George Jeffrey Children's Centre

Privacy of personal information is an important principle to the George Jeffrey Children's Centre. We are committed to collecting, using and disclosing personal information responsibly, and only to the extent necessary for the services we provide. We also attempt to be open and transparent as to how we handle personal information. This document describes our privacy policies.

What Is Personal Information?

Personal information is information about an identifiable individual. Personal information includes information that relates to their personal characteristics (e.g., gender, age, income, home address or phone number, ethnic background, family status), their health (e.g., health history, health conditions, health services received by the individual) or their activities and views (e.g., religion, politics, opinions expressed by an individual, an opinion or evaluation of an individual). Personal information is to be contrasted with business information (e.g., an individual's business address and telephone number), which is not protected by privacy legislation.

Who We Are

The George Jeffrey Children's Centre includes, at the time of writing, various clinicians, administrative staff, health information staff, day care staff, maintenance and housekeeping staff. We use five consultant companies that may, in the course of their duties, have limited access to personal information we hold. These include computer consultants, accountants and mail distributors. We restrict their access to any personal information we hold as much as is reasonably possible. We also have their written assurance that they follow appropriate privacy principles. We also provide volunteer, cooperative student and clinical student placement opportunities. We restrict their access to any personal information we hold as much as is reasonably possible. Clients are also advised when volunteers or students are working directly with clinicians. We also obtain written assurance of confidentiality of appropriate privacy principles.

Collection Of Personal Information: Primary Purposes

About Clients
We collect, use and disclose personal information in order to serve our clients. Regarding clients, the primary purpose for collecting personal information is to provide assessment and treatment. For example, we collect information about a client's health history, including their family history, physical condition and function and social situation in order to help us assess clinical needs, to advise of clinical options, and then to provide the clinical care they choose. A second primary purpose is to obtain a baseline of health and social information so that in providing ongoing health services we can identify changes that occur over time. It would be rare for us to collect such information without the express consent of the client or guardian of the client. This would only occur in the event of an emergency.

About Members of the General Public
For members of the general public, our primary purposes for collecting personal information are to provide notice of special events (e.g., educational sessions offered, fundraising ventures, special events notification). We may collect home addresses, fax numbers and e-mail addresses. We attempt to obtain consent before using such personal information, but where this is not, for any reason, possible, we will upon request immediately remove any personal information from our distribution list.

On our website we only collect, with the exception of cookies, the personal information you provide and only use that information for the purpose you gave it to us (e.g., to respond to your e-mail message, to register for a course, to obtain information, to subscribe to our newsletter). Cookies are only used to help you navigate our website, and are not used to monitor you.

About Contract Staff, Volunteers and Students
For people who are contracted to do work for us (e.g., temporary workers), our primary purpose for collecting personal information is to ensure we can contact them in the future (e.g., for new assignments) and for necessary work-related communication (e.g., sending out pay cheques, year-end tax receipts). Examples of the type of personal information we collect for those purposes include home addresses and telephone numbers. It is rare for us to collect such information without prior consent, but it might happen in the case of health emergency (e.g., a SARS outbreak) or to investigate a possible breach of law (e.g., if a theft were to occur at the Centre). If contract staff, volunteers or students wish a letter of reference or an evaluation, we will collect information about their work related performance and provide a report as authorized by them.

About Permanent Employees

We Collect Personal Information: Related And Secondary Purposes

Like most organizations, we also collect, use and disclose information for purposes related to or secondary to our primary purposes. The most common examples of our related and secondary purposes are as follows:

To invoice clients for goods or services that were not paid for at the time, to process credit card payments or to collect unpaid accounts.
To advise clients and others of special events or opportunities (e.g., a seminar, development of a new service, distribution of newsletter)
To forward information to clients and others regarding fundraising campaigns
To provide receipts to clients and donors for payments and donations
To review client, financial, and human resources files for the purpose of ensuring that we provide high quality services, including assessing the performance of our staff. In addition, external consultants (e.g., auditors, lawyers, practice consultants, voluntary accreditation programs) may on our behalf do audits and continuing quality improvement reviews of our Centre, including reviewing client files, staff files, financial files, and interviewing of staff.
Centre clinicians are regulated by their respective colleges who may inspect our records and interview our staff as part of their regulatory activities in the public interest. In addition, as professionals, we will report serious misconduct, incompetence or incapacity of other practitioners, whether they belong to other organizations or our own. Also, our Centre believes that it should report information suggesting serious illegal behaviour to the authorities. External regulators have their own strict privacy obligations. Sometimes these reports include personal information about our clients, or other individuals, to support the concern (e.g., improper services, child abuse or neglect). Also, like all organizations, various government agencies (e.g., Information and Privacy Commissioner, Human Rights Commission, Government funding body, etc.) have the authority to review our files and interview our staff as a part of their mandates. In these circumstances, we may consult with professionals (e.g., lawyers, accountants) who will investigate the matter and report back to us.
The cost of some goods/services provided by the Centre to clients is paid for by third parties (e.g., OHIP, Assistive Devices Program). These third-party payers often have your consent or legislative authority to direct us to collect and disclose to them certain information in order to demonstrate client entitlement to this funding.
Required employee information may be shared with health and insurance benefits providers with whom the Centre is contracted. Information may also be shared with our financial institution for payroll and company RRSP purposes.
You can choose not to be part of some of these related or secondary purposes (e.g., by declining to receive notice of special events or opportunities, by declining to receive our newsletter, by paying for particular non-funded services in advance). We do not, however, have much choice about most of the related or secondary purposes guided by external regulations.

Protecting Personal Information

We understand the importance of protecting personal information. For that reason, we have taken the following steps:

Paper information regarding clients, employees, and others is either under supervision or secured in a locked or restricted area.
Electronic hardware is either under supervision or secured in a locked or restricted area at all times. In addition, passwords and security levels of access are used on individual computers.
Paper information is transmitted through sealed, addressed envelopes or boxes by reputable companies.
Electronic information is stored on a secured server with back up.
Staff are trained to collect, use and disclose personal information only as necessary to fulfill their duties and in accordance with our privacy policy and legislation.
External consultants with access to personal information must enter into privacy agreements with us.

Retention And Destruction Of Personal Information

We are required to retain and destroy personal information as per legislated guidelines. We retain and destroy records as follows:

Upon discharge, client files are retained for a period of 10 years from 18th birthday, or if adult or deceased, for a period of 10 years.
Financial and payroll records are retained for a period of 7 years.
Human resources records are retained for a period of 7 years from termination date.
We retain indefinitely a client discharge registry noting client name, date of birth and Centre discharge date.
We retain indefinitely an employee registry noting employee name, date of birth, social insurance number, position(s) held, start date, termination date, last known address and last known telephone number.

Paper files containing personal information are destroyed by shredding. Electronic personal information is destroyed by deleting it and, when the hardware is discarded, we ensure that the hard drive is erased or destroyed.

If you have a privacy concern, please contact our Privacy Officer at 625-6799

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