About the FVCDC
The FVCDC is committed to providing our clients with exceptional service. As providing this service involves the collection, use and disclosure or some personal information about our clients, protecting their personal information is one of our highest priorities.
While we have always respected our clients' privacy and safeguarded their personal information, we have strengthened our commitment to protecting personal information as a result of British Columbia's Personal Information Protection Act (PIPA). PIPA, which came into effect on January 1, 2004, sets out the ground rules for how B.C. not-for-profit organizations may collect, use and disclose personal information.
FVCDC will inform clients of why and how we collect, use and disclose their personal information, obtain consent where required and only handle their personal information in a manner that a reasonable person would consider appropriate in the circumstances.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices the FVCDC will follow in protecting clients' personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our clients' personal information and allowing our clients' to request access to, and correction of their personal information.
This Personal Information Protection Policy, in compliance with PIPA, also outlines the principles and practices the FVCDC will follow in protecting employees' and volunteers' personal information.
This Personal Information Protection Policy applies to Fraser Valley Child Development Centre and its contracted agents.
This policy also applies to any service providers collecting, using, disclosing or disposing of personal information on behalf of FVCDC.
Definitions:
Personal Information - means information about an identifiable individual, e.g. name, age, marital status, vehicle license, home address and phone number, physicians, and medical information. Personal information does not include contact information.
Contact Information - means information that would enable an individual to be contacted at a place of business. Contact information is not covered by this policy or PIPA.
Privacy Officer - means the individual designated responsibility for ensuring that FVCDC complies with this policy and PIPA.
Procedure 1:
1.1 Unless the purposes for collecting personal information are obvious, and the client (family) voluntarily provides his or her personal information for those purposes, FVCDC will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
1.2 FVCDC will only collect client, volunteer and employee information that is necessary to fulfill the following purposes:
To verify identity, we may collect name, address, home telephone number and birth date.
To verify eligibility for service, we may collect medical information, pre -and post-natal history, age, and impairments or disabilities.
To assess and provide appropriate therapy services, we may collect developmental information and complete standardized and non-standardized testing.
To determine appropriateness of volunteers, we may collect information and conduct reference and criminal record checks.
To provide employment, we may collect personal information for payroll and benefit purposes.
To provide employment, we may collect conduct reference and criminal record checks.
To provide emergency medical intervention for employees and volunteers, we may collect medical and health information.
Non-identifying statistical information may be collected, collated and distributed to support requests for funding, advocacy, resource allocation and measuring outcomes.
Procedure 2: Consent
2.1 FVCDC will obtain client consent to collect, use or disclose personal
information. Refer to: Operations: Intake Visit 3.2, Appendix HH
Guidelines for Consents
2.2 Consent can be provided orally and in writing or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the client voluntarily provides personal information for that purpose.
2.3 Subject to certain exceptions (e.g. the personal information is necessary to provide the service, clients can withhold or withdraw their consent for FVCDC to use their personal information in certain ways). A client’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service. If so, FVCDC will explain the situation to assist the client, in making the decision.
2.4 FVCDC may collect, use or disclose personal information without the client’s knowledge or consent in the following limited circumstances:
When the collection, use or disclosure of personal information is permitted or required by law;
In an emergency that threatens an individual’s life, health or personal security;
When the personal information is available from a public source (e.g.: a telephone directory);
When the FVCDC requires legal advice from a lawyer;
To investigate an anticipated breach of an agreement or a contravention of law.
Procedure 3: Using and Disclosing Personal Information
3.1 FVCDC will only use or disclose client, volunteer or employee personal information where necessary to fulfill the purposes identified at the time of collection.
To provide assessments, reports and appropriate services.
To communicate with other service providers who are providing services.
To conduct client, volunteer and employee surveys to enhance the provision of our services.
To contact clients regarding services, information and events that may be of interest.
To determine eligibility of services.
3.2 FVCDC will not use or disclose client, employee or volunteer personal information for any additional purposes unless we obtain consent to do so.
3.3 FVCDC will not sell client, employee or volunteer personal information to other parties.
Procedure 4: Retaining Personal Information
4.1 If FVCDC uses personal information to make a decision that directly affects the individual, FVCDC will retain that personal information for at least one year so that the individual has a reasonable opportunity to request access to it.
4.2 Subject to Procedure 4.1, FVCDC will retain personal information only as long as necessary to fulfill the identified purposes or a legal purpose.
Refer to: Administration: Client Filing System 2.15
Procedure 5: Ensuring Accuracy of Personal Information
5.1 FVCDC will make reasonable efforts to ensure that personal information is accurate and complete where it may be used to make a decision about the individual or disclosed to another organization.
5.2. Individuals may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information may be made to the service provider orally or in writing. A request to correct personal information may also be forwarded to the Privacy Officer if there is disagreement regarding the accuracy of the information.
5.3 If the personal information is demonstrated to be inaccurate or incomplete, FVCDC will correct the information as required and send the corrected information to the client and to any organization or individual to which the information was disclosed. If the correction is not made, FVCDC will note the clients' correction request in the file.
Procedure 6: Securing Personal Information
6.1 FVCDC is committed to ensuring the security of client, volunteer and employee personal information in order to protect it from unauthorized access, collection, use disclosure, copying, modification or disposal or similar risks.
6.2 FVCDC is committed to following security measures to ensure that client, volunteer and employee information is appropriately protected.
Refer to: Administration: Client Filing System 2.15, Legal: Confidentiality 4.3.
6.3 FVCDC will use appropriate security measures when destroying personal information such as shredding and deleting electronically stored information.
6.4 FVCDC will continually review and update our security polices and controls as technology changes to ensure ongoing personal information security.
Procedure 7: Providing Clients and Employees Access to Personal Information
7.1 Clients, volunteers and employees have a right to access their personal information, subject to limited exceptions. Refer to: Legal: FOI 4.12
7.2 A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought unless it is already information that has been given to the client or family, i.e.: therapist reports or consultation notes. Copies of reports or consultations will be provided to clients upon request to their therapist or consultant. A request to access personal information should be forwarded to the Privacy Officer. Refer to: Human Resources: Personnel Files 1.53
7.3 Upon request, the FVCDC will also tell clients how we use their personal information and to whom it has been disclosed if applicable.
7.4 FVCDC will make the requested information available within 30 business days, or provide written notice of an extension where additional time is required to fulfill the request.
7.5 If a request is refused in full or in part, we will notify the client in writing, providing the reasons for refusal and the recourse available to the client.
Procedure 8: Questions and Complaints: The Role of the Privacy Officer
8.1 The Privacy Officer (Executive Director) is responsible for ensuring FVCDC compliance with this policy and the Personal Information Protection Act.
8.2 Clients should direct any complaints, concerns or questions regarding FVCDC compliance to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the client may also write to: Office of the Information and Privacy Commissioner of British Columbia BP Box 9038, Stn.Prov.Govt. Victoria, BC V8W 1H2 Telephone: 250-387-5629 Fax: 250-387-1696 E-mail: HYPERLINK "mailto:infor@oipc.bc.ca" infor@oipc.bc.ca Website: www.oipc.bc.ca
FVCDC has a Policy and Procedure for Complaint Resolution, that shall be followed in the event of a disagreement between staff and clients regarding privacy issues.
Privacy Officer:
Karen McLean, Executive Officer
Fraser Valley Child Development Centre
#102-32885 Ventura Ave,
Abbotsford, BC V2S 6A3
604-852-2686 ext. 227
Personal Information Protection Act.