STATEMENT
La Boîte à soleil is committed to respecting individuals’ privacy with regard to personal information and to ensuring the confidentiality of personal information entrusted to it in the course of its activities. It recognizes that this commitment is essential to maintaining the public’s trust.
La Boîte à soleil seeks to maintain a balance between the right to privacy and the need to collect or use personal information in the course of its activities. This Personal Information Protection Policy describes our standards for the collection, use, disclosure, and retention of your personal information. The policy also explains how we protect your personal information and your right of access to it.
PROCEDURES
Source of Personal Information Protection
The protection of personal information at La Boîte à soleil is governed by the Personal Information Protection Act. This Act establishes the confidential nature of personal information and regulates its collection, use, disclosure, and retention. The Act applies to personal information regardless of the medium on which it is recorded.
Definition of Personal Information
Personal information generally refers to information that identifies an individual, or a combination of information that makes it possible to identify an individual.
The name of a natural person is not considered personal information unless it is mentioned together with other information concerning that person, or unless its mention alone reveals personal information about that person.
Purposes of Collecting Personal Information
- We must collect information about you in order to provide high-quality services. The nature and sensitivity of the information we collect varies depending on the services we provide and the legal requirements with which we must comply.
- If you have questions or comments about the purposes for which we collect certain information, please do not hesitate to contact us at the address listed at the end of this policy.
Partners
- We work in partnership with a number of organizations and support workers who, in the course of their duties, have limited access to the personal information we hold. These include IT consultants providing technical support, auditors, procurement staff, resource consultants and assistants, and employees of organizations that support children with special needs.
- The Ministry of Education, in carrying out its responsibilities to ensure compliance with the Child Care and Early Years Act, 2014, will have access to the personal information we hold. In the course of its duties, the Regional Municipality of Niagara will have access to personal information concerning subsidized clients to whom we provide services.
- In carrying out its responsibilities to ensure compliance with the Child Care and Early Years Act, 2014, the Regional Municipality of Niagara – Public Health Inspection Services will have access to and may collect personal information that we hold. We limit their access to personal information based on legislative requirements and their authority. We are also assured that they comply with appropriate confidentiality principles.
- We do not share or sell your information with third parties except as identified in this policy.
Primary Purposes for the Collection of Personal Information
About Clients
- As licensed child care service providers, we collect, use, and disclose personal information in order to better serve our clients. The primary purpose of collecting information about clients is to provide the best possible child care services by adequately meeting the needs of children and families.
- A second primary purpose is to comply with the legislative requirements of the Child Care and Early Years Act, 2014.
- A third primary purpose is to collect and/or disclose personal information to resource support agencies to help us provide the best possible child care services and appropriately meet children’s needs.
- A fourth primary purpose is to collect necessary personal information so that we can contact appropriate individuals in the event of an emergency.
- It is rare that we collect or disclose personal information without the express consent of the client; however, this may occur in an emergency (for example, when a parent or guardian is unavailable) or when we believe the client would consent but it is impossible to obtain consent (for example, when a child’s well-being is at risk).
- Authorization/consent forms are provided to families before information about a child is disclosed, unless the child’s well-being is at risk or a legally mandated program requests information (e.g., FACS).
- A consent form is signed at registration to allow photographs to be taken of children in the centres.
About Members of the Board of Directors
The primary purpose of collecting information is to allow the distribution of relevant information so members can fulfill their responsibilities as Board members. A secondary purpose is to complete required disclosure documents for the Ministry of Public and Business Service Delivery, Canada Revenue Agency, the Regional Municipality of Niagara, and the Ministry of Education.
About Staff
For staff, the primary purpose of collecting personal information is to process payroll, provide employee and dependent benefits, maintain contact information, etc. A secondary purpose is to comply with legislative requirements and ensure the well-being of clients and the workforce.
About External Agency Staff
- For individuals hired on a contractual basis, the primary purpose of collecting personal information is to ensure we can contact them in the future (e.g., related communications such as issuing pay cheques or paying for services).
- Examples of the types of personal information collected for these purposes include home addresses and telephone numbers. It is rare that we collect such information without prior consent, but this may occur in the event of a public health emergency (e.g., an outbreak of a contagious disease) or to investigate a potential violation of the law (e.g., theft occurring in a centre or office).
Consent
- When we collect personal information about you, we obtain your consent to use it for the purposes for which it was collected. We must obtain your consent to use your information for other purposes or to collect additional information about you.
- Generally, we request your explicit written consent to collect, use, or disclose your personal information. For less sensitive information, we may, in certain circumstances, accept verbal consent.
- Consent must be given by you or by a duly authorized person such as a guardian or legal representative.
- You may withdraw your consent at any time, subject to legal or contractual restrictions. We will inform you of the consequences of such withdrawal, including the possibility that we may no longer be able to provide services. If you choose to withdraw your consent, this will be recorded in our files.
Limits on Collection, Use, and Disclosure
- We limit the collection of personal information to what is necessary for the purposes explained to you.
- We collect personal information directly from you, unless you have consented to collection from third parties or the law permits otherwise.
- We use personal information only for the purposes for which it was collected, unless otherwise permitted by law or with your consent.
- We do not disclose personal information without your consent, except as required by law. Personal information is accessible only to authorized individuals who require it in the performance of their duties.
Accuracy
We make every reasonable effort to ensure that personal information is as accurate and complete as required for the purposes for which it is collected, used, or disclosed.
Accountability
We are responsible for the personal information in our possession or under our control, including information entrusted to third parties for processing. We require such third parties to maintain strict standards of confidentiality and security.
Security Measures
- We recognize the importance of protecting personal information. For this reason, we have implemented and continue to develop rigorous security measures to ensure personal information remains strictly confidential and protected against loss, theft, unauthorized access, disclosure, copying, use, or modification.
- These measures include organizational safeguards (security clearances and restricted access); physical safeguards (external data backup and archiving systems; paper records monitored or secured in locked or restricted areas; staff training on proper collection, use, and disclosure of personal information); and technological safeguards such as password-protected computers and electronic equipment secured or monitored at all times.
Retention and Destruction of Personal Information
- We retain personal information for a period necessary to respond to inquiries about services provided and to meet accountability requirements with legislative and regulatory bodies, while avoiding unnecessary retention to protect privacy.
- Client files are retained for three years after a client leaves our centres. Financial records are retained for seven years. Employee records are retained for seven years after employment ends.
- Paper records containing personal information are destroyed by shredding.
- Electronic information is destroyed by deletion, and when equipment is disposed of, we ensure hard drives are formatted to erase all stored information.
Access to Information and Corrections
With limited exceptions, you have the right to know whether we hold personal information about you and to access that information. You also have the right to request details about how the information was collected, how it was used, and to whom it may have been disclosed.
This information will be provided within a reasonable time after receipt of a written request. We reserve the right to charge reasonable fees for processing such requests.
If you believe there is an error in the information, you have the right to request correction. This applies to factual information and not to professional opinions. We may request documentation to support the correction. If we agree an error was made, we will correct it and notify any third parties to whom the information was disclosed. If we do not agree, we will include a brief statement from you in the file.
Concerns and Complaints
Under the Act, the Executive Director has designated the Finance Manager as the Privacy Officer for La Boîte à soleil. Any unresolved questions or concerns may be submitted to the Executive Director.
All requests for access or correction must be sent to:
Christina Clark – Executive Director
674 Tanguay Avenue
Welland, Ontario L3B 6B2
905-735-1840 ext. 21
directrice@laboiteasoleil.ca
They will attempt to respond to your questions or concerns.
If you wish to file a formal complaint regarding our personal information practices, you may do so in writing. Receipt of the complaint will be acknowledged, an investigation conducted promptly, and a formal written decision with reasons provided.
This policy is made pursuant to the Personal Information Protection and Electronic Documents Act (PIPEDA), a complex law that provides additional exceptions to privacy principles not fully detailed here. There are limited exceptions to the commitments outlined above.
For general inquiries, the Office of the Privacy Commissioner of Canada oversees the administration of private-sector privacy legislation and acts as an ombudsman for privacy disputes. The Commissioner can be contacted at:
Office of the Privacy Commissioner of Canada
30 Victoria Street
Gatineau, Quebec K1A 1H3
Toll-free: 1-800-282-1376
Phone: 819-994-5444
www.priv.gc.ca
This External (Public) Personal Information Protection Policy summarizes our commitments. For internal procedures applicable to staff, La Boîte à soleil refers to its Internal Privacy Policy and procedures.