The organization strives to protect and respect personal information of its clients, employees, and visitors in accordance with all applicable statutory requirements. All employees must abide by the procedures and practices set out below while handling personal information.
This policy outlines the organization’s commitment to privacy and establishes the methods by which privacy is ensured. This policy applies to all personal information in the organization’s care, custody, and control.
Personal information is any factual or subjective identifying information about an individual or group of individuals. This can include name, date of birth, address, income, e-mail address, social insurance number, gender, evaluations, credit records, and so forth.
Consent occurs and is considered obtained by Brass Bell Family Resource Centre when an individual provides express consent orally, in writing, or through an applicable online action. Before being asked to provide consent, individuals will be provided with the reasons their personal information is being collected, how it will be used and stored, and any disclosure or possible disclosure of the information. Individuals whose personal information is being collected are at all times entitled to know how the organization uses their personal information and that the use of any personal information collected is limited to only what is needed for those stated purposes. If necessary, Brass Bell Family Resource Centre will obtain individual consent if personal information is to be used for any other purpose.
Brass Bell Family Resource Centre collects and uses personal information solely for the purpose of its operations.
Personal information may only be collected for the following purposes:
- Legislative Requirements
- Employment & Recruitment
- Emergency Contacts
- Health and Safety
- Planning, Programs & Services
Personal information will only be used:
- if the person to whom the information relates has identified that information in particular and consented to its use;
- for the purpose for which it was obtained or compiled or for a consistent purpose; or
- for a purpose for which the information may be disclosed to the institution under section 32 or under section 42 of the Freedom of Information and Protection of Privacy Act. R.S.O. 1990, c. M.56, s. 31.
Brass Bell Family Resource Centre assumes full accountability for the personal information within its possession and control. The organization has appointed the Executive Director as custodian of all privacy matters and legal compliance with privacy laws.
Under no circumstances will the organization sell, distribute, or otherwise disclose personal information, including personal contact information or employee lists, to third parties, unless required to do so by law.
The organization will retain personal information only for the duration it is needed for conducting its business and ensuring statutory compliance. Once personal information is no longer required, it will be destroyed promptly, safely, and securely. However, certain laws may require that certain personal information be kept for a specified amount of time. Where this is the case, the law will supersede this policy.
The organization will take every reasonable precaution to protect personal information with appropriate security measures, physical safeguards, and electronic precautions. The organization maintains personal information through a combination of paper and electronic files. Where required by legislation or disaster recovery or business continuity policies, older records may be stored in a secure, offsite location.
Brass Bell Family Resource Centre will ensure:
- Access to personal information is authorized only for the employees and other agents of the organization who require the information to perform their job duties, and to those otherwise authorized by law;
- The organization’s computer systems and databases are secured by complex passwords and firewalls to which only authorized individuals may access;
- Active physical files are kept in locked filing cabinets;
- Routers and servers connected to the Internet are protected by a firewall, and are further protected against virus attacks or “snooping” by sufficient software solutions;
- Personal information is not transferred to employees, volunteers, summer students, or any other person in the organization unless authorized.
In most instances, Brass Bell Family Resource Centre will grant individuals access to personal information in the care, custody, and control of the organization upon presentation of a written request and satisfactory identification. If an individual finds errors of fact with their personal information, they should notify the organization as soon as possible to make the appropriate corrections.
If the organization denies an individual’s request for access to their personal information, the organization will advise in writing of the reason for such a refusal. The individual may then challenge the decision.
Any questions or concerns regarding this policy can be addressed by contacting Brass Bell Family Resource Centre. The organization will investigate and respond to concerns about any aspect of the handling of personal information. This organization will address concerns to the best of its abilities.
PIPEDA Compliance Policy
The Personal Information Protection and Electronic Documents Act (PIPEDA) establishes rules to govern the collection, use, and disclosure of personal information in a manner that recognizes the right to privacy of individual’s personal information and the need of organizations to collect, use, or disclose personal information for purposes that a reasonable person would consider appropriate in the circumstances. Brass Bell Resource Centre is committed to protecting and respecting the personal information of its customers, employees, partners, and all other entities it interacts with in accordance with PIPEDA. This policy will provide guidelines to ensure that Brass Bell Resource Centre remains compliant with PIPEDA requirements.
Breach of security safeguards: The loss of, unauthorized access to, or unauthorized disclosure of personal information resulting from a breach of an organization’s security safeguards, or from a failure to establish those safeguards.
Personal information: Information about an identifiable individual.
Security safeguards: Security safeguards include the following:
- Physical measures: for example, locking filing cabinets and restricting access to offices;
- Organizational measures: for example, security clearances and limiting access on a “need-to-know” basis; and
- Technological measures: for example, the use of passwords and encryption.
Significant harm: Includes bodily harm; humiliation; damage to reputation or relationships; loss of employment, business, or professional opportunities; financial loss; identity theft; negative effects on a credit record; and damage to or loss of property.
All definitions sourced from PIPEDA.
Brass Bell Resource Centre has implemented these guidelines to ensure continuing compliance with PIPEDA requirements. The personal information of Brass Bell Resource Centre employees, customers, clients, business partners, and so on will be managed to meet the following PIPEDA requirements:
- All personal information in Brass Bell Resource Centre possession or custody must be protected appropriately.
- Individuals must be informed as to why personal information is being collected.
- Consent must be obtained for the collection and use of information.
- The consent of an individual is only valid if it is reasonable to expect that the individual understands the nature, purpose, and consequences of the collection, use, or disclosure of the personal information.
- Personal information may only be collected without consent if:
- The collection is clearly in the interests of the individual and consent cannot be obtained in a timely way;
- The personal information was produced by the individual in the course of their employment, business, or profession, and the collection is consistent with the purposes for which the information was provided;
- The collection is made for the purpose of making a disclosure; or
- Any other reason as defined in PIPEDA section 7(1).
- Individuals have the right to withdraw their consent.
- Personal information collected is only collected, used, or disclosed for purposes that a reasonable person would consider appropriate in the circumstances.
- Personal information is used only for the purposes for which it was collected, except with the consent of the individual or as required by law.
- Personal information is retained only for the period of time that it is reasonably required.
- Personal information is destroyed that is no longer required using a safe, secure, and effective manner (for example, shredding).
- All personal information collected is accurate.
- Individuals are allowed access to their personal information, and to make corrections as appropriate.
- Appropriate security and safeguards are employed for the protection of personal information.
- Access to personal information is limited to authorized personnel who have a legitimate need to access the information.
- Consent must generally be obtained before the release of personal information to any third party.
- Consent to disclose personal information to a third party is not required if:
- Brass Bell Resource Centre has reasonable grounds to believe that the information could be useful in the investigation of a contravention of the laws of Canada, a province or territory, or a foreign jurisdiction, and the information is used for the purpose of investigating that contravention;
- It is used for the purpose of acting in respect to an emergency that threatens the life, health, or security of an individual;
- The information was produced by the individual in the course of their employment, business, or profession, and the use is consistent with the purposes for which the information was produced; or
- Any other circumstances as defined in PIPEDA section 7(2) are met.
- The forms of information being collected must be identified and communicated to the individual, as well as the rationale for the collection of these forms of information.
- Individuals must be notified and consent must be obtained before using personal information for any reason other than those provided at the time of collection.
In addition to the above requirements, Brass Bell Resource Centre will designate a representative to hold accountability for the organization’s compliance with PIPEDA. The representative will hold responsibility for the management of the personal information policies and procedures of Brass Bell Resource Centre.
- The representative shall be the Executive Director.
The PIPEDA representative shall be responsible for:
- Developing and implementing policies and practices under PIPEDA, including:
- Procedures that address the collection, use, retention, destruction, and management of personal information;
- Procedures for protecting personal information in all formats;
- Procedures for complaints and inquiries; and
- Staff training on PIPEDA obligations.
- Using privacy agreements and contracts to ensure the protection of personal information where the information must be provided to a third party.
- Reviewing policies, practices, and procedures annually or as needed, making appropriate revisions.
Breaches of Security Safeguards
If Brass Bell Resource Centre becomes aware of a breach of our security safeguards that compromises the privacy of the personal information retained by the company, the following action shall be taken:
- The Executive Director is responsible for coordinating the response to the breach and ensuring that all reasonable action is taken to address the breach.
- The Executive Director will notify the privacy commissioner of Canada of the breach in the prescribed form and manner as soon as feasible once Brass Bell Resource Centre has determined that a breach has occurred. Brass Bell Resource Centre will also submit any new information that the company becomes aware of after having made the report.
- The Executive Director will notify any affected individuals of the breach in the prescribed form and manner as soon as feasible
- Brass Bell Resource Centre will comply to the greatest extent possible and in a timely manner with any requests, orders, or other instructions from the Office of the Privacy Commissioner of Canada in order to respond to and address the security breach.
- Brass Bell Resource Centre will maintain records of every breach of security safeguards, and will provide the privacy commissioner of Canada with access to or a copy of a record of a breach at the request of the commissioner.
As per the Breach of Security Safeguards Regulations, the report submitted to the privacy commissioner will contain:
- A description of the circumstances of the breach and if known the cause;
- The date on which or the period during which the breach occurred or if neither is known the approximate period;
- A description of the personal information that is the subject of the breach to the extent that the information is known;
- The number of individuals affected by the breach or if unknown the approximate number;
- A description of the steps that the organization has taken to reduce the risk of harm to affected individuals that could result from the breach or to mitigate that harm;
- A description of the steps that the organization has taken or intends to take to notify affected individuals of the breach in accordance with subsection 10.1(3) of PIPEDA; and
- The name and contact information of a person who can answer the commissioner’s questions about the breach on behalf of the organization.
Notifying Affected Individuals
Determining Whether a Real Risk of Significant Harm Exists
Brass Bell Resource Centre will assess the following factors when determining whether a security breach constitutes a real risk of significant harm to an individual or individuals:
- The sensitivity of the personal information involved in the breach;
- The probability that the personal information has been, is being, or will be misused; and
- Any other prescribed factor.
The Executive Director is responsible for ensuring that all individuals for whom the breach creates a real risk of significant harm are notified at the earliest available opportunity, subject to any legal restrictions, in a form of communication that a reasonable person would consider appropriate in the circumstances. As per the regulation, notifications shall contain sufficient information to allow the individual to understand the significance to them of the breach, including:
- A description of the circumstances of the breach;
- The date on which or period during which the breach occurred or if neither is known the approximate period;
- A description of the personal information that is the subject of the breach to the extent that the information is known;
- A description of the steps that the organization has taken to reduce the risk of harm that could result from the breach;
- A description of the steps that affected individuals could take to reduce the risk of harm that could result from the breach or to mitigate that harm;
- Contact information that the affected individual can use to obtain further information about the breach; and
- Any other prescribed information.
The notice shall be conspicuous and given directly or indirectly to the individual in the prescribed form and manner as legislatively required as the situation dictates.
In addition to the individuals affected by the breach, Brass Bell Resource Centre may notify other parties of the breach or disclose personal information relating to the breach, subject to the following guidelines:
- Brass Bell Resource Centre will notify other organizations, government institutions, or parts of government institutions if Brass Bell Resource Centre believes that doing so can reduce or mitigate the harm from the breach.
- Brass Bell Resource Centre may disclose personal information without the knowledge or consent of the individual if:
- The disclosure is made to the other organization, the government institution, or the part of a government institution that was notified under the breach; and
- The disclosure is made solely for the purpose of reducing the risk of harm to the individual that could result from the breach or mitigating that harm.
Accessible Customer Service Policy
All goods and services provided by Brass Bell Family Resource Centre will follow the principles of dignity, independence, integration, and equal opportunity.
This policy meets the requirements of the customer service standards included in the Integrated Accessibility Standards Regulation under the Accessibility for Ontarians with Disabilities Act, 2005. It applies to the provision of goods and services to the public or other third parties, not to the goods themselves.
Assistive device: A technical aid, communication device, or other instrument that is used to maintain or improve the functional abilities of people with disabilities.
Disability: As defined by the Accessibility for Ontarians with Disabilities Act, 2005, and the Ontario Human Rights Code, refers to:
- Any degree of physical disability, infirmity, malformation, or disfigurement that is caused by bodily injury, birth defect, or illness and, without limiting the generality of the foregoing, includes diabetes mellitus, epilepsy, a brain injury, any degree of paralysis, amputation, lack of physical co-ordination, blindness or visual impediment, deafness or hearing impediment, muteness or speech impediment, or physical reliance on a guide dog or other animal or on a wheelchair or other remedial appliance or device;
- A condition of mental impairment or a developmental disability;
- A learning disability, or dysfunction in one or more of the processes involved in understanding or using symbols or spoken language;
- A mental disorder; or
- An injury or disability for which benefits were claimed or received under the insurance plan established under the Workplace Safety and Insurance Act, 1997.
Guide dog: A highly trained working dog that has been trained at one of the facilities listed in Ontario Regulation 58 under the Blind Persons’ Rights Act, to provide mobility, safety, and increased independence for people who are blind.
Service animal: An animal is a service animal if the animal can be readily identified as one that is being used by a person for reasons relating to that person’s disability, including where the animal is confirmed as such by a letter from a qualified regulated health professional.
Support person: In relation to a person with a disability, another person who accompanies them in order to help with communication, mobility, personal care, medical needs, or access to goods and services.
The Provision of Goods and Services to Persons with Disabilities
Brass Bell Family Resource Centre will make every reasonable effort to ensure that its policies, practices, and procedures are consistent with the principles of dignity, independence, integration, and equal opportunity by:
- Ensuring that all customers receive the same value and quality;
- Allowing customers with disabilities to do things in their own ways, at their own pace when accessing goods and services, as long as this does not present a health and safety risk;
- Using alternative methods when possible, to ensure that customers with disabilities have access to the same services, in the same place and in a similar manner;
- Taking into account individual accommodation needs when providing goods and services; and
- Communicating in a manner that takes into account the customer’s disability.
The Use of Assistive Devices
Customer’s Own Assistive Devices
Persons with disabilities may use their own assistive devices as required when accessing goods or services provided by the organization.
In cases where the assistive device presents a health and safety concern or where accessibility might be an issue, other reasonable measures will be used to ensure the access of goods and services, up to the point of undue hardship.
For example, open flames and oxygen tanks cannot be near one another. Therefore, the accommodation of a customer with an oxygen tank might involve ensuring the customer is in a location that would be considered safe for both the customer and business.
Alternatively, where elevators are not present and where a customer requires assistive devices for the purposes of mobility, service will be provided in a location that meets the needs of the customer.
Guide Dogs and Service Animals
A customer with a disability who is accompanied by a guide dog or service animal will be allowed access to premises that are open to the public unless otherwise excluded by law. “No pet” policies do not apply to guide dogs or service animals.
Staff may respectfully ask if an animal is a service animal and will not ask the nature of the person’s disability or purpose of the animal.
If a customer’s guide dog or service animal is excluded by law (see applicable laws below), Brass Bell Family Resource Centre will offer alternative methods to enable the person with a disability to access goods and services, when possible. For example, the organization might accommodate a customer’s disability by securing the animal in a safe location and offering the assistance of an employee to facilitate the delivery of goods and services.
The Use of Support Persons
If a customer with a disability is accompanied by a support person, Brass Bell Family Resource Centre will ensure that both persons may enter the premises together and that the customer is not prevented from having access to the support person.
In situations where confidential information might be discussed, consent will be obtained from the customer before any potentially confidential information is mentioned.
Notice of Disruptions in Service
Service disruptions may occur for reasons that may or may not be within the control or knowledge of Brass Bell Family Resource Centre. In the event of any temporary disruptions to facilities or services that customers with disabilities rely on to access or use goods or services, reasonable efforts will be made to provide advance notice. In some circumstances, such as in the situation of unplanned temporary disruptions, advance notice may not be possible.
If a notification needs to be posted, the following information will be included unless it is not readily available or known:
- Goods or services that are disrupted or unavailable;
- Reason for the disruption;
- Anticipated duration; and
- A description of alternative services or options.
When disruptions occur, Brass Bell Family Resource Centre will provide notice by:
- Posting notices in conspicuous places, including at the point of disruption, at the main entrance, and the nearest accessible entrance to the service disruption, or on the organization website;
- Contacting customers with appointments;
- Verbally notifying customers when they make a reservation or appointment; or
- By any other method that may be reasonable under the circumstances
Brass Bell Family Resource Centre shall provide customers with the opportunity to provide feedback on the service provided to customers with disabilities. Information about the feedback process will be readily available to all customers. Feedback forms, along with alternate methods of providing feedback verbally (in person or by telephone) or written (handwritten, delivered, website, or e-mail), will be available upon request.
Customers can submit feedback to:
Or through our contact form on our website at www.brassbell.org
Customers who wish to provide feedback by completing an onsite customer feedback form or verbally can do so to any Brass Bell Family Resource Centre employee.
Customers who provide formal feedback will receive acknowledgement of their feedback, along with any resulting actions based on concerns or complaints that were submitted.
Training will be provided to:
- Every employee of or a volunteer with Brass Bell Family Resource Centre;
- Every person who participates in developing the policies of Brass Bell Family Resource Centre; and
Regardless of the format, training will cover the following:
- A review of the purpose of the Accessibility for Ontarians with Disabilities Act, 2005;
- A review of the requirements of the customer service standards;
- Instructions on how to interact and communicate with people with various types of disabilities;
- Instructions on how to interact with people with disabilities who:
- Use assistive devices;
- Require the assistance of a guide dog or other service animal; or
- Require the use of a support person (including the handling of admission fees);
- Instructions on how to use equipment or devices that are available at our premises or that we provide that may help people with disabilities;
- Instructions on what to do if a person with a disability is having difficulty accessing our services; and
- Policies, procedures, and practices of the organization pertaining to providing accessible customer service to customers with disabilities
Brass Bell Family Resource Centre will provide training as soon as practicable. Training will be provided to new employees, volunteers, and contractors within the first three months of employment or involvement with the organization. Revised training will be provided in the event of changes to legislation, procedures, policies, or practices.
If you have any questions or concerns about this policy or its related procedures, please contact:
Or through our contact form on our website at www.brassbell.org
This policy and its related procedures will be reviewed as required in the event of legislative changes or changes to organization procedures.