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Privacy and Confidentiality Policy and
Procedures
Maple
Ridge/Pitt Meadows Community Services ensures that information concerning
all clients is privileged and confidential.
Policy
Maple Ridge/Pitt Meadows Community Services respects and upholds an
individual’s right to privacy and to protection of his or her personal
information. Community Services is committed to collecting, using,
disclosing and retaining personal information in a manner that complies with
applicable privacy legislation. This means that personnel take an active,
protective role with regard to the confidentiality of all personal or
identifying information.
Community Services sets out the procedures that will be observed with
respect to the collection, use, disclosure, retention and security of
information about any identifiable individual who is a past, current or
prospective: child, client, member, employee, volunteer, or donor of
Community Services.
All employees and volunteers will sign a "Declaration of Confidentiality"
at the beginning of their service with Community Services. Anyone who
breaches the provisions of this policy is subject to legal action as
appropriate and disciplinary action up to and including termination.
Principles and Procedures
1. Accountability
Community Services is responsible for all personal information under its
control. The organization’s Privacy Officer is accountable for Community
Service’s compliance with the principles described in this policy. The
Privacy Officer can be contacted at Community Services (604.467.6911, Ext.
206).
Community Services is responsible for both personal information in its
physical custody, and also personal information that is transferred by
Community Services to a third party. Therefore, Community Services has in
place procedures to: • protect personal information • receive and respond to
complaints and inquiries • orient employees and volunteers in the policies
and procedures regarding the collection, use, disclosure and retention of
personal information under Community Service’s protection • ensure all
members, clients, employees and volunteers have access to Community
Service’s Privacy Policy and Procedures
2. Purposes for Collection, Use, and Disclosure
Personal information will be collected on a “need to know” basis for the
operation of Community Services.
Community Service may collect personal information concerning children,
clients, members, employees, volunteers and/or donors for the following
purposes:
 | to comply with legal and regulatory requirements, |
| to operate Community Services, including to deliver and to record
services provided to clients, |
| to administer and maintain accounts relating to operations and/or
donations. |
No portion of a client record or personnel record shall be transmitted or
made available and no reports shall be made on any person unless:
- The person has given written permission for the information to be
disclosed.
- It is necessary for the proper administration of the agency,
including quality improvement activities, i.e., during audits or reviews
of client records.
- It is necessary for providing services to the client, i.e., for
supervision of a service provider or during a team meeting with other
Community Services personnel.
- There is nothing in the information which will identify the person.
- The information is requested by a funding body, or federal or
provincial reporting agency with the approval of the Executive Director.
- It is subpoenaed by a court.
- Agency personnel believe a person served is a danger to him/herself,
others, or the community.
- Agency personnel have reason to believe that a child has been or is
likely to be abused or neglected.
3. Consent
Consent of the individual is required for the collection, use and/or
disclosure of personal information by Community Services, except where that
is impossible or inappropriate. This means that before any personal
information is gathered, clients are invited to review and sign a "Consent
for Service" form. Clients are advised regarding the limits of
confidentiality (for example the duty to report certain types of
information) before personal information is gathered.
Implied consent may arise through action or inaction on the part of the
individual. For example, in certain circumstances a client may consent for
service by taking part in the service after they have been advised of their
rights.
4. Limiting Collection
Community Services will limit the amount and type of personal information
collected to information that is necessary for the purposes of Community
Services.
5. Limiting Use, Disclosure and Retention
Community Services will not use or disclose personal information for
purposes other than those for which it was collected, except with the
written consent of the individual or as required or permitted by law.
Personal information will be retained only as long as necessary for the
fulfillment of legal or business purposes. Personal information will be
stored in a locked cabinet at Community Services and will be accessed on a
“need to know” basis.
6. Accuracy
Community Services will make a reasonable effort to ensure that personal
information collected by Community Services or on its behalf is as accurate
and complete as is necessary for the purposes for which it is to be used.
Community Services will generally rely on individuals to provide updated
information, such as changes to addresses and other contact information.
7. Safeguards
Community Services will make reasonable security arrangement to protect
personal information. Safeguard arrangements are employed to protect
personal information against loss or theft, as well as unauthorized access,
disclosure, copying, use, modification, or disposal. The methods of
protection employed by Community Services will include:
| physical measures, including locked filing cabinets and restricted
access to offices; |
| organizational measures such as limiting access to a “need to know”
basis; |
| technological measures, such as use of passwords to access
electronic files. |
8. Openness
Community Services will ensure that individuals are able to acquire
information about agency policies and procedures on privacy protection. We
do this through a simplified "Confidentiality Policy" handout given to all
clients at Intake, and also by posting this Privacy Policy on the agency
website.
9. Accessing Personal Information
Community Services has procedures in place to govern access to client and
personnel records.
10. Complaints
An individual may complain, in writing, to the Privacy Officer with
regard to Community Service’s compliance with privacy protection. When a
written complaint is made, Community Services will:
| promptly acknowledge receipt of the complaint in writing; |
| contact the individual to clarify the complaint, if necessary; |
| investigate all complaints received; |
| notify the individual of the outcome of investigations promptly,
informing them clearly of any relevant steps taken; |
| correct any inaccurate personal information or modify policies and
procedures based on the outcome of complaints; and, |
| make reasonable efforts to process complaints within 30 days or
apply to the Privacy Commissioner for an extension. |
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