Mission Services is committed to protecting the privacy of all clients, residents, staff, board members, volunteers and donors, as well as confidential business information.
Collection and storage of personal information will be treated in a manner that is respectful of individuals in all of the aforementioned groups.
The Privacy Team will be composed of the Director of Finance and Human Resources and the Director of Development and Communications. The Director of Finance and Human Resources will be responsible for the organization’s compliance with all privacy legislation of staff, clients, residents and board members and the Director of Development and Communications will be responsible for the organization’s compliance with all privacy legislation of donors and volunteers.
Definition of Personal Information
For the application of this policy, personal information, where collected, means:
- The personal address, telephone number or email address of the individual.
- Any identifying number assigned to an individual that can lead to their identification (e.g. social insurance number, constituent number).
- Information about the individual’s income and assets.
- Bank account and credit card information.
- Information about rent payment history.
- Information relating to the race, national or ethnic origin, citizenship status, colour, religion, age, gender, sexual orientation, marital or family status of the individual.
- Information relating to the education, medical, psychiatric, psychological, criminal or employment history of the individual.
- Credit and rental history reports.
- Financial information for the purposes of establishing rent-geared-to-income.
- An individual’s blood type or fingerprints.
- Information about an individual’s personal or political opinions.
- Correspondence sent to Mission Services of a confidential nature, and any replies from Mission Services that would reveal contents of the original correspondence.
- The individual’s name if it appears with other confidential information (e.g. rental arrears report, client list etc.).
- Employee information including curriculum vitae, salary and benefits, disciplinary action, bank account information, resident complaints about the specific individual and employee grievances.
- Identifiable images of clients/residents.
Information not considered confidential:
- The name, position and business phone number of employees.
- Personal information that is summarized in a non-identifying manner.
- Business contact information and publicly available information (e.g. as published in telephone or city directories).
- The name and Board position of current Board members.
Collection of Information
1. Personal information will be collected only for the following purposes:
- To demonstrate compliance with funding requirements.
- To protect the health and safety of all aforementioned groups.
- To determine income and assets for rate of pay for stay assessment.
- To ascertain service levels required for special needs and/or for special needs accommodation.
- To conduct reference (including criminal vulnerability) and employment checks.
- To confirm income or illness of employees.
- To provide income verification and/or references for loans or new employment.
- To retain relevant information about employees and Board members for government reporting purposes.
- To provide tax receipts and to keep donors informed and up-to-date on the activities (including programs, services, special events, funding needs, opportunities to volunteer, open houses and more) and fundraising opportunities in support of Mission Services.
- To confirm child custody and to report any concerns to appropriate authorities (police, child welfare, courts etc.).
- To make client referrals to and/or verify information from social service agencies, education, health, immigration, child welfare and/or judicial systems.
- To ensure client/resident quality assurance.
- To provide continuity of care for clients/residents.
2. Employees will not seek out personal information about any of the aforementioned groups unless it is relevant to their work.
3. All documents used for collection of personal information shall state:
- the purpose(s) of the collection;
- the name, title, business address and business telephone number of the Privacy Team who can answer questions and respond to complaints about the collection, use or disclosure of the information; and will include:
4. Additionally, documents used for collection of client/resident personal information shall also include:
- the reasons for collection, including the fact that the information may be shared, as necessary, for the purpose of making decisions or verifying eligibility for assistance under the Social Housing Reform Act, the Ontario Disability Support Program Act, 1997, the Ontario Works Act, 1997, the Mental Health Act, the Child and Family Services Act or the Day Nurseries Act; or as authorized by an agreement under sections 163 or 164 of the Social Housing Reform Act;
- a consent form to be signed by the client or resident authorizing the collection, use or disclosure of the information being collected.
Protection of Information
- All client, resident, volunteer, donor and employee files (including information on databases) will be safeguarded against unauthorized access.
- Staff, volunteers and members of the Board, where appropriate, will only have access to records containing personal information when required to fulfil their duties.
- All staff have a responsibility to ensure that unauthorized individuals do not have unsupervised access to areas where files are kept and used.