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10 Principles of Privacy

The Children's Aid Society of London and Middlesex (CASLM) is responsible for personal information under our control and is committed to a high standard of privacy for our information practices. The Child, Youth and Family Services Act (CYFSA) protects your personal information and is based on 10 privacy principles.

Principle 1 – Accountability for Personal Information

CASLM is responsible for personal information under its control and has designated an individual, our Privacy Officer, who is accountable for compliance with Part X (10) of the CYFSA at all of our agency work sites.

CASLM complies with the CYFSA by:

  • implementing policies and procedures to protect your personal information, and all other confidential information including information relating to service users, staff and affiliates (affiliates include child protection workers, support staff, students, volunteers, care providers, researchers, and contracted individuals and visitors who are not paid by CASLM but have a working relationship with CASLM);
  • responding to inquiries for access to and disclosure of your personal information in accordance with laws, regulations, policies and procedures;
  • responding to breaches, complaints and requests for corrections of your personal information in accordance with laws, regulations, policies and procedures; and
  • educating our staff and affiliates about privacy policies and practices.

Principle 2 – Identifying Purposes for the Collection of Personal Information

CASLM will identify the purposes for which your personal information is collected at the time of first contact when collection commences. Additional details related to the collection of your personal information will be discussed in the course of service provision as required and in accordance with our policy and procedures. 

The purposes for collection of your personal information will be conveyed by means of posters, brochures and this website. 

The primary purpose of collecting, using and sharing your personal information is to deliver child welfare services to you and your family as prescribed by our mandate and related regulations. We also use your information:

  • for administrative purposes,
  • to collect statistics,
  • to promote learning that is informed by practice,
  • for program development; and,
  • to comply with our legal and regulatory requirements.

Principle 3 – Consent for the Collection, Use and Disclosure of Personal Information

The CASLM will make reasonable efforts to ensure that your personal information is not collected without authority.  The CASLM is mandated to receive reports of child abuse or mistreatment and respond to those that meet the threshold for investigation and service as defined in the Ontario Child Welfare Eligibility Spectrum Code, 2016.

To the extent possible, personal information for the purposes of delivering child welfare services by the CASLM will be:

  • collected with the consent of the individual to whom the personal information relates;
  • collected directly from the individual to whom the information relates; and
  • limited to the amount of information necessary to provide the service.

Depending on the circumstance we may rely on either your implied consent or your explicit consent or both to the collection and use of your personal information.

Under all circumstances, CASLM staff will clearly identify themselves and their role when engaging with you. 

The indirect collection of information pertaining to you may occur without your consent under the following defined circumstances:

  • where permitted or required by law (e.g. receiving a complaint in accordance with the duty to report); or
  • when the information is reasonably necessary to provide child welfare services or to assess, reduce or eliminate a risk of serious harm to a person or group and it is not reasonably possible to collect personal information directly that can reasonably be relied upon as accurate and complete, or in a timely manner.

Disclosure refers only to giving your personal information to another individual or organization.  Disclosure will only occur with your knowledge and consent, except in those circumstances as permitted by Part X, s. 292(1) of the CYFSA.  

Principle 4 – Limiting Collection of Personal Information

The CASLM will only collect the information that is necessary to fulfill our mandate to protect children and youth. All information will be collected by fair and lawful means.

Principle 5 – Limiting Use and Disclosure of Personal Information

Your personal information will only be used and/or disclosed by the CASLM for the purposes for which it was collected, except with your consent and knowledge or as required by law.

Principle 6 – Ensuring Accuracy of Personal Information

The CASLM will make every effort to ensure that the information we hold is accurate, complete for the purposes for which it is to be used and is as up-to-date as possible. 

Principle 7 – Ensuring Safeguards for Personal Information

The CASLM has prescribed practices as well as security safeguards of physical property and electronic systems to support the protection of your sensitive personal information.  We aim to protect you against loss, theft, and unauthorized access, disclosure, copying, use or modification of your records regardless of format. Protection may include physical measures (e.g. locked filing cabinets and restricted access), organizational measures (e.g. limiting access on a ‘need-to-know’ basis), and technological measures (e.g. password protected access). 

All new staff and affiliates receive orientation specific to privacy and confidentiality and are required to enter into confidentiality agreements as a condition of their employment or retention. Outside Services Providers are bound to privacy and confidentiality as a condition of the contract.  

Principle 8 – Openness About Personal Information Policies and Practices

The CASLM makes information about our privacy policy and practices available by means of posted notices and brochures within the reception area of our main office and satellite offices, as applicable. Additionally, the information is posted on the CASLM website page. Information provided includes:

  • contact information to reach the CASLM’s Privacy Office, to which inquiries and complaints can be forwarded;
  • the process for a service recipient to access their personal information held by the CASLM; and
  • a description of the type of personal information held by the CASLM, including general explanation of its use, and common examples of how the information may be shared.

Principle 9 – Individual Access to Own Personal Information

Upon written request, within a reasonable time, you will be informed whether the CASLM has a record of your personal information and will be given access to it, as requested.  You may challenge the accuracy and completeness of your records, and request that it be amended as appropriate.

Exceptions to providing access will be limited and specific. This may include information that refers to other individuals, cannot be disclosed for legal or security reasons, and/or is subject to solicitor-client or litigation privileges.

An individual must provide sufficient information to permit the CASLM to identify the existence of personal information, which may include identification of involved third parties.

Principle 10 – Challenging Compliance with the CASLM’s Privacy Policy and Practices

The CASLM aspires to meet and/or exceed the above principles.  The Privacy Officer is available to receive and hear concerns related to our compliance with privacy laws and our privacy policy.  The CASLM will review all complaints received and will investigate to the extent required.  If a complaint is justified, the CASLM will take appropriate measures including, if necessary, amending our policies and procedures.

Additionally, the Information and Privacy Commissioner of Ontario is available to receive and evaluate complaints that pertain to compliance by the CASLM with the above principles. They can be reached at https://www.ipc.on.ca/.

 

 

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