Women’s Community House(WCH) believes in the rights of all clients, donors, board members, staff and volunteers to have their personal information remain private and confidential.
Women’s Community House also believes that clients have a right to be assured that their safety is not compromised in any way by any records, or practices observed at Women’s Community House.
Women’s Community House wishes to comply with Personal Information Protection and Electronic Documents Act (PIPEDA) legislation as it applies to the use, retention and destruction of confidential personal information.
WCH will comply with the Personal Information Protection and Electronic Documents Act (PIPEDA), Bill 168 of the amendment to the Occupational Health and Safety Act and other applicable and relevant (provincial or federal) legislation.
All Board members, management, staff, students, volunteers (Professional Standards Agreement) , contractors (Memo of Understanding with External Service Providers and Contractors), visitors and clients (Caring Commitment B 04) sign a confidentiality statement agreeing to maintain confidentiality regarding current and former service users in perpetuity.
All paper and electronic records containing personal information are safeguarded to protect confidentiality.
Women’s Community House has designated the Human Resources Manager as the Chief Privacy Officer.
Women’s Community House will obtain an individual’s personal information for the identified purposes and by lawful means only.
At the time of collecting personal information of any individual, the purpose for the collection of the information will be explained by the staff asking for the information to the individual and the individual’s consent will be obtained for collection, use, retention and disclosure of the information. Critical information is stored only until service use has ended and then stored in a locked Archives Room. Electronic records, stored behind security firewalls, are backed up daily and stored appropriately.
Personal information collected and retained shall be as accurate, complete and up to date as is necessary for the purposes for which it is to be used.
Upon request, Women’s Community House will inform an individual of the existence, use, and disclosure of personal information and shall give the individual access to that information. The privacy of other’s personal information must be protected when giving an individual access to her/his own personal information.
If the Privacy Officer believes that releasing personal information to an individual would prejudice the mental or physical health or the security of any person, she/he will not release the information.
Women’s Community House shall ensure that an individual is able to challenge the accuracy and completeness of the information by addressing a challenge to the Chief Privacy Officer. See Procedure for Handling Complaints (Appendix A).
When providing personal and/or corporate information through e-mail or the Women’s Community House website, an individual’s assent to the proper use of this information is accepted.
WCH has professionals from other agencies come into shelter to help meet the needs of the agency and its residents. All external professionals are required to agree to our confidentiality standards in writing and understand the need for safety. The WCH Board of Directors and any professionals from outside agencies will sign a Professional Standards Agreement which binds them to confidentiality
These professionals may, from time-to-time, have access to information about individuals including staff, on a need-to-know basis. These professionals include: Mental Health Care professionals under Canadian Mental Health Association, and Streetscape; WCH Workplace Violence and Harassment Advisor; Police; CAS; information technology consultants (i.e. data base support and TLT Networks) and technicians required to support our computer systems; and others representing Ontario Works or housing providers. Confidentiality is understood to be vitally important to all these outside support staff.
Procedure for handling complaints regarding privacy of information or breach of confidentiality is outlined in Procedure for Handling Complaints (Appendix A).
Personal information is gathered by Development during fundraising activities to support the Women’s Community House mission. The names, addresses and information about donations will be used only in the process of fundraising. The donor’s personal (or financial information) will not be disclosed to any other organization or to individuals without the expressed consent of the donor. Limited donor information may be released in donor recognition activities, with the donor’s consent and in communications such as Women’s Community House Newsletter, eNewsletter and Annual Reports.
Clients include shelter residents and tenants of WCH and families receiving service through Women’s Community House’s Transitional Outreach Program.
All personal information, including name, address, financial information, alleged abuser descriptions, life circumstances, and personal information about children, etc., is used in the provision of service to abused women and their children.
All database entries and electronic documentation, including e-mail, are secured by firewalls and Women’s Community House internal network, using current technology, protected passwords and limited access to protect the integrity of the information.
Service notes, incident reports and ECRA’s entered into the database are used only as a communication mechanism amongst Women’s Community House staff to advance a plan of action for the family, or to assess safety concerns. Critical information includes resident’s name (woman and any children), admission and discharge dates, abuser description and any pertinent Eligibility Criteria for Re-admission (according to ECRA guidelines). All other written documents are shredded after 30 days.
All resident personal information and documentation shall remain on the premises, unless under subpoena and be disposed of as noted above.
Second Stage Housing will retain its financial records relating to each tenant for at least seven years after the end of the fiscal year to which the record related. Second Stage Housing will retain its tenant files for a period of at least five years after the date the household last resides in a unit. Tenant files will include an application for housing, Lease Agreement, rent calculation forms, verification of income, Occupancy Agreement, and critical information. These records will be kept on the Second Stage Housing premises or in WCH archives.
Staff working in an outreach capacity are responsible to ensure client notes, planners or other documentation containing personal information are secured at the end of the workday and purged as outlined above.
Residents are informed about the collection, use and disclosure of their personal information at the time of intake and are asked to consent to its use as part of the Caring Commitment – intake agreement. Residents are informed at the time of intake that this information may be shared between staff at all WCH sites. All service users are informed that information regarding other cleints who may be also recieving service is confidential. Residents sign a Caring Commitment agreeing to maintain confidentiality.
The use of images of current service users or WCH security measures including photos on cell phones and cameras are prohibited, and residents are informed of this policy.
Tenants are informed about the collection, use and disclosure of their personal information at the time of application for housing and are asked to consent to its use as part of the application process.
Procedures for Handling Complaints
The WCH Privacy Officer will respond to all concerns about collection, use, disclosure, storage and disposal of personal information within thirty days of the request being made, and advise the complainant as to the action that has been made.
In the event of a complaint:
The Privacy Officer will inform the Management Team of the complaint.
Each complaint will be assessed by the Privacy Officer and the appropriate Manager to determine whether: correction of the personal information is necessary; the information was collected, used, released or disposed of inappropriately; the policies and procedures need to be revised; disciplinary or other action need to be taken with respect to a breach of confidentiality.
Breach of Confidentiality
It is a breach of confidentiality to:
Discuss any confidential information within or outside the organization where it may be heard by individuals who are not authorized to have access to that information.
Provide confidential information or records to unauthorized individuals.
Leave confidential information in written form or displayed on a computer terminal in a location where it may be viewed by unauthorized individuals.
A breach of confidentiality may be grounds for staff discipline or termination. A breach of his or her confidentiality obligation may be grounds for a board member to be removed as a Board Director. A board member who breaches confidentiality may not be covered by the WCH insurance.