At The Bridge Youth & Family Services Society, we are committed to providing our participants with exceptional service. As providing this service involves the collection, use and disclosure of some personal information about our participants and employees, protecting their personal information is one of our highest priorities.
While we have always respected our participants and employees’ 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. businesses and not-for-profit organizations may collect, use and disclose personal information.
Certain aspects of our operation, in particular children in care, continue to be governed by the Freedom of Information Act and Protection of Privacy Act (FOIPPA). While that legislation is similar to PIPA there are some differences. In the event of a conflict between PIPA (and this policy) the FOIPPA will prevail.
We will inform our participants and employees 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.
This Personal Information Protection Policy, in compliance with PIPA, outlines the principles and practices we will follow in protecting participants’ and employees’ personal information. Our privacy commitment includes ensuring the accuracy, confidentiality, and security of our participants’ and employees’ personal information and allowing our participants and employees to request access to, and correction of, their personal information.
Scope of this Policy
This policy also applies to any service providers collecting, using or disclosing personal information on behalf of The Bridge Youth & Family Services.
Personal Information –means information about an identifiable individual including name, age, home address and phone number, social insurance number, marital status, religion, income, credit history, medical information, education, employment information. Personal information does not include contact information (described below).
Contact information – means information that would enable an individual to be contacted at a place of business and includes name, position name or title, business telephone number, business address, business email or business fax number. Contact information is not covered by this policy or PIPA.
Privacy Officer – means the individual designated responsibility for ensuring that The Bridge Youth & Family Services complies with this policy and PIPA.
Participant – means someone who has requested or is receiving services of the Society or has received services of the Society. In this definition services includes services requested for or rendered to a relative, guardian, or other acquaintance of a participant. It also includes volunteers and supporters who assist the Society in carrying out its objects.
Collecting Personal Information
Unless the purposes for collecting personal information are obvious and the participant or employee voluntarily provides his or her personal information for those purposes, we will communicate the purposes for which personal information is being collected, either orally or in writing, before or at the time of collection.
Subject to the foregoing we will only collect participant information that is necessary to fulfill the following purposes as may be applicable:
- to verify identity;
- to identify participant preferences;
- to understand the needs of our participants;
- to deliver requested or required services;
- to provide counselling services;
- to send out the societies’ program information;
- to ensure a high standard of service to our participants.
Unless the need for the information is obvious we will only collect employee information that is necessary to fulfill the following purposes:
- to enroll the employee in benefit programs and provide information to statutory authorities requiring such information;
- to meet regulatory requirements;
- to assess suitability for employment;
- to manage the employment relationship.
We will obtain participant or employee consent to collect, use or disclose personal information (except where, as noted below, we are authorized to do so without consent).
Consent can be provided orally, in writing, electronically, through an authorized representative or it can be implied where the purpose for collecting using or disclosing the personal information would be considered obvious and the participant or employee voluntarily provides personal information for that purpose.
Consent may also be implied where a participant is given notice and a reasonable opportunity to opt-out of his or her personal information being used for mail-outs and the participant does not opt-out.
Subject to certain exceptions (e.g., the personal information is necessary to provide the service or maintain the employment relationship, or the withdrawal of consent would frustrate the performance of a legal obligation), participants and employees can withhold or withdraw their consent for The Bridge Youth & Family Services to use their personal information in certain ways. A participant or employee’s decision to withhold or withdraw their consent to certain uses of personal information may restrict our ability to provide a particular service or product. If so, we will explain the situation to assist the participant or employee in making the decision.
We may collect, use or disclose personal information without the participant or employee’s knowledge or consent in limited circumstances including:
- 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 we require legal advice from a lawyer;
- to a youth’s guardianship social worker, where the youth in care under a temporary or continuing custody order.
- for the purposes of collecting a debt;
- to protect ourselves from fraud;
- to investigate an anticipated breach of an agreement or a contravention of law;
- when the society is being monitored or evaluated (e.g. licensing, financial audits, accreditation reviews, contract monitoring by a funder.)
- to establish, mange, or terminate an employment relationship.
Using and Disclosing Personal Information
We will only use or disclose participant or employee personal information where necessary to fulfill the purposes identified at the time of collection or for a purpose reasonably related to those purposes such as:
- to conduct participant or employee surveys in order to enhance the provision of our services;
- compelling circumstances exist that affect the health or safety of any individual and if notice of disclosure is mailed to the last known address of the individual to whom the personal information relates;
- to contacting next of kin or a friend of an injured, ill or deceased individual;
- to a lawyer representing the organization;
- to an archival institution for research or archival purposes.
We will not use or disclose participant or employee personal information for any additional purpose unless we obtain consent to do so.
We will not sell participant or employee lists or personal information to other parties.
Retaining Personal Information
If we use participant or employee personal information to make a decision that directly affects the participant or employee, we will retain that personal information for at least one year so that the participant or employee has a reasonable opportunity to request access to it.
Subject to policy 4.1, we will retain participant or employee personal information only as long as necessary to fulfill the identified purposes or a legal or business purpose.
Ensuring Accuracy of Personal Information
We will make reasonable efforts to ensure that participant or employee personal information is accurate and complete where it may be used to make a decision about the participant or employee or disclosed to another organization.
Participants and employees may request correction to their personal information in order to ensure its accuracy and completeness. A request to correct personal information must be made in writing and provide sufficient detail to identify the personal information and the correction being sought.
A request to correct personal information should be forwarded to the Privacy Officer.
If the personal information is demonstrated to be inaccurate or incomplete, we will correct the information as required and send the corrected information to any organization to which we disclosed the personal information in the previous year. If the correction is not made, we will note the participant’s or employee’s correction request in the file.
Securing Personal Information
We are committed to ensuring the security of participant or employee personal information in order to protect it from unauthorized access, collection, use, disclosure, copying, modification or disposal or similar risks.
Participant files are kept locked in a file cabinet at the main office or a residential site. When files are removed they are checked out using a computerized monitoring system. Case records must not be left unattended in public areas, on desks, or in unsecured areas. When not in use by authorized personnel, files must be returned to a secure area. If files are moved from the building they are transported in a locked briefcase and returned within 24 hours. Outreach counsellors are issued a locking Society briefcase.
The following security measures will be followed to ensure that employee personal information is appropriately protected:
- the use of locked filing cabinets;
- physically securing offices where personal information is held;
- restricting employee access to personal information as appropriate (i.e., only those that need to know will have access; contractually requiring any service providers to provide comparable security measures).
We will use appropriate security measures when destroying participant or employee’s personal information.
Security measures are implemented and maintained on the Society’s computer system including:
- the use of user IDs, passwords, encryption and firewalls;
- access to the server is electronically monitored and unauthorized attempts at access are attended immediately.
- implementing the “account lockout” feature to lock out logon attempts after three failed attempts.
- all personnel who log on to the Society’s computer network must personally attend to the workstation at all times.
- should personnel leave their computer terminal they must log out or put their workstation on security mode.
We will continually review and update our security policies and controls as technology changes to ensure ongoing personal information security.
Providing Participants and Employees Access to Personal Information
Participants and employees have a right to access their personal information, subject to limited exceptions including:
- solicitor-client privilege;
- disclosure would reveal personal information about another individual or could threaten the safety of health of another individual;
- the disclosure would identify a confidential informant.
- the information was collected without consent for an investigation and the investigation and associated proceedings have not been completed;
A request to access personal information must be made in writing and provide sufficient detail to identify the personal information being sought. A request to access personal information should be forwarded to the Privacy Officer (or designated individual).
Upon request, we will also tell participants and employees how we use their personal information and to whom it has been disclosed if applicable. We will make the requested information available within 30 days, or provide written notice of an extension where additional time is required to fulfill the request. A minimal fee may be charged for providing access to personal information. Where a fee may apply, we will inform the participant or employee of the cost and request further direction from the participant or employee on whether or not we should proceed with the request.
If a request is refused in full or in part, we will notify the participant or employee in writing, providing the reasons for refusal and the recourse available to the participant or employee.
Questions and Complaints: The Role of the Privacy Officer or designated individual
The Privacy Officer is responsible for ensuring The Bridge Youth & Family Services’ compliance with this policy and the Personal Information Protection Act.
Participants and employees should direct any complaints, concerns or questions regarding The Bridge Youth & Family Services’ compliance in writing to the Privacy Officer. If the Privacy Officer is unable to resolve the concern, the participant or employee may also write to the Information and Privacy Commissioner of British Columbia.
Contact information for The Bridge Youth & Family Services’ Privacy Officer
Leigh MacLeod, Program Manager, Youth Young Adult Initiatives
The Bridge Youth & Family Services Society
760 Highway 33 W
Kelowna, BC V1X 1Y4
Phone: 250-763-0456, ext 2225
Email: [email protected]