as a result of initiating a complaint;
  • Staff, volunteers, program/student placements and clients will be encouraged and will have the opportunity to respond to complaints and/or correct the issue at hand locally before proceeding to a further stage in the complaints process. This does not apply in situations involving criminal acts or suspected client abuse, which the CCS stakeholder has an obligation to report immediately to the Supervisor/Manager;

Procedures

CCS’ clients will be informed of our procedures regarding complaints about our programs or services. Our Complaint Policy and Complaint Satisfaction Form will be posted on our website.

Informal Complaints

An informal complaint is a comment on an operational matter that can be readily resolved by a program coordinator or staff, volunteer, program/student placement.

All managers are to summarize the number of complaints on the first tab of the records document at the end of each month. Health Services will log their complaints on GoldCare but still report number of complaints at the end of each month on the records document.

Formal Complaints

A formal complaint is where the complainant wishes the issue to be referred to management and/or any complaint that relates to CCS’ policy, procedures or individual/public safety.

Formal complaints will be managed by the Program Manager, Division’s Director, CEO or the Chair of the Board as applicable.

Formal complaints regarding the actions or decisions of any CCS staff, volunteer, program/student placement, service or program shall be reported to the Program Manager who shall document the complaint in writing on the Complaint Satisfaction Form and submit it to their Division Director within 48 hours of the complaint being made.

Formal Complaints procedures involve:

  • A completed Complaint Satisfaction Form
  • Investigation of the allegations
  • Making a finding
  • Submitting a report with a recommended course of action to the appropriate decision-maker
  • Implementation of an appropriate outcome
  • Informing the complainant of outcomes of their complaint and any changes to policy, procedures, services or programs as a result of their complaint

Investigation of the allegations must include:

  • The complainant be interviewed and the allegations particularized in writing
  • The allegations are conveyed to the alleged party in full
  • The alleged party is given the opportunity to respond and defend themselves
  • If there is a dispute over facts, statements from any witnesses and other relevant evidence is gathered

The Divisional Director, CEO or designate will investigate following the procedures set out in the Workplace Incident Investigation Policy.

CCS commits to informing the complainant of the outcome within twenty (20) business days. Complainants will be provided clear and understandable reasons for decisions relating to the complaint.

Appeal Process

  • If the outcome of the complaint does not satisfy the complainant, then the CEO shall designate a third party who will have responsibility for hearing, reviewing and resolving the complaint. The designated third party should not have a direct line of responsibility over the area, person or subject of the complaint;
  • If the complaint is still not resolved to satisfaction, then the CEO shall direct the complainant to an appropriate outside source.

Quality Assurance

On an annual basis, the Senior Management Team will review all formal complaints to determine trends, areas needing performance improvement, and actions to be taken, if applicable.

References: Complaint/Satisfaction Form

Workplace Incident Investigation Policy

Date Developed: January 2016

Date Approved: February 2016

Date Reviewed: March 2017, March 2018, March 2019, March 2020, March 2021, March 2022