GENERAL PRIVACY STATEMENT
Mission Services of London (MSL) is committed to protecting the privacy of all participants, staff, volunteers and donors, as well as confidential organization information. MSL collects, stores and uses personal information under its control, in a manner that is respectful of individuals in all of the aforementioned groups.
Mission Services of London’s designated Privacy Officer is the Director of Retail Operations and Social Enterprise. For questions or concerns regarding privacy of information, please contact Susan Fahner, Director of Retail Operations and Social Enterprise: email@example.com
Definition of Personal Information
For MSL purposes, personal information means:
Any/all non-public, “identifying information” collected in MSL’s course of business, whether oral or recorded, about a current, past or potential MSL participant, staff, volunteer or donor. This could include (but is not limited to):
- Information concerning physical or mental health
- Information about any services provided
- Information concerning personal finances or donation history
- Credit card or banking information
- Addresses and telephone numbers that are not published
- Age, date of birth, sex, national or ethnic origin, sexual orientation, marital or family status
- Private information about an individual’s personal or political opinions
Information not considered confidential
- MSL employees’ name, position, business telephone number and business email
- Personal information that is summarized in a non-identifying manner
- Business contact information and all other publicly available information (e.g. as published/broadcast online, in print, on the radio, via advertising or other public means)
- The name and Board position of current MSL Board of Directors members
Collection and Use of Information
In the standard course of business, we do, from time to time, collect, store, use, and manage personal data. If and when we collect such data, we do so in compliance with the Personal Information Protection and Electronic Documents Act (PIPEDA), the Personal Health Information Protection Act (PHIPA), and Canada’s Anti-Spam Legislation (CASL), where and as applicable. The collection, storage, use and management of collected data is also subject to our organizational operating policies:
- Privacy – Protection of Client Personal Health Information (5-60)
- Privacy – Collection, Use, Disclosure & Security of Client Information (5-70)
- Privacy – Client Consent (5-80)
- Privacy – Access and Correction to Client Record (5-90)
- Privacy – Client Refusing or Revoking Consent (5-100)
- Privacy – Security of Client Personal Health Information (5-110)
- Privacy – Security Incident Management (5-120)
- Privacy – Security of Donor Personal Information (5-130)
- Privacy – Safe Storage of Donor Personal Information (5-140)
- Privacy – Donor Privacy and Security Incident Management (5-150)
- Records Management & Retention (5-160)
Together, the above policies address the collection, use, disclosure and security of personal information. A copy of these operating policies may be obtained from the Privacy Officer upon request (see Privacy Officer for contact information).
MSL collects, uses and discloses personal information for purposes related to direct service provision to participants, administration and management of MSL’s programs and services, statistical reporting, research, teaching, communications/public relations, and fundraising or donor stewardship as permitted by law. Information is collected with the individual’s knowledge and consent, and is used only for the purposes for which it was collected, except with consent or as required by law. Examples of these purposes include (but are not limited to):
- To demonstrate compliance with funding requirements
- To protect the health and safety of participants, staff, volunteers and donors
- To provide income verification for loans
- To provide tax receipts to donors
- To confirm child custody and to report concerns to appropriate authorities (police, child welfare, courts, etc.)
- To make participant referrals to and/or verify information from social service agencies, education, health, immigration, child welfare and/or judicial systems.
The form of consent – express or implied- and the way it is sought – in writing or orally – may vary depending upon the circumstances and sensitivity of the information. Individuals have the right to refuse, place limits or revoke consent at any time, subject to legal or contractual restrictions and reasonable notice, by contacting their MSL staff representative or the Privacy Officer.
In instances where personal information is collected, used or managed for communications/public relations activities, consent will be obtained and documented per the procedures outlined in the Communications, Public Relations & Advocacy Policy (6-10).
Donor/prospective donor implied or verbal consent to collect, store and/or disclose donor personal information will be documented in appropriate and reasonably feasible ways (e.g. a note in the donor’s record in MSL donor database).
MSL employees will not seek out personal information about participants, staff, volunteers and donors, nor will they seek confidential organization information, unless it is relevant to their work.
All means used for collection of personal information shall state the purpose(s) of the collection. MSL will publish the contact information of the Privacy Officer, who can answer questions and respond to complaints about the collection, use or disclosure of the information.
Additionally, means used for collection of participant personal information shall include:
- mention of 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 participant authorizing the collection, use or disclosure of the information being collected
Personal information can be collected, used, or disclosed without the knowledge and consent of the individual only if and when legal, medical or security reasons make it impossible or impractical to seek consent (e.g. there is a risk of injury to self or others).
Any information or records that are no longer needed will be disposed of in a secure way that protects the privacy of the individual (e.g. rendering documents unreadable by shredding them before secure disposal), and in accordance with any applicable legislation, organization policies and procedures.
Protection of Information
All participant, volunteer, donor and employee files (including information in databases) will be safeguarded against unauthorized access. All staff have a responsibility to ensure that access to areas where files are kept and used, is appropriately supervised and/or restricted.
Staff and volunteers will only have access to records containing personal information when required to fulfil their duties.
We respect donor and volunteer privacy, and we do not rent or sell our mailing lists.
Viewing or Making Changes to Your Personal Information
A person can view, read, copy and request changes/additions to information to their own personal information records kept by MSL. Only authorized guardians may view, copy or change/add personal information for under-aged individuals in their care, and only authorized representatives (e.g. Estate Executor or Lawyer) may view, copy or change/add personal information relating to a deceased individual. Program participants should contact the Privacy Officer (see Privacy Officer section above for contact information) or the Branch Director where they receive services in order to access their personal information on file; Branch Directors may be reached by contacting each branch (See Branches of Services at https://missionservices.ca/contact/). Volunteers should email firstname.lastname@example.org and donors should email email@example.com (or contact their MSL Development Team representative) to access their personal information on file.
Questions or Concerns
You may contact MSL’s Privacy Officer regarding any questions, concerns or to file a privacy-related complaint specific to MSL. Please email Susan Fahner, Director of Retail Operations and Social Enterprise firstname.lastname@example.org
In keeping with the recommendation of both the Office of the Privacy Commissioner of Canada and the Information and Privacy Commissioner of Ontario, we encourage anyone with a privacy-related concern to reach out to MSL’s Privacy Officer first. Should the issue be unable to be resolved directly with MSL, you may decide to file a formal complaint. To file a formal complaint in matters subject to PIPEDA, visit: https://www.priv.gc.ca/en/report-a-concern/file-a-formal-privacy-complaint/. To file a privacy complaint in matters subject to PHIPA, visit: https://www.ipc.on.ca/health/your-health-privacy-rights-in-ontario/privacy-breaches-under-phipa/. For CASL related matters, visit: https://www.fightspam.gc.ca/eic/site/030.nsf/eng/home.
MSL Website Privacy Statement
Mission Services of London (MSL) recognizes the importance of protecting the privacy of visitors to our website.
Mission Services of London collects information about website visits in the following ways:
- MSL collects anonymous information about how visitors use our website. We log all web traffic and associate it with the visitor’s IP address. Our primary goal for tracking this data is to improve the reliability of our website, and improve the information and service we provide. We only share this information with our contracted advertising or web development agencies, who are bound by agreements to maintain confidentiality and to refrain from inappropriately using data they may come into contact with via our website
- When submitting a form, filling out a survey, completing a registration or application, making an online inquiry or subscribing to our newsletter online, you may be asked to provide personally identifying information (e.g. your name, address, e-mail address). This information will be used to fulfill the specific request; we do not rent out or sell our mailing or email lists
- Any online requests for personal or financial information will be encrypted to protect your privacy. This information will be used to fulfill your specific request
- MSL makes no guarantees as to the privacy policies of external pages that we link to
- If and when we collect personal information and non-identifiable data on our website, we do so in compliance with Canada’s Anti-Spam Legislation (CASL), the Personal Information Protection and Electronic Documents Act (PIPEDA), and the Personal Health Information Protection Act (PHIPA), where and as applicable.
- Data collected on our website is subject to MSL’s General Privacy Statement and the operating policies noted therein. The statement and policies address the handling, retention and destruction of information, as well as consent procedures among other privacy related matters