Effective January 1, 2004, the Personal Information Protection and Electronic Documents Act (PIPEDA) went into effect. This Act regulates Umbrella’s collection and use or disclosure of personal information in the course of our activities.
Personal information includes any factual or subjective information, recorded or not, about an identifiable individual. This includes information in any form such as a person’s e-mail address, food allergies, person’s age, home address and so on. It does not include the name, title or business address or business telephone number of an employee of an organization.
Protecting Personal Information
The Executive Director, Coordinator or Centre Director may be delegated to either act on behalf of Umbrella or to take responsibility for occasional collection, use and disclosure of personal information.
We understand the importance of protecting personal information. For that reason Umbrella has taken the following steps.
- Paper information is either under supervision or secured in a locked or restricted area.
- Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords are used on computers, telephone voice mail, and cell phones
- Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
Staff are trained to collect, use, and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy.
External consultants and agencies with access to personal information must enter into privacy (confidentiality) agreements with us.
Does Umbrella disclose personal information?
We disclose personal information
- To institutions providing Umbrella with payroll and banking services
- To assist with collection of outstanding child care fees
- To our auditors, and
- To third parties for processing of data (e.g. hardware and software support)
Unless required to do so by law, Umbrella does not currently disclose the personal information under its control to any other parties. It does not trade, sell, barter, or give away its client information to anyone. Should it be necessary in the future to make such a disclosure, Umbrella will not do so without the express consent of the individuals involved.
How do individuals provide Umbrella with their consent for the collection, use and disclosure of their personal information?
When families seek the services of Umbrella they provide their personal information expressly through a registration/referral process. Umbrella then has access only to the personal information provided by the client that is required to fulfill the purposes stated above. A client may withdraw their consent at any time upon reasonable notice, subject to legal or contractual restrictions. Please note however, that due to our statutory and regulatory obligations withdrawing consent may affect our ability to continue to provide a client with the services they have or would like to receive.
How much personal information does Umbrella collect, use or disclose?
Umbrella collects, uses and discloses the personal information it requires only in order to fulfill the purposes listed above, and no more.
Retention and destruction of personal information
Umbrella only retains personal information fot as long as is required to fulfill the purposes listed above. For example, regulations stipulate that we keep a child's file for two years after they have been discharged from a child care program. However, many of our programs retain information longer than this two year period (for example, programs where children may use the service more than once). The Canada Revenue Agency requires us to keep financial records (e.g. child care billings) for six years plus the current year.
How accurate is the personal information collected, used and disclosed by Umbrella?
Umbrella makes every effort to ensure the personal information it collects, uses and discloses is as accurate and up-todate as is required to fulfill the purposes listed above. If an individual's personal information requires amendment, they need only contact Umbrella to ensure that the correction is made.
When a file is no longer needed it is either destroyed or all personal identifiers are removed in such a way as to prevent accidenta.1 disclosure.
How secure is the personal information stored at Umbrella?
Umbrella is committed to ensuring that personal information is protected from unauthorized access, unintended disclosures or theft. This protection is provided by firewalls in the computer system, passwords to protect databases, encrypted e-mail, locked filing cabinets and limited access to certain work areas. Only the Centre Coordinator and Centre Director and delegated individuals have access to this information.
We destroy paper files that contain personal information by shredding. We destroy electronic information by deleting it, and when the hardware is discarded, we ensure that the hard drive is formatted to erase any information contained within.
You can look at your information
With some exceptions you have the right to see what personal information we hold about you. Often, all you have to do is ask. Umbrella reserves the right to charge a reasonable fee for the copying of this information.
We will need to confirm your identity, if we do not know you, before providing you with access.
If there is a problem, we may ask you to put your request in writing. If we cannot give you access, we will tell you within 30 days - if at all possible - and tell you the reason, as best we can, as to why we cannot give you access.
If you believe there is a mistake in your information, you have the right to ask for it to be corrected. This applies to factual information and not to any professional opinions we may have formed. We may ask you to provide documentation that our files are incorrect. Where we agree that there is an error, we will make the correction and notify anyone to whom we sent this information. If we do not agree that there is an error, we will still be willing to include in our file a brief statement from you on the point.