Your Privacy Is Important

At Children First, we respect and protect the privacy of those who are involved with our agency (e.g., clients, referral sources, donors, staff, board members, volunteers, students, consultants, and candidates for employment). We are committed to meeting the highest standards of ethics with respect to the collection, use, disclosure, and security of personal information,* and we are striving to ensure our policies meet or exceed the privacy standards established by relevant legislation, standards, and guidelines, including Ontario’s Personal Health Information Protection Act, 2004 and the Child and Family Services Act, 1990 (as amended).

This statement provides general information about our policies and procedures with respect to collecting, using, disclosing, and maintaining personal information.* It also provides information about accessing personal information and requesting correction of recorded information.

*With some exceptions identified by legislation, ‘personal information’ in this statement is used broadly to refer to information that can be used to distinguish, identify, or contact a specific individual.

The Information We Collect

The type of personal information we collect varies depending upon the individuals involved and the nature of their relationships with Children First.

For clients (children and their families), personal information may include names, addresses, phone numbers, dates of birth, and personal/family information related to assessment, consultation, programming, and treatment. By law, and in accordance with professional standards, we are required to keep a record of our services to, and contacts with, clients. Client records include:missionguy_kite

  • Referral information
  • Information that a family has provided to us or authorized us to receive
  • Family service plans
  • Results of any assessments or consultations
  • Consent forms
  • Contact notes
  • Progress summaries
  • Service-related correspondence that we have sent or received

The physical service records are retained by our agency; however, as discussed later, clients have rights regarding access to information and disclosure of information from their records.

For referral sources (i.e., those contacting our agency to make referrals on behalf of children and their families), we collect personal information that may include names, addresses, phone numbers, and employment designations. This information is collected for the purposes of identifying and initiating contact with the children’s families.

For donors, we collect personal information that may include names and addresses. This information is collected to acknowledge donations and for accounting purposes.

For staff, board members, volunteers, students, consultants, and candidates for employment, we collect personal information that may include names, addresses, resumes, proof of professional education/registration, and criminal reference check information.

Personal information is collected directly from the individuals involved with Children First (or from the person who is lawfully entitled to give, withhold, or withdraw consent on that person’s behalf) except:

  • When the individuals have provided consent to obtain the information from others (e.g., reports from other service providers, child care centers, schools, etc.)
  • Where the law requires or allows us to collect information without consent (e.g., in urgent situations, where information is needed to prevent potential harm).

Whether we collect information directly or from third parties, we collect only information that we believe is reasonably necessary for the intended purposes.

How We Use the Information

Our use of personal information varies depending upon the individuals involved and the nature of their relationships with Children First. For example:

Personal information related to clients and their referral sources may be used:

  • To provide the assessment, programming, and treatment services that have been requested
  • To maintain contact for service-related purposes, or for future consent purposes
  • To offset harm (e.g., asking for emergency contacts)
  • For quality assurance purposes (e.g., to allow us to evaluate the effectiveness of our services and improve them)
  • To comply with legal, regulatory, and accreditation requirements
  • To contact individuals regarding upcoming events, activities, and services that may be of interest
  • For research purposes*

Personal information related to donors may be used:

  • To issue charitable tax receipts and acknowledge donations
  • To share information regarding upcoming events, activities, and services that may be of interest
  • For future fundraising purposes
  • To comply with legal and regulatory requirements

Personal information related to staff, board members, consultants, volunteers, students, and candidates for employment may be used:

  • In the course of conducting Children First’s regular business practices
  • To comply with legal, regulatory, and accreditation requirements
  • For research purposes*

*Aggregate or anonymous information that will not be linked to identified individuals may be used for research and program evaluation purposes, as well as for the education and professional development of our trainees and staff. In the case of specific research initiatives requiring individuals’ direct participation or identifying information, we are governed by specific research policies and will obtain informed consent as required. If individuals decide that they do not want to participate in research for which consent is required, they are free to decline with no impact on their relationship with our agency.

Children First does not use personal information for purposes other than those for which it was originally collected without consent, nor does our agency use more information than is reasonably necessary for the intended purposes.

Personal information held by Children First is only accessed by our staff members on a “need-to-know” basis. For example, this means that staff members involved in human resources only access the personal information needed to carry out their functions. They do not access other information.

How We Share the Informationshutterstock_71224573-350px-300x240

Personal information related to clients and their referral sources:

  • With very few exceptions, we do not share the personal information of our clients or their referral sources* with anyone outside of Children First without obtaining consent from the individual to whom the information pertains (or the consent of another person who is lawfully entitled to give, withhold, or withdraw consent on that person’s behalf [e.g., a parent, with some exceptions])
  • Our processes for obtaining consent for the disclosure of clients’ personal information are in keeping with legal and professional requirements. Obtaining the appropriate consent for the release of clients’ personal information typically includes ensuring their awareness and agreement as to:
    • The nature of the personal information to be disclosed
    • The manner in which the personal information will be disclosed
    • The purpose of the disclosure
    • The person or body to whom the personal information will be disclosed
    • The time frame during which the personal information will be disclosed
    • The anticipated risks and benefits of the disclosure
  • Exceptions to typical consent procedures occur only as required or permitted by law and ethical standards, such as:
    • In situations of suspected child abuse or neglect
    • In situations of imminent harm (e.g., where there is a clear and imminent risk of serious bodily harm to someone, including the possibility of self-harm)
    • Mandatory reporting by regulated health professionals of another regulated health professional who has sexually abused a client
    • In the context of legal proceedings (e.g., to comply with a summons or order issued by a person with jurisdiction to compel the disclosure)
    • To comply with the requirements of our accreditors and professional regulatory bodies
    • In the course of consultation with our agents (e.g., legal counsel)
    • To researchers, where legislative provisions and specific policies are met**
  • The above exceptions are called “limits of confidentiality” if there are other limits of confidentiality that are identified as relevant in a particular situation, we will identify and discuss them with clients as they arise

Personal information related to donors:

  • We do not rent, sell, or trade our donor lists, and we typically do not release personal information about our donors without obtaining their consent (or the consent of another person who is lawfully entitled to give, withhold, or withdraw consent on their behalf)
  • In the case of donors, exceptions to typical consent procedures occur only as required or permitted by law, such as:
    • In the context of a legal proceeding (e.g., to comply with a summons, order, or similar requirement issued by a person with jurisdiction to compel the disclosure)
    • To comply with the requirements of auditors

Personal information related to staff, board members, consultants, volunteers, students, and candidates for employment:

  • With very few exceptions, we do not release the personal information of personnel without the consent of the individual (or the consent of another person who is lawfully entitled to give, withhold, or withdraw consent on that person’s behalf) except as required in the course of conducting regular business practices (e.g., to agents of the organization, such as group insurance providers)
  • Exceptions to typical consent procedures occur only as required or permitted by law, such as:
    • In situations of suspected abuse, neglect, or imminent harm (e.g., when there is a clear and imminent risk of serious bodily harm to someone, including the possibility of self-harm)
    • Mandatory reporting of a regulated health professional who has sexually abused a client
    • In the context of legal proceedings (e.g., to comply with a summons or order issued by a person with jurisdiction to compel the disclosure)
    • To comply with the requirements of our accreditors and professional regulatory bodies
    • In the course of consultation with our agents (e.g., legal counsel)
    • As required by the Occupational Health and Safety Act
    • To researchers, where legislative provisions and specific policies are met**
  • The above exceptions are called “limits of confidentiality” if there are other limits of confidentiality that are relevant to a particular situation, we will identify and discuss them with the personnel to whom they may pertain

*Typically, the type of information provided to our agency by referral sources includes personal information (e.g., their names, business names, addresses, phone numbers, and employment designations). However, this information is not usually personal health information. Information regarding referrals, including the referral source, contact information, and reason for referral, will be included in client files, and may also appear in materials (e.g., assessment reports) that are released to third parties.

**Aggregate or anonymous information that will not be linked to identified individuals may be shared for research and program evaluation purposes. In the case of specific research initiatives requiring individuals’ direct participation or identifying information, we are governed by specific research policies and will obtain informed consent as required. If individuals decide that they do not want to participate in research for which consent is required, they are free to decline with no impact on their relationship with our agency.

Those with whom personal information is shared cannot use or disclose the information for any purpose other than that for which it was shared except as required or permitted by law.

Safeguards and Security

Personnel and agents of Children First, as well as accreditors and professional regulatory bodies, are bound by confidentiality with respect to the personal information obtained in the course of their work with our agency. This is effective upon the commencement of their involvement with our agency and continues indefinitely upon their departure.

Children First does not permit identifiable records that are accessed for external purposes (e.g., auditing, licensing, research, or accreditation purposes) to be removed from our premises except as required by law.

Children First’s personnel are trained in the need for privacy and confidentiality. They are also trained in our agency’s privacy policies and procedures, including the prevention of record loss and unauthorized access.

Personnel who know a client personally are required to declare this and to remove themselves from access to that client’s record unless there is an emergency or unless the client has given express consent for access.

Personal information may be stored in paper and/or electronic forms. All information is protected by physical and electronic security measures appropriate to the nature of the information, and is accessible only by authorized personnel. In the event that personal information is stolen, lost, or improperly accessed, the individual to whom the information pertains (or the person who is lawfully entitled to give, withhold, or withdraw consent on that person’s behalf) will be notified.

Retention and Disposition of Personal Information

We keep personal information in active files or systems only as long as needed to meet the purposes for which it was collected, as required by law or agency policy, or, where applicable, for the appropriate statute of limitations period (e.g., client records are typically retained for 30 years following the date of discharge). Client and personnel records are retained in secure storage and disposed of in a secure manner.

Access to Personal Information

Individuals (or the persons who are lawfully entitled to give, withhold, or withdraw consent on their behalf) have the right to access and request copies of their (or their children’s) personal information that is held by Children First and to verify or correct this information (see Accuracy of Personal Information). As set out by legal and regulatory requirements, there are very few exceptions to this rule and specific policies and procedures regarding such matters exist within Children First. Exceptions may include:

  • Legal restrictions on parents’ and guardians’ access to the personal records of children; if this is the case in a situation, we will provide further information
  • Access to confidential information about a person other than the person (or child of the person) requesting access, access to raw data from psychological assessments, information provided in confidence by a third party, and information that could result in serious harm to someone’s treatment or recovery, or in serious bodily harm to someone

Individuals may request access to, and copies of, their personal information at any time by contacting Children First’s Privacy officer at (519) 250-1850 or privacyofficer@children-first.ca Clients who are currently involved with our program may also speak to their primary worker regarding requests to access their personal information.

Children First may charge a reasonable fee to cover copying costs, which, if applicable, will be discussed before the copying is completed on an individual’s behalf.

Accuracy of Personal Information

Children First has policies and procedures to ensure records of personal information are completed and maintained promptly, accurately, and completely. We encourage individuals to advise us of any changes to personal information that is relevant to their relationship with our agency, and we will respond promptly when advised that our records are inaccurate or incomplete. Upon request, records will be corrected or statements of disagreement will be attached. Depending on the circumstances (e.g., upon an individual’s request), notification of changes or addendums may be provided to those with whom the information is, or has been, disclosed.

Policy Review and Amendments

At Children First, we review policies and procedures on an ongoing basis and may amend these from time to time. If such amendments significantly alter how we use, maintain, or disclose previously collected personal information, we will inform those affected and obtain consent where required.

You have the Right to Provide, Withdraw,* or Refuse Consent

Clients and their referral sources have the right to withhold or withdraw* consent for Children First to collect, use, or disclose their personal information in situations in which consent is required. In such circumstances, it is possible that we may not have sufficient information to provide services to clients. Additionally, if clients restrict us from sharing all or part of their personal information with another health service provider, and it is our opinion that the information is reasonably necessary for that provider to provide appropriate service, we are required by law to inform that provider that consent has been withheld to disclose some needed information.

Where staff, board members, consultants, volunteers, students, or candidates for employment choose not to provide, or withdraw,* consent to collect, use, or disclose personal information, Children First may not be able to employ or place the individuals, or to carry on with the normal course of business (e.g., providing the individuals with benefits).

*Please note that withdrawals of consent are not retroactive; for example, where a disclosure has occurred on the basis of consent, Children First is not required to retrieve the information that was disclosed.

Questions/Concerns

Children First recognizes that individuals may have questions or concerns about privacy at our agency (e.g., regarding the collection, use, security, and disclosure of personal information). We have appointed a Privacy Officer to ensure our compliance with the laws of Ontario (as well as with professional regulations and ethical standards), to provide further information about our practices, and to receive and respond to complaints. Please contact:

Privacy Officer Children First 3295 Quality Way Windsor, ON N9T 3R9 Phone: (519) 250-1850 E-mail: privacyofficer@children-first.ca

In addition to contacting our Privacy Officer, you may obtain further information about the laws and regulations that are applicable to personal information in Ontario at the Websites of the Ontario Ministry of Health and Long Term Care (http://www.health.gov.on.ca/) and the Information and Privacy Commissioner of Ontario (http://www.ipc.on.ca/).

To exercise your right to contact the Information and Privacy Commissioner of Ontario about Children First’s treatment of your personal information (e.g., in the event of a problem that you have not been able to resolve directly with us), please contact:

Information and Privacy Commissioner/Ontario 80 Bloor Street West, Suite 1700 Toronto, ON M5S 2V1 Phone: (416) 326-3333 E-mail: commissioner@ipc.on

Privacy Statement Disclaimer

Please note that this Privacy Statement provides general information only. As noted throughout this document, there may be exceptions (e.g., legally required or permitted) that pertain to our collection, use, and disclosure of personal information, or to access of personal information, that have not been outlined in this document.

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